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The Intersection of Religion and Labour: Insights from Tirumala Tirupati Devasthanam v/s Commissioner Of Labour

Tirumala Tirupati Devasthanam vs. Commissioner Of Labour And Ors.

Case Background
The subject of whether certain TTD workers were entitled to be classified as "workmen" under the Industrial Disputes Act, 1947, and whether they might seek protection and benefits under the Act, is at the centre of the case Tirumala Tirupati Devasthanam (TTD) vs. Commissioner of Labour and Others.

Tirumala Tirupati Devasthanam vs. Commissioner Of Labour And Ors.
Equivalent Citations: (1996) IIILLJ 362 SC, 1995 Supp (3) SCC 653
Date of Decision: 19 August 1993
Parties Involved:
  1. Tirumala Tirupati Devasthanam - Appellant
  2. Commissioner Of Labour and Others � Respondents
Author: Alladi Kuppuswami
Bench: A Kuppuswami, M Rao
Judgment: Alladi Kuppuswami, J

Facts of the Case

A well-known religious organisation in India called Tirumala Tirupati Devasthanam (TTD) is in charge of running the affairs and administration of the Tirumala Venkateswara Temple in Andhra Pradesh. The TTD hired a variety of people to carry out a variety of tasks and services inside the temple complex.

Some employees of the temple complex asserted that they should be given the same treatment as "workmen" under the 1947 Industrial Disputes Act. They argued that because they were performing different chores linked to temple rites, they should be entitled to the protection and benefits provided by the Act to "workmen."

Issue(s) Presented:
  1. Whether the temple employees of TTD can be considered "workmen" under the Industrial Disputes Act, 1947?
  2. Whether the Commissioner of Labour has the authority to issue directions for the regularization of services of TTD employees?
  3. Whether the Commissioner of Labour's order is legally valid?
Legal Provisions Involved:
The case primarily deals with the interpretation of various provisions of the Industrial Disputes Act, 1947, and other relevant labour laws.

Court's Decision:
In its ruling from 19 August 1993, the Supreme Court of India decided that the people employed by the Tirumala Venkateswara Temple could not be regarded as "workmen" for the purposes of the Industrial Disputes Act, 1947.

The Court's justification focused principally on the character of the tasks carried out by these people. It noted that the work they were doing was primarily spiritual and religious in character and that they were managing a temple, a revered location. The definition of "workmen" under the Act, according to the Court, was only designed to apply to industrial and commercial activity; it was not supposed to include solely religious or spiritual activities.

The Court also emphasised how closely tied to religion the temple and its operations were, warning against the potential complexities and interruptions that might result from labour laws getting involved.

In conclusion, the court's ruling in this case supported the line separating exclusively spiritual and religious pursuits from commercial or economic endeavours. It was decided that anyone taking part in religious activities within a temple complex could not be regarded as "workmen" for the purposes of the Industrial Disputes Act, 1947, and as a result, they were not eligible for the protection and benefits provided by the Act.

According to me, I don't agree with the reasoning given by the court. As the main contention point in this case is whether the persons working in the TTD would be considered as an workman or not where they have given example where the temple community when they sell gold there is no tax levied on that sold amount, and another contention point was the main source of income is a charitable income and not of a business.

But the people working in the water department and other departments they work as an normal employee, they don't have any link with the service of the deity like priests, if any dispute occurs with the employees and TTD, the employer will always state that they have no right as they have no right as they are not part of the trade union. So by doing this the rights of the common employees have been hampered.

The case of Tirumala Tirupati Devasthanam vs. Commissioner Of Labour And Ors. is noteworthy because it established the notion that religious organisations, regardless of nature, are subject to labour regulations in India. It emphasises the need of safeguarding the rights and welfare of employees within such organisations and acknowledges the necessity to strike a balance between religious autonomy.

This ruling has affected how labour laws are applied by religious organisations all throughout India and has clarified the responsibility that religious institutions have to their employees under the law.

It should be noted that this commentary gives a broad summary of the case and its importance. You can consult legal analyses, articles, or the complete text of the Supreme Court's decision for a more in-depth study.

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