Is the entire TTD an industry?

No. As a whole, TTD is a religious body, not an industry. But some utility-like departments can be treated as industries.

Are TTD department staff ‘workmen’?

Yes, if they work in departments that function like an industry (e.g., water, power). They can form and register a union.

What tests did the Court use?

The Dominant Nature Test and the Triple Test to see if the activity is systematic, service-oriented, meets human wants, and involves cooperation.

Could TTD challenge the registration?

Yes. TTD had locus standi because the decision directly affected its employer–employee relations.

What was the final outcome?

Water & Power Workers Union stayed registered; the general employees’ union could not be registered.

Tirumala Tirupati v. Commissioner of Labour

Quick Summary

TTD is mainly a religious body, so the whole institution is not an “industry.” But some utility-style departments work like industries. Staff in those departments are “workmen” and can register a trade union. TTD could challenge the registration because it affects its employment relations.

Dominant Nature Test: Look at the institution’s main character.
Triple Test: Systematic activity, services meeting human wants, and employer–employee cooperation.

Issues

Can TTD be generally treated as an “industry”?
Are its employees “workmen” under labour law?
Can they form and register a trade union?
Does TTD have locus standi to contest union registration?

Rules

Dominant Nature Test: Focus on the main character of the institution and the integrated nature of departments.
Triple Test: (a) Systematic activity; (b) service/production that meets human wants; (c) cooperation between employer and employees.
Where a specific department meets these tests, it may be treated as an “industry” even if the whole body is religious.

Facts (Timeline)

CASE_TITLE

TTD manages major temples; large pilgrim inflow and donations.
Workers—especially in Water & Power—sought union registration as “workmen.”
Registrar granted registrations in 1970.
TTD objected: religious body, not industry; employees not “workmen.”
Sec. 10 TUA cancellation sought by TTD; Registrar refused in 1975.
TTD filed W.P. No. 840/1976 (Water & Power Union) and W.P. No. 1866/1976 (general employees’ union).
TTD argued the Endowments Act governed its staff, not TUA.

Timeline for TTD industry and union registration dispute

Arguments

TTD (Petitioner)

TTD is religious; not an “industry.”
Employees are governed by Endowments law, not TUA.
General staff do not fit “workmen”; registrations erroneous.

Employees/Registrar (Respondents)

Utility departments run systematic services like an industry.
Such staff are “workmen”; unions validly registered.
Dominant/Triple Tests support department-wise industry status.

Judgment

Held

Whole institution: TTD is not an industry due to its dominant religious character.
Departments: Water/Electricity units satisfy the tests; they are industries.
Workmen & Unions: Staff of those departments are workmen and may register unions.
Locus standi: TTD can challenge registrations.
Result: W.P. 840/1976 dismissed (utility union stands). W.P. 1866/1976 allowed (general union not registrable).

Judgment illustration for TTD industry case

Ratio Decidendi

Use Dominant Nature Test for the institution and Triple Test for activities. A religious body may host departments that are “industries”; their staff are workmen with union rights.

Why It Matters

Explains how mixed religious–service institutions are treated under labour law.
Confirms department-wise union rights where industrial features exist.
Clarifies standing to challenge union registration decisions.

Key Takeaways

TTD overall ≠ industry; utility departments can be.
Department staff with industrial features = workmen.
Such staff may form and register trade unions.
TTD had locus to contest registrations.

Mnemonic + 3-Step Hook

Mnemonic: “RELi-UTIL” — RELigious whole, UTILity parts are industries.

Identify: Whole vs department.
Apply Tests: Dominant Nature + Triple Test.
Decide: Workmen & unions valid where industrial features exist.

IRAC Outline

Issue

Industry status of TTD and its departments; workmen status; union registration; TTD’s locus standi.

Rule

Dominant Nature Test + Triple Test; department-wise analysis under TUA/IDA principles.

Application

Religious core ≠ industry; utilities meet tests; staff = workmen; unions valid; TTD may challenge.

Conclusion

Utility union stands; general union disallowed; mixed character recognized.

Glossary

Dominant Nature Test: Checks the main character of a multi-activity body and how departments integrate.
Triple Test: Looks for systematic activity, service/production meeting human wants, and employer–employee cooperation.
Locus Standi: Right to bring a challenge because one is directly affected.