Question

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

• A. Vishaka v. State of Rajasthan
• B. PUDR v. Union of India
• C. M.C. Mehta v. State of Tamil Nadu
• D. Glaxo Laboratories v. Presiding Officer, Labour Court, Meerut

Hint:

Remember the association: PUDR Case $\rightarrow$ Forced Labour $\rightarrow$ Article 23 $\rightarrow$ Minimum Wage Protection.

Answer 1

The Correct Option is B

Concept: Article 23 of the Constitution of India prohibits human trafficking, begar, forced labour, and other similar forms of exploitation. The provision is a fundamental right intended to safeguard human dignity and protect economically vulnerable sections of society from exploitation. The Supreme Court has interpreted Article 23 broadly through various landmark judgments.

Step 1: Understanding the background of the PUDR case.
The case of People's Union for Democratic Rights v. Union of India arose from investigations into labour conditions at construction projects connected with the Asian Games. Workers were being paid wages below the legally prescribed minimum wage. The issue before the Supreme Court was whether such labour amounted to forced labour under Article 23.

Step 2: Observing the Supreme Court's interpretation.
The Court held that when a person is compelled by economic necessity to work for wages below the statutory minimum wage, such labour amounts to forced labour. The Court significantly expanded the meaning of: Forced Labour beyond physical coercion and recognized economic compulsion as a form of coercion.

Step 3: Significance of the judgment.
The decision transformed Article 23 into a powerful tool for protecting labour rights. It established that: Payment below minimum wages can constitute Forced Labour under Article 23 Therefore, \[ \boxed{\text{PUDR v. Union of India}} \] is the landmark case that expanded the scope of Article 23.