The Supreme Court held that, “Even though an educational institution has to be treated as an industry, the teachers employed by educational institutions whether the said institutions are imparting primary, secondary, graduate or post graduate education cannot be called as ‘workman’ within the meaning of Section 2(s) of the Industrial Disputes Act, 1947”. Imparting of education which is the main function of teachers cannot be considered as skilled or unskilled manual work or supervisory work or technical work or clerical work. University of Delhi v. Ramnath, (1964) 2 S.C.R. 703 overruled in Bangalore Water Supply & Sewerage Board. v. R. Rajappa, (1978) 3 S.C.R. 207.