Temple Trust not covered by Industrial Disputes Act’s ‘Industry’ definition, says SC

In a significant labour law face-off involving religious institutions and employee rights, the Supreme Court stepped in to address a decades old dispute over whether a temple trust can be treated as an “industry” under labour laws. The appeal raised high stakes for a former accountant who claimed illegal termination after years of service, forcing the court to examine the limits of the Industrial Disputes Act and the fairness of the employer’s conduct.

The controversy began when the appellant, appointed as an accountant with a temple trust in 1977, claimed he was orally terminated in 1999 after over a decade of continuous service. His repeated pleas for reinstatement went unanswered, leading him to approach labour authorities. The trust, however, took the stand that as a charitable religious institution, it did not fall within the definition of an “industry” under Section 2(j) of the Industrial Disputes Act.

While the workman relied heavily on the landmark Bangalore Water Supply judgment to argue that profit motive is irrelevant, both the Labour Court and the High Court rejected his claim, holding that a temple trust does not qualify as an industry.

While the Bench agreed that the trust could not be brought “within the four corners of the expression ‘industry’,” it took a hard look at how the employee was treated. The Court noted that the termination was oral, carried out without any inquiry, and followed by an unwarranted transfer to a distant location.

Calling for a pragmatic closure, the Court decided the dispute could be resolved through compensation rather than prolonged litigation, directing the trust to pay Rs.12 lakh to the workman as full and final settlement. Consequently, the appeal was disposed of with a direction to pay the amount within four weeks, failing which interest would apply.

Case Title: Indravadan N. Adhvaryu Pipala Fali Modhvada Vs. Laxminarayan Dev Trust And Anr

Case No.: Civil Appeal No.7549 Of 2011

Coram: Hon’ble Justice Aravind Kumar, Hon’ble Justice Prasanna B. Varale,

Advocate for the Petitioner: Sr. Adv. Nachiketa Joshi, AOR P. V. Saravanaraja, AOR Bhushan Mahendra Oza, Adv .P. Veerappan, Adv. kh Farukpasha Bashumiya, Adv. Dikshit, Adv.  Sanjay Akumar Upadhyay, Adv.  M.J. Riaz Ahamed, Adv.  Muskan, Adv.  Bachita Baruah, Adv.  Vikash Kumar, Adv. Monika Shrivastava, Adv.  Satyendar Saxena, Adv. Krishna Kumar Yadav,

Advocate for the Respondent: AOR Anil Kumar Mishra-I, Adv. ntha Sinha, Adv. Navneet Jha, Adv. Rahul Singh,

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