Federal Constitutional Court - Complaints against minimum wage in Yoga Center unsuccessful
A Yoga- and Meditation center failed at the Federal Constitutional Court due to constitutional complaints. The association wanted to challenge judgments of the Federal Labor Court, which ruled that two former members were entitled to the statutory minimum wage for their work at the Yoga-Ashram, a spiritual retreat center. The Karlsruhe Senate did not accept the constitutional complaints, according to the court. They did not meet the legal requirements and there was no reason for acceptance. (Az. 1 BvR 2244/23; 1 BvR 2231/23)
The labor courts in Erfurt had decided in April 2023, among other things, that a former priestess from the Yoga-Ashram was entitled to the statutory minimum wage instead of a tip for her services. The successful plaintiff was a member of Yoga Vidya e.V. from 2012 to 2020 and worked as a "Sevaka" (Servant) in seminar planning and online marketing. The nationwide acting association with its seat in Horn-Bad Meinberg in North Rhine-Westphalia sees itself as a spiritual-religious community.
Yoga as Religion?
The labor court ruled at that time that the plaintiff had rendered services not as a member of the association or of a worldview community, but as an employee. Therefore, she was entitled to the minimum wage. The case of a second Ashram member also proceeded similarly. The association saw its right to free religious exercise violated and filed a constitutional complaint. The Sevaka service was an integral part of their faith and not to be evaluated as work, explained a spokesperson before the decision.
Whether the assumption of the Federal Labor Court that the association is not a religious community with the constitutionally protected freedom of religion is compatible, remains open, now stated the Federal Constitutional Court. "For neither has it been proven nor is it otherwise apparent that the services rendered by the plaintiffs for the maintenance of the lodging and seminar business of the association and the sale of Yoga products, for whose labor law assessment it is relevant here, were religiously motivated."
- The Yoga- and Meditation center's complaint regarding the statutory minimum wage for its members at the Federal Labor Court was initially filed in North Rhine-Westphalia, where their association is based.
- Despite the rejection of their constitutional complaints by the Karlsruhe Senate, the association decided to escalate the issue to the Federal Constitutional Court, citing a violation of their religious freedoms.
- In Erfurt, a former member of the Yoga-Ashram successfully argued for the statutory minimum wage, as her work was classified as an employment, not a religious service. Despite this, the association, arguing for their fundamental right to religious exercise, filed a constitutional complaint at the Federal Constitutional Court.
- The Federal Labor Court's assumption that the association is not a religious community with constitutionally protected religious freedoms is being challenged by the Federal Constitutional Court in Karlsruhe. The court is currently considering whether the association's services were religiously motivated, which could potentially impact their labor law situation.
- The Federal Constitutional Court's decision on this constitutional complaint is highly significant, as it may set a precedent for the status of spiritual-religious communities in the German labor market and their right to exercise their beliefs without infringing on labor laws.
