Chandra Bhavan Boarding & Lodging v. State of Mysore (1969) 3 SCC 84
Does the Minimum Wages Act, 1948 unreasonably restrict business freedom under Articles 14 and 19(1)(g)?
Quick Summary
The Supreme Court upheld the Minimum Wages Act, 1948. It said the law is a reasonable restriction on business under Article 19(6) and does not offend Articles 14 or 19(1)(g).
On these facts, the procedure used to fix wages was adequate. Not appointing a Section 5(1)(a) committee did not violate natural justice.
Issues
- Does wage fixation under the Act violate Articles 14 and 19(1)(g)?
- Is the Act an unreasonable curb on trade or business?
- Were principles of natural justice breached in issuing the notification?
Rules
Minimum Wages Act, 1948 is a social justice law. Business freedom under Art. 19(1)(g) allows reasonable restrictions for worker welfare.
Which natural justice rules apply depends on case facts and the statute’s built-in safeguards.
Facts (Timeline)
Arguments
Appellants (Hotel Owners)
- Wage fixation is arbitrary; hurts business freedom (Art. 19(1)(g)).
- No Section 5(1)(a) committee → breach of natural justice.
- Violates equality (Art. 14) by treating dissimilar units alike.
Respondent (State of Mysore)
- Act protects vulnerable workers; restriction is reasonable.
- Statute allows alternative procedure to collect data and consult.
- Classification is rational; notification follows the Act.
Judgment
Appeal dismissed. The Act is constitutionally valid. The Mysore notification stands.
Court granted six months to clear arrears with 6% p.a. interest. No violation of Articles 14 or 19(1)(g); procedure was sufficient for natural justice on these facts.
Ratio Decidendi
Minimum wage policy furthers social justice. Reasonable limits on business are valid when aimed at preventing exploitation. Natural justice is context-specific; the Act’s procedure met the need here.
Why It Matters
- Confirms strong constitutional backing for minimum wages.
- Clarifies that how the State fixes wages can vary within the Act.
- Guides future Article 14/19 challenges against wage notifications.
Key Takeaways
- Minimum wages = reasonable restriction under Art. 19(6).
- Article 14 attack fails if classification is rational and data-based.
- Section 5 procedure is flexible; fairness judged on facts.
Mnemonic + 3-Step Hook
Mnemonic: “MIN WAGE = MIN RIGHT? NO.”
- Purpose: Protect workers from exploitation.
- Power: Reasonable limits on business allowed.
- Process: If fair on facts → valid notification.
IRAC Outline
| Issue | Rule | Application | Conclusion |
|---|---|---|---|
| Are minimum wages unconstitutional? | Art. 19(1)(g) subject to reasonable restrictions; Act furthers social justice. | State gathered material and followed permissible procedure. | Law and notification upheld. |
| Natural justice breach? | Content of fairness varies by context and statute. | No committee ≠ automatic invalidity; facts show adequate safeguards. | No violation; arrears payable with 6% p.a., time given. |
Glossary
- Minimum Wages Act
- Law to set floor wages in scheduled employments to prevent exploitation.
- Reasonable Restriction
- A lawful limit on a right when justified by public interest and proportionality.
- Natural Justice
- Fairness in decision-making; the exact rules depend on context and statute.
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