Are publication of books, manufacture of prasadam by temples an industrial activity, Supreme Court asks

Supreme Court questions if temple activities like book publishing and prasadam manufacturing qualify as industrial activities under current laws.

The Supreme Court on Wednesday (March 18, 2026) questioned whether activities such as publication and sale of books and manufacture of food associated with temples can be considered an industry.

The oral observation came from Justice B.V. Nagarathna, who is part of a nine-judge Bench headed by Chief Justice of India Surya Kant examining the ambit of the definition of ‘industry’ and whether it would include charities and hospitals.

The question was posed to the Commissioner of Hindu Religious and Charitable Endowments in Tamil Nadu. Senior advocate Jaideep Gupta, appearing for the Commissioner, referred to High Court decisions that temple trust activities such as manufacturing prasadam, running hotels or operating transport were an “industry” under the Industrial Disputes Act, 1947, and an “establishment” under the Shops and Establishments Act.

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Justice Nagarathna said she had authored a single-judge Bench judgment in the Karnataka High Court which had held that a temple was not an establishment under the Karnataka Shops and Establishments Act.

“But a Full Bench of the Madras High Court had held a temple to be an ‘industry’. The Orissa High Court had held the Jagannath temple to be an ‘industry’,” Mr. Gupta responded to the judge.