The Gujarat High Court has ruled that a temple priest performing religious duties cannot be treated as a “workman” under the Industrial Disputes Act, 1947. The court dismissed a Letters Patent Appeal filed by a former pujari who challenged the rejection of his labour dispute against a temple trust.
A division bench comprising Justice Bhargav D. Karia and Justice L.S. Pirzada delivered the judgment on 16 February 2026.
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Background of the Case
The dispute began when Umeshwar Akshaywar Dubey, who had been serving as a pujari in a temple run by Shree Sainath Sarvajanik Seva Mandal Trust since 1999, alleged that his services were terminated on 30 November 2012 without notice, compensation, or due process.
According to Dubey, the temple trust was engaged in several activities including selling prasad items such as bundi laddus and coconuts. He claimed that these activities amounted to commercial operations and therefore the trust should be treated as an “industry” under the Industrial Disputes Act.
On this basis, he approached the Labour Court seeking reinstatement with continuity of service and full back wages.
However, the Labour Court in Navsari examined the issue as a preliminary question and concluded that Dubey did not fall within the definition of a “workman” under Section 2(s) of the Industrial Disputes Act. Consequently, the reference was rejected for lack of jurisdiction.
Dubey then challenged the order before the Gujarat High Court through a Special Civil Application, but the single judge upheld the Labour Court’s decision. The present Letters Patent Appeal was filed against that ruling.
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Counsel for the appellant argued that the temple trust was involved in commercial activities and employed several workers for administrative and operational work.
He contended that because the trust sold prasad and managed various activities through multiple employees, it should qualify as an “industry.” According to him, the duties performed by the pujari were service-oriented and therefore could fall within the scope of “workman” under the Act.
The appellant also relied on judgments from other High Courts where religious institutions conducting substantial commercial activities were treated as industries.
On the other hand, the trust argued that its primary function was religious and spiritual. The management maintained that a temple established for worship and spiritual service could not be equated with an industrial establishment.
It also emphasized that the role of a pujari is essentially religious and cannot be categorized as manual, technical, clerical, or supervisory work as required under the Industrial Disputes Act.
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The High Court examined the statutory definitions under Section 2(j) and Section 2(s) of the Industrial Disputes Act.
The bench noted that the Act defines a “workman” as a person employed in an industry to perform manual, skilled, technical, operational, clerical, or supervisory work. Religious functions like conducting puja or performing rituals do not fall within these categories.
Referring to several precedents, the court emphasized that the dominant nature of an institution must be considered when determining whether it qualifies as an industry.
The bench observed that temples primarily exist to provide spiritual and religious services to devotees. Even if some ancillary activities such as sale of prasad take place, they are incidental to the religious purpose and do not transform the institution into an industrial establishment.
The court also relied on earlier rulings where priests and similar religious functionaries were held not to be “workmen” under labour law.
After considering the arguments and precedents, the Gujarat High Court concluded that the Labour Court and the single judge had committed no error in their findings.
The bench held that a pujari performing religious duties in a temple does not fall within the definition of “workman” under Section 2(s) of the Industrial Disputes Act. As a result, the Labour Court had no jurisdiction to adjudicate the dispute raised by the appellant.
Accordingly, the court dismissed the Letters Patent Appeal and upheld the earlier orders rejecting the labour dispute.
Case Title: Umeshwar Akshaywar Dubey v. Shree Sainath Sarvajanik Seva Mandal Trust & Anr.
Case No.: Letters Patent Appeal No. 2319 of 2017
Decision Date: 16 February 2026
