LLM Notes: Supreme Court Judgment " People's Union for Democratic Rights v. Union of India 1982"

 The Supreme Court's 1982 judgment in People's Union for Democratic Rights v. Union of India (AIR 1982 SC 1473) is a landmark ruling that expanded the scope of fundamental rights and reinforced labor protections through public interest litigation (PIL). Here's a breakdown:

Background

The case arose from a PIL filed by the People’s Union for Democratic Rights, highlighting labor rights violations during construction projects for the 1982 Asian Games in Delhi. Workers faced exploitative conditions, including:

• Non-payment of minimum wages (with contractors deducting ₹1 daily from wages).

• Child labor (children under 14 employed in hazardous work).

• Gender discrimination (women paid less than men in violation of the Equal Remuneration Act, 1976).

• Poor living conditions and lack of amenities under the Contract Labour Act, 1970.

The petitioners argued these violations breached Articles 21 (right to life with dignity), 23 (prohibition of forced labor), and 24 (ban on child labor)

Key Legal Issues

1. Locus Standi in PILs: Whether a third party could file a petition on behalf of marginalized workers.

2. State Responsibility: Whether the state (Union of India, Delhi Administration) could evade liability by blaming private contractors.

3. Labor Law Violations as Fundamental Rights Breaches: Whether non-compliance with labor laws (e.g., Minimum Wages Act, Contract Labour Act) amounted to constitutional violations.

Court’s Decision

1. Expanded Access to Justice:

   • The Court upheld the petitioners’ locus standi, emphasizing that PILs are essential for marginalized groups to seek redress.

   • Stated that Article 32 (right to constitutional remedies) could be invoked for systemic labor rights violations.

2. State Accountability:

   • Held that the state and its agencies (e.g., Delhi Development Authority) were responsible for ensuring contractors complied with labor laws, as they were the “principal employers”.

   • Directed authorities to enforce the Inter-State Migrant Workmen Act, 1979, and other labor laws.

3. Fundamental Rights Interpretation:

   • Article 21: Broadened to include “right to live with human dignity,” covering fair wages and safe working conditions.

   • Article 23: Non-payment of minimum wages was deemed a form of “forced labor”.

   • Article 24: Employment of children in construction (even if not explicitly “hazardous” under statutes) violated constitutional protections.

Impact

• Strengthened PIL Mechanism: Enabled civil society to champion workers’ rights through judicial intervention.

• Labor Rights as Fundamental Rights: Linked statutory labor protections (e.g., minimum wages) to constitutional guarantees, making them enforceable under Article 32.

• State Enforcement Mandate: Directed governments to proactively monitor contractors and penalize violations.

This judgment remains a cornerstone for enforcing socio-economic justice in India, ensuring the judiciary acts as a “protector of the oppressed”.

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