Temple Trust Is Not an ‘Industry’ Under Labour Law: Supreme Court

The Supreme Court of India has ruled that a temple trust cannot be treated as an “industry” under the Industrial Disputes Act. Because of this, labour law protections under the Act do not apply to employees working in such trusts.

The case involved an accountant who had worked for over 12 years at the Laxminarayan Dev Trust. His services were ended without a formal inquiry, and he was later asked to report to a distant location. When his requests for reinstatement were ignored, he approached labour authorities.

The Labour Court rejected his claim, holding that the trust was a religious and charitable institution, not an industry. This view was upheld by both a Single Judge and a Division Bench of the Gujarat High Court.

A Supreme Court Bench comprising Justices Aravind Kumar and Prasanna B. Varale agreed with the lower courts. It said a temple trust does not fall within the legal definition of an industry, as it does not carry out commercial or profit-oriented activities.

However, considering the employee’s long and unblemished service and the fact that no inquiry was conducted before termination, the Court ordered the trust to pay ₹12 lakh as one-time compensation. The amount must be paid within four weeks, failing which interest at 9% per annum will apply.