Supreme Court Refuses PIL On Temple Staff Wages, Asks Petitioners To Approach Appropriate Forum

The bench of Justices Vikram Nath and Sandeep Mehta held that the petition, filed under Article 32 of the Constitution, was not maintainable in its present form and observed that persons aggrieved could approach the appropriate forum instead of invoking the Court’s writ jurisdiction directly.

During the hearing, the Court also orally cautioned the petitioner against generalising or speculating on the earnings of temple functionaries, noting that such matters require factual assessment rather than broad assumptions.

The petition had sought directions to the Union and State governments to constitute a judicial or expert body to examine remuneration structures in Hindu Religious and Endowments institutions across States. It also sought a declaration that priests and temple staff should be treated as “employees” under the Code on Wages, 2019, arguing that State control over temple administration creates an employer-employee relationship that triggers constitutional obligations under Article 21.

The plea further raised issues of alleged wage disparities across States, claiming that temple staff in several jurisdictions receive minimal or inconsistent remuneration despite large-scale revenues generated by temple institutions. It relied on provisions of the Constitution, including Articles 14, 21, 38, 39 and 43, to argue that denial of minimum wages amounts to violation of the right to livelihood and dignity. 

"Petitioner also seeks a declaration that priests and temple staff are 'employee' under Section 2(k) of the Code on Wages, 2019. Petitioner submits that once the State assumes the administrative, economic and financial control over temples, an employer-employee relationship arises and denial of dignified wages to priests and temple staff violates the right to livelihood guaranteed under Article 21," the plea stated.

It also cited examples of State regulations governing temples, including restrictions on income allocation and differing administrative frameworks across States such as Tamil Nadu, Andhra Pradesh, Telangana, Kerala, Karnataka and others, to highlight what it termed systemic inconsistency in wage protections.

The petition said, “Priests and temple staff are not getting even the minimum wage prescribed by the State for unskilled and semi-skilled workers. This is a systemic exploitation.”

It referred to protests by priests in Andhra Pradesh and Telangana demanding minimum wages and alleged that the state, while controlling temple administration, was violating provisions of the Minimum Wages Act and Directive Principles under Article 43.

However, the Court declined to entertain the matter under its extraordinary jurisdiction, effectively leaving it open for the petitioner to pursue alternative legal remedies.