I believe it's measured in the shade only so it's a true measure of the air temperature and isn't affected by the direct heat transfer from the sunlight. (eg https://www.forbes.com/sites/dennismersereau/2021/06/30/the-... )
> Temperatures measured directly on the ground may exceed air temperatures by 30 to 50 °C (54 to 90 °F).[6] The highest natural ground surface temperature ever recorded may have been an alleged reading of 93.9 °C (201.0 °F) at Furnace Creek, California, United States, on 15 July 1972.[7] In 2011, a ground temperature of 84 °C (183.2 °F) was recorded in Port Sudan, Sudan. [1]
[1] https://en.wikipedia.org/wiki/List_of_weather_records#Measur...
Filling the void and dead air time, commentators resorted to demos like "frying an egg on center court" to show just how hot it was.