Question

Which is the landmark case which expanded the scope of Article 23 of the Constitution of India?

• A. PUDR v. Union of India, (1982) 3 SCC 235
• B. M.C. Mehta v. State of Tamil Nadu, (1996) 6 SCC 756
• C. Glaxo Laboratories v. Presiding Officer, Labour Court, Meerut, (1984) 1 SCC 1
• D. Vishaka v. State of Rajasthan, (1997) 6 SCC 241

Hint:

PUDR Case = "No Minimum Wage = Forced Labor." The Supreme Court made it clear that economic exploitation disguised as low wages violates the constitutional protection against forced labor!

Answer 1

The Correct Option is A

Step 1: Understanding the Concept:
Article 23 prohibits "forced labor" and "begar." The PUDR (People's Union for Democratic Rights) case significantly broadened this definition.

Step 2: Detailed Explanation:
- In the PUDR case, the Supreme Court held that "forced labor" under Article 23 includes labor provided for less than minimum wages. The Court reasoned that if a person is paid less than the minimum wage, they are effectively being forced to work out of economic necessity, which is a form of exploitation prohibited by the Constitution.

Step 3: Final Answer:
The PUDR case expanded the scope of Article 23. Option (A) is correct.

Answer 2

Each option names a real, well-known Supreme Court decision, so the most direct way to answer is to recall what each case actually decided and check which one specifically deals with expanding the meaning of forced labour under Article 23.

1. Option (A) - PUDR v. Union of India, (1982) 3 SCC 235: This case held that paying workers less than the statutorily prescribed minimum wage amounts to forced labour within the meaning of Article 23, because economic compulsion driving a person to accept below-minimum pay is itself a form of forced labour. This is precisely the ruling that broadened Article 23's reach beyond its earlier, narrower reading.
2. Option (B) - M.C. Mehta v. State of Tamil Nadu, (1996) 6 SCC 756: This case is concerned with the elimination of child labour, particularly in hazardous industries such as match and fireworks factories, and the framework for rehabilitating child workers. Its subject matter is child labour policy, not the definitional scope of forced labour under Article 23.
3. Option (C) - Glaxo Laboratories v. Presiding Officer, Labour Court, Meerut, (1984) 1 SCC 1: This case deals with the validity and interpretation of standing orders and disciplinary procedures under industrial employment law before a labour court, an entirely different area of labour jurisprudence with no bearing on Article 23's scope.
4. Option (D) - Vishaka v. State of Rajasthan, (1997) 6 SCC 241: This case laid down guidelines to prevent sexual harassment of women at the workplace in the absence of specific legislation, addressing a completely different constitutional concern than forced labour under Article 23.

Matching each case's actual subject matter against the question shows that only one of them is concerned with, and responsible for widening, the meaning of forced labour under Article 23.

Therefore, the correct answer is PUDR v. Union of India, (1982) 3 SCC 235.