Supreme Court upheld termination of temple trust accountant after 12 years of service, ruling trusts managing temples fall outside Industrial Disputes Act’s Section 2(j) “industry” definition. The bench affirmed the Labour Court’s finding that Laxminarayan Dev Trust, being a charitable religious institution without a profit motive, engages no systematic manufacturing or economic activity qualifying as industry.
Despite oral termination lacking a formal inquiry, violating natural justice, the Court declined reinstatement since ID Act protections don’t apply to non-industrial temple trusts. Justice exercised Article 142 power,s granting Rs 12 lakh lump sum compensation, recognizing 12 years’ unblemished service against unwarranted distant transfer demand.
The judgment navigates Bangalore Water Supply precedent’s broad functional test but defers to precedents excluding religious charities from labour law burdens that could disrupt devotional functions. Transfer to remote Vadtal deemed punitive without due process, though trust status shielded from full reinstatement obligations.
