Reviewed case brief
Management of Safdarjung Hospital v Kuldip Singh Sethi
AIR 1970 SC 1407
AIR 1970 SC 1407 · Supreme Court of India
- Court
- Supreme Court of India
- Year
- 1970
- Subjects
- Labour Law
- Reviewed
- 2026-08-02
Rule established
An establishment carrying on activities of a philanthropic, charitable, or purely medical/educational nature, without a profit-making or commercial motive, does not constitute an 'industry' under Section 2(j) of the Industrial Disputes Act, since the systematic activity must be analogous to trade or business to qualify.
Facts
Issues
Held
Ratio decidendi
How to use it in an exam
Editorial source
AIR 1970 SC 1407; foundational authority narrowing the definition of industry, later reconsidered in Bangalore Water Supply v Rajappa (1978), cross-verify citation before exam use
Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.