Bandhua Mukti Morcha v. Union of India (1984)

Quick Summary

An NGO wrote a letter about bonded labour in Faridabad quarries. The Supreme Court treated it as a writ petition under Article 32. It found grave violations of dignity and freedom from forced labour, and ordered identification, release, and rehabilitation of workers plus strict enforcement of labour laws.

Issues

• Can a letter be treated as a PIL under Article 32?
• Are governments duty-bound to secure and rehabilitate bonded workers?
• Did authorities fail to enforce labour laws (Mines Act, Bonded Labour Act, Inter State Migrant Workmen Act)?
• Were working and living conditions contrary to Articles 21 & 23?

Rules

Articles 21 & 23: Life with dignity and freedom from forced labour are non-negotiable.

State Duty: Prevent bonded labour; enforce labour statutes; provide protection and rehabilitation.

Access to Justice: Procedural technicalities cannot block relief in public interest matters.

Arguments

Judgment

Held: The Court accepted the letter as a writ (Article 32), expanded PIL, and issued directions to identify, release, and rehabilitate bonded workers. It mandated enforcement of labour laws and provision of medical care, housing, and welfare benefits.

• Forced labour under Article 23 includes bondage due to debt or economic compulsion.
• Article 21 covers dignity, humane work conditions, and health.
• State agencies failed to supervise and enforce the statutes.

Technical objections cannot block justice where fundamental rights are at stake.

Ratio (Core Legal Principle)

Courts may relax procedure in public interest to protect fundamental rights. Bonded labour = forced labour (Art. 23). The State must act to secure dignity, health, and humane work (Art. 21).

Why It Matters

• Launchpad for social-action PIL via letters.
• Strong stance against bonded labour nationwide.
• Push for health, housing, sanitation, education at worksites.

Key Takeaways

1. Letter can be a PIL when public rights are involved.
2. Bonded labour = forced labour; bans are absolute.
3. Rehabilitation + strict enforcement are mandatory duties.

Mnemonic + 3-Step Hook

Mnemonic: “L-E-T-T-E-R” → Letter as PIL • Enforce labour laws • Track bonded workers • Treat with medical care • Educate families • Rehabilitate fully.

1. Identify bonded workers through field checks.
2. Release & Rehabilitate with jobs, housing, benefits.
3. Monitor compliance and punish violations.

IRAC

Glossary

Bonded Labour

Work extracted due to debt or compulsion; banned under Article 23 and the 1976 Act.

PIL

Public Interest Litigation—allows action for community rights, with flexible procedure.

Rehabilitation

Support for released workers: wages, housing, health, education, and livelihood schemes.

FAQs

Related Cases

• People’s Union for Democratic Rights v. Union of India — Forced labour & Art. 23
• Olga Tellis v. Bombay Municipal Corporation — Article 21 and livelihood
• M.C. Mehta cases — Enforcement of labour and environmental duties