Naphade: as far as university is concerned,... ... 'Industry' Definition Reference : Live Updates From Supreme Court 9-Judge Bench Hearing

Naphade: as far as university is concerned, teachers are not workmen. even bangalore water supply proceedings on that assumption. the other staff members, their help is of marginal nature. the judgment also refers to univeristy having transport department, these are incidental activities. in nagpur, the court formulates the test of essential and primary functions