Bandhua Mukti Morcha vs. Union of India||Case Summary|| 1984 3 SCC 161||Bonded Labor and Fundamental Rights
- Vinita Pathak
- 17 hours ago
- 2 min read
FACTS
Bandhua Mukti Morcha, a non-governmental organization (NGO), filed a Public Interest Litigation (PIL) under Article 32 of the Indian Constitution, highlighting the inhumane working conditions and bonded labor practices in stone quarries in the state of Haryana. The petition alleged violations of fundamental rights, particularly Articles 21 (Right to Life and Dignity), 23 (Prohibition of Forced Labor), and 24 (Prohibition of Child Labor).
The petitioners contended that the laborers were being subjected to exploitative conditions, denied basic amenities, and forced into bonded labor due to debts. The government of Haryana, however, denied these allegations and argued that labor laws were being implemented effectively.
ISSUES
Whether the laborers working in stone quarries were victims of bonded labor and if their fundamental rights under Articles 21, 23, and 24 were violated?
Whether the Supreme Court could expand the scope of Public Interest Litigation (PIL) and issue directions for social justice?
What is the responsibility of the state in ensuring the enforcement of labor laws?
RELEVANT CONSTITUTIONAL AND LEGAL PROVISIONS
Article 21: Right to life, including the right to live with dignity.
Article 23: Prohibits human trafficking and forced labor.
Article 24: Prohibits child labor in hazardous industries.
Bonded Labour System (Abolition) Act, 1976: Prohibits bonded labor and mandates the rehabilitation of freed laborers.
Mines Act, 1952: Regulates the working conditions in mines.
JUDGEMENT
The Supreme Court, led by Justice P.N. Bhagwati, ruled in favor of the petitioners and recognized bonded labor as a violation of fundamental rights. Key rulings included:
Right to dignity under Article 21 includes the right to fair working conditions, wages, and humane treatment.
The state has an obligation to identify, release, and rehabilitate bonded laborers under the Bonded Labour System (Abolition) Act, 1976.
Widening the scope of PIL, the Court held that NGOs and concerned citizens can approach the judiciary on behalf of marginalized sections who cannot represent themselves.
Directed the Haryana government to conduct an inquiry, take corrective measures, and ensure proper implementation of labor laws.
SIGNIFICANCE
Established PIL as a tool for social justice, allowing courts to intervene in cases of human rights violations.
Reinforced the judiciary’s proactive role in protecting the rights of marginalized workers.
Expanded the interpretation of Article 21, emphasizing the right to live with dignity beyond mere survival.
Led to stronger enforcement of labor laws and welfare measures for bonded laborers.
This landmark case paved the way for future judicial activism in labor rights and human rights cases in India.
Vinita Pathak
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