Dharmarth Trust Qualifies as ‘Industry’ Under Industrial Disputes Act: J&K&L High Court

The High Court of Jammu & Kashmir and Ladakh has held that the Dharmarth Trust cannot be treated as a purely religious or voluntary organisation and falls within the definition of an “industry” under the Industrial Disputes Act, 1947.

The Court noted that the Trust undertakes systematic activities, employs workmen for remuneration, and renders services that extend beyond exclusively spiritual or religious functions.

Applying the dominant nature test, it held that the Trust’s operations attract labour law obligations, making it amenable to industrial adjudication.

The Court clarified that mere religious affiliation does not place an organisation outside the scope of labour legislation.

[Dharmarth Trust J&K v. Industrial Tribunal & Anr.]