Children are universally recognized as the most important asset of any nation and their importance in the nation-building process cannot be undermined. The issue of child labour is not a new concept in the Indian context. Child labour per se is a violation of human rights of children as it deprives them of their growth, development, education, childhood itself. According to the census report, 2011, India has a total 82 lakhs population of working children whose age ranges between 5 to 14 years. In order to protect and secure human rights of the children, Universal Declaration of Human Rights, adopted way back in 1948, had proclaimed that childhood was entitled to special care and protection. The Constitution of India in Article 24 provides that no child below the age of 14 years be employed in any factory or mine or engaged in any hazardous employment. Poverty, lack of basic education of the parents, culture, large family, child abuse by family members, poor implementation of laws and presence of alcoholic or physically challenged family members are the main reasons behind child labour. It is mentally, physically, socially or morally dangerous and harmful to children. Since centuries child labour is prevailing across the world and it is a universal problem, its practice in any society is a violation of human rights as it is barbarous, illogical, inhuman & degrading the ethos of the children. Thus the child labour is not only a social evil but it is a stigma on the childhood & exploitation of the children. The present paper is an attempt to discuss the problems related to child labour, and the critical analysis of existing laws.
Keywords: Child Labour, Human Rights, Poverty, Exploitation
“Children are the greatest gift to the humanity and they are the representation of the beautiful creation of God”. They are the most tender, gentle and fragile one and needs to be handled and protected with immense care and delicacy. Child labour per se is a violation of human rights of children as it deprives them of their growth, development, education, childhood itself.
India accounts for the highest number of child labour in the world. According to the Census of India 2001, 1.25 core children in the age group of 5-14 years are engaged in different occupations. However, estimates of NGO’s put this at much more, because there are many more working in the unorganised sector and in small-scale households units, who never get enumerated as child labour.
According to Census 2001, the state with the highest child labour in the country is Uttar Pradesh which had 1.92 million working children. Other states where child labour population is more than one million are Andhra Pradesh, Madhya Pradesh and Bihar and had 1.36 million, 1.06 million and 1.11 million populations of working children respectively.
As per Census 2011, the total child population in India in the age group (5-14) years is 259.6 million. Of these, 10.1 million (3.9% of the total child population) are working, either as ‘main worker’ or as ‘marginal worker’. In addition, more than 42.7 million children in India are out of school.
2.CONCEPT OF CHILD LABOUR
The concept of child labour is complex in its nature. The word ‘child labour’ is a combination of two components, i.e. ‘child’ in terms of his chronological age, and ‘labour’ in terms of its nature, quantum and income generating capacity.
The word ‘labour’ is a controversial concept to define, especially in the context of child labour, child work and child labour often used synonymously. However, all work is not bad for children because some light work, properly structured and regulated, is not child labour. This implies that work which does not detract from other essential activities for children such as leisure, play and education are not child labour. ‘Child labour’, therefore, is the work which involves some degree of exploitation namely, physical, mental, economic and social and therefore, impairs the health and development of children.
2.1. Meaning of Child Labour
The term “child labour” is often defined as work that deprives children of their childhood, their potential and their dignity, and that is harmful to physical and mental development.
Child Labour means the employment of children (5 to 14 years of age) in gainful occupations, which are injurious to their physical, mental, moral and social development. The child labour is, at times, used synonym for ‘employed child’ or ‘working child’. But a working child is one who subjects himself or herself to work, unpaid or free, instead of being at the school at a tender and formative stage of his or her life.
Constitution of India provides that, “no child below the age of fourteen years shall be employed to work in any factory or mine or engaged in any other hazardous employment”. In Directive Principles of State Policy, the Constitution of India pledged that the health and strength of workers, men and women, and the tender age of children are not abused and that citizens are not forced by economic necessity to enter avocations unsuited to their age or strength; and that children are given opportunities and facilities to develop in a healthy manner and in conditions of freedom and dignity and that childhood and youth are protected against exploitation and against moral and material abandonment.
Child labour has been defined differently, and therefore, no universally accepted definition of child labour is available at present. In India, the definition of child labour in terms of age; differed from year to year under different legislations:
- The Factories Act, 1881, defined child as a person below 12 years, minimum age of employment was 7 years and hours of work for the age 7 to 12 years, were fixed at 9 with rest interval and holidays.
- Factories Act, 1891, raised the minimum age of employment to 9 years, and the hours of work for age 9 to 14 years, were fixed at 7 hours a day restricted to daylight.
- Factories Act, 1911, put the hours of work to 6 in textile mills and employment of labour between 7.00 p.m. and 5.30 a.m. was prohibited.
- Factories Act, 1922, declared persons below the age of 15 years as children; hours of work were limited to 6 with a rest interval of half an hour, minimum age of employment was raised from 9 to 12 years.
- Factories Act, 1934 fixed the minimum age of employment at 12 and persons between 12 to 15 years were to be treated as children.
- Factories Act, 1948, raised the minimum age of employment to 14 years, a working day of 4½ hours with a spread over of 5 hours was prescribed. Employment during the night and on hazardous occupations is prohibited.
- The minimum age in the Mines Act, 1952 is 15 years.
- It is 12 years in the Plantations Labour Act, 1951.
According to ILO’s comprehensive definition of child labour, “Child Labour includes children prematurely leading adult lives, working long hours for low wages under conditions damaging to their health and to their physical and mental development, sometimes separated from their families, frequently deprived of meaningful education and training opportunities that could open up for them a better future”.
The ILO continues to define child labour as “work situations where children are forced to work on a regular basis to earn a living for themselves and their families, and as a result they remain backward educationally and socially in a situation which is exploitative and harmful to their health and to their physical and mental development. The children are separated from their families, often deprived of educational and training opportunities and they are forced to prematurely lead adult lives (ILO)”
2.2. Forms of Child Labour
Children work in three sectors of the economy:
(a) The Agrarian sector: The agrarian sector in India is characterised by poverty, illiteracy, unemployment, highly skewed distribution of land-ownership, traditional modes of production, prevalence of old customs and traditions, system of usury, etc. Several forms of child labour such as invisible, migrant, bonded etc. emerge from this sector, which encompasses such time-consuming activities for boys as looking after animals, gathering wood and fodder, sowing and reaping, protecting fields from pests, weeding, etc. For girls, the activities are milking animals, cooking, and looking after younger children. The rural child is working child and work is a fundamental part of his or her existence, irrespective of whether it is non-monetary. It also, therefore, means that education is a casualty for such a child.
(b) Industrial sector: Industrial sector is a growing level of urbanisation as a result of migration from rural to urban areas and from smaller towns to bigger cities, where industries are being set up. Another feature is the dispersal of industries into family-based units. This again causes the emergence of various forms of child labour, such as invisible, wage-based child labour working under conditions of acute exploitation in the industries, children of marginalised families working as self-employed children or under-wage employment in the services sector.
(c) Service sector: The service sector actually has a certain overlap with the industrial sector. A majority of children in this sector are self-employed because its very nature provides relief from direct supervision. It also provides autonomy and freedom of control over resources. Such children are found to be working both in the urban as well as rural areas. In this sector, child labour can take such forms as invisible, self-employed or under wage-based employment, with children changing jobs at regular intervals. This is particularly true in urban areas.
2.3. Factors leading to child labour
The Indian problem of child labour is not a result of any single isolated factor. It is a multi-dimensional problem that involves various reasons contributing to it in a variety of ways. Some of the factors contributing and responsible for prevalence and perpetuation of child labour are:
- continued poverty,
- illiteracy and ignorance of poor parents,
- population explosion-large family size,
- low family income,
- the tradition of making children learn the family skill,
- lack of political will and weak/tardy enforcement of laws,
- absence of provision for universal compulsory primary education etc.
Thus, the problem of child labour is acute and multi-dimensional. The Government of India has conceded the existence of child labour as “harsh reality”. The debate about whether child labour should be banned or regulated is not new. It surfaced in 1985 when the Government of India claimed that ‘child labour was a harsh reality’ and found it more prudent to regulate rather than ban it; the Child Labour (Prohibition and Regulation) Act, 1986 – an Act without teeth and innumerable loopholes was passed.
3. JUDICIAL RESPONSE TO CHILD LABOUR
Though the court’s approach to the issue of child labour may be described as one step forward and two steps backwards, it can generally be said that the court has been sympathetic to the cause of child labour.
In the following pages, an attempt is made to discuss the few cases decided by the courts on the issue of child labour to assess the role played by them in prohibiting, ameliorating or alleviating the employment of children and their working conditions.
3.1. Judiciary on employment of children:
Article 24 of the Constitution prohibits the employment of children below certain age limit. It provides that “no child below the age of 14 years shall be employed to work in a factory or mine or in any other hazardous employment”.
M.C Mehta v. State of Tamil Nadu hailed as a landmark decision of the Supreme Court, the court had an occasion to agonize about the problem of child labour not only in match and fireworks factories but all over the country. The court relied on the Indian Constitution, India’s international commitments, and domestic legislation as the basis for its decision. The court, therefore, issued certain directions regarding the manner in which the children working in the hazardous occupations are to be withdrawn from work and rehabilitated as also the manner in which the working conditions of the children working in non-hazardous occupations are to be regulated.
Peoples Union for Democratic Rights v. Union of India (popularly known as the Asiad case) is a writ petition brought by way of public interest litigation in order to ensure observance of the provisions of various labour laws in relation to workmen employed in the construction work of various projects connected with the Asian Games. It was alleged by the petitioners, inter alia, that there was violation of Article 24 of the Constitution of India and of the provisions of the Employment of Children Act, 1938 in as much as children below the age of 14 years were employed by the contractors in the construction work of the various projects connected with the Asian Games. It was also alleged that there was a violation of Article 23 since the workers, including the children, were not being paid the minimum wages under the Minimum Wages Act, 1948.
As regards the violation of the provisions of Article 24 is concerned, the court held that it embodies a fundamental right which is plainly and undoubtedly enforceable against everyone and by reason of its compulsive mandate, no one can employ a child below the age of 14 years in a hazardous employment, and since construction work is a hazardous employment, no child below the age of 14 years can be employed in construction work and therefore, not only are the contractors under a constitutional mandate not to employ any child below the age of 14 years, but it is also the duty of these authorities to ensure that this constitutional obligation is obeyed by the contractors to whom they have entrusted the construction work of the various Asiad projects.
People’s Union for Civil Liberties V. Union of India, a public interest litigation was filed by the non-governmental organisation based on the report- ‘Campaign against Child Labour’. It was reported that five minor children were procured by one Rajput from the State of Tamil Nadu by paying Rs. 500 to Rs. 1500 to their parents and took them to Maharashtra and forced them into bonded labour. One of them was beaten to death and the remaining went missing. The trial court convicted the procurer of murder. Under the orders of the apex court the Maharashtra police traced three of them but the fourth, real brother of the deceased, still remained untraced.
Agreeing with the contentions of the counsel appearing for the petitioner that these boys were entitled to compensation, the court directed the State of Maharashtra to pay a sum of Rs. Two lakhs to the brother of the deceased who was still untraced. Likewise, the State of Tamil Nadu was directed to pay Rs.75,000 each as compensation to the other three boys. The court, thus, upheld the claim in public law for compensation for contravention of human rights and fundamental freedoms, the protection of which is guaranteed by the Constitution of India.
3.2. Right to Education and Child Labour:
Article 21A of the Constitution provides for the right to education. It lays down that “the State shall provide free and compulsory education to all children of the age of six to fourteen years in such a manner as the State may, by law, determine. In regard of this Article, Right of Children to Free and Compulsory Education Act, 2009 (RTE Act, 2009) had been passed to provide for free and compulsory education to all children of the age of six to fourteen years. Despite of making right to education and more particularly right of children to free and compulsory education a fundamental right followed by the enactment of the RTE, 2009 most of the children particularly in rural areas and even those who are below poverty line are not in schools. Instead, they are compelled to work because of their poverty, ignorance, illiteracy, lack of social security, health facilities and, among others, food security. According to a report published in the press the Supreme Court has sought a response from the Indian government and all the states on the prohibition of all forms of child labour, and the enforcement of the right to education of all Indian children in the 6-14 age group. This has been in response to a public interest litigation filed jointly by a group of three Non-Government Organizations (NGOs). The counsel for the petitioners has argued that nearly six decades after the Independence, the government has neither made child labour illegal nor education compulsory, despite the amendment to the Constitution of India.
Referring to Article 21A of the Constitution of India, which guarantees the right to education to all children of age between 6 and 14 years, the petitioners have argued: “after the amendment, there is no scope for child labour. There can’t be any place for children other than school, the state has to provide that.” The petitioners have urged that a directive be issued to the governments to make changes in all existing laws relating to child labour, including the Child Labour (Prohibition and Regulation) Act, Plantation Labour Act, Children (Pledging of Labour) Act and the Apprentices Act. The amendments, they have argued, would ensure that the Acts conform to the Constitution of India, the UN Convention on Rights of the Child and the International Labour Organization’s Minimum Age Convention.
3.3. Remedial Measures to Prevent Child Labour
Karnataka High Court in the A. Srirama Babu v. The Chief Secretary to the Government of Karnataka, has suggested the following remedial measures to be taken to prevent child labour:
(i) The root cause has been identified to be poverty. The poor parent sends his child to work to earn a pittance for want of any or proper employment avenue for himself. The employer, enticed by the prospect of paying low wages and long hours of work, engages the child; the child works, without complaint as long as the master wants; there are no Trade Unions to clamour and protect his rights. The Factories Act states that a child may work at the most six hours a day. It means if he turns out that quantum of work, it can be presumed that he turns out work of normal person. If so, there need not be a distinction in the matter of wages to be paid to him. Equal wages may be notified under the Minimum Wages Act for a child as well as the adult.
(ii) The Labour Legislation enacted in the matters of hours of work, health care, wages, etc., should also be enforced by the State strictly. There should be a check by Medical Officers of the health of the working child periodically and the report thereof should be submitted to the Labour Department. If any follow-up action is contemplated, appropriate measures should be taken in that behalf.
(iii) The factory or workplace must be made congenial and hygienic. In places where a large number of children are employed, the State should endeavour to establish of a school with the assistance of industrial undertakings in the area to educate the working child as indicated by the Supreme Court.
(iv) The State should consider taking steps to amend the Child Labour (Prohibition and Regulation), Act 1986 in the manner indicated above to achieve the desired effect.
(v) There should be a total ban of employing children below the age of 10 in any employment.
(vi) The State should ensure that in any industry or a factory where children are employed, they enjoy the same benefits as those that are enjoyed by any other industrial workers. In other cases, which is not an industrial establishment or factory, but a shop or commercial or other establishment, the State should ensure that the child labour’s gets the notified wages, that they work to only the statutorily fixed hours of work, they are provided with appropriate medical care that they have facility to avail of insurance protection, that they have clean places for dwelling, that they have rest places and that they enjoy hygienic work atmosphere.
(vii) There is a category of child workers who, perhaps, are the worst hit. They are the child labourers employed in the hotels and other catering establishments. The Health Inspectors of the Local Authorities should be empowered to check the working condition of these children and any default on the part of the employer should be reported to the Labour Department for stringent action. The statute should be so amended disabling an employer to earn any renewal of the licence to run the establishment in the event he is guilty of violating any of the provisions of the Labour Law while employing child labour.
(viii) The Government should create a fund to provide social security to the child labourers who are working in unorganised sectors. The fund being created by the Government should be out of the contributions made by the employers in a fixed proportion over and above the salary paid to the child labourers. It would be made available to the children who were once employed but lose their employment and remain unemployed and are not provided for. Vagrant or unemployed children should also be in a position to earn the benefit of the fund. A strict drive should be conducted by the Government to prevent the vagrancy of children. The Government should see that the Labour Department conducts surprise inspections of all establishments where there is a likelihood of children being employed and ascertain whether the Labour enactments and other relevant directions issued on the basis of the order of the Supreme Court are being given effect to. An erring employer should be dealt with a deterrent. The Government should maintain a record of these omissions and commissions of the employer and this should be taken note of while granting future renewals of licence for running the establishments or for receiving other statutory benefits. These omissions of the employers should be treated as a black-mark while considering the case for renewal of the licence to run the establishments in future or earning any statutory benefits such as tax holiday, rebate, etc.
(ix) The Government should see that each of the directions issued by the Government on the basis of the Court orders is strictly implemented and the Labour Laws are enforced. A mere inspection by the Labour Department for the sake of satisfying the statistics is not what is intended to be performed by them.
4. CRITICAL ANALYSIS OF CHILD LABOUR (PROHIBITION AND REGULATION) AMENDMENT ACT, 2016
4.1. Salient features of the Amended Act:
- Prohibition of employment below the age of 14 years – In the view of the Right of Children to Free and Compulsory Education Act, 2009, the Act put the blanket ban on employment of children below 14 years of age but allow them to work in home, family enterprises, outside of school hours and during holidays, and in audio-visual entertainment industry and sports only if it does not affect their education.
- A new category of ‘adolescents’ formed – The Act added a new category of ‘adolescents’ (the 14-18 age groups). They can be employed in ‘non-hazardous’ occupations.
- Stringent punishment – The Act has enhanced the punishment by way of this amendment. For the first time offender, the fine has been increased from 20,000 to 50,000 and imprisonment has been extended from 6 months to 2 years. The offence is cognizable and a punishment of 1-3 year will be awarded to repeat offenders. The Act incorporates relaxed penal provisions for a parent. In a case of a repeat offender, a parent has to pay a fine of 10,000 rupees.
- Powers conferred on the Central Government – The Act empowers the Central Government-
- To alter the list of hazardous occupation.
- To empower District Magistrate in order to ensure effective implementation of the law.
- To conduct periodic inspection of places where children and adolescent cannot be employed.
- Child and Adolescent Labour Rehabilitation Fund – The Act proposes to set up Child and Adolescent Labour Rehabilitation Fund for rehabilitation of children.
- Child rehabilitation – The Act puts the onus on the State Government to rehabilitate the child and to extend monetary assistance by giving Rs 15,000 and add the fine from the employer for child’s rehabilitation.
4.2. Critical Analysis of the Amended Act
On the face of it, the amended Act of 2016 seems to be progressive. However, on careful reading, various flaws in the new Act are exposed. The shortcomings of the Act are as follows:
- Slashed list of hazardous occupation encourages child labour– Reducing the list of hazardous occupation from 83 to just 3 (mining, explosives, and occupations) would only reduce child labourers in number, not in reality. The law is grossly unfair to adolescents as they can be employed in rest 80 hazardous occupations. Section 4 of the Act gives discretionary power to government authorities, not to Parliament, to revise the list. Therefore, it will give rise to more child labour.
- Legalizing Child labour in “family enterprise” will results in forced labour – Section 3 Clause 5 of the Act permits a child to work in family or family enterprises and in an audio-visual entertainment industry. The said provision is detrimental as it does not define the hours of work. It simply provides that only after school hours and during vacation child can work. Such legal provision is likely to be misused in the Indian context and would pave the way for child labour as most children indeed work in a family-run trade. The term family enterprise is defined as any work, profession or business performed by the members of the family with the help of other persons. Such a broader definition would definitely promote caste-based occupation. It will also empower contractors that will, in turn, result in bonded/forced labour. Such provision will have an adverse impact on education, innovative minds, learning outcomes as well as health and overall development of a child.
- The Act has completely overlooked the vital distinction between children and adults– Non – recognition of this distinction is arbitrary and a clear violation of a right to equality embodied under Article 14 of the Constitution of India. Further, the definition of child labour has been altered by the Act as it legitimizes child labour in a family business and permits adolescent to work in the non- hazardous occupation.
- The Act contravenes domestic legislation as well as International Conventions– The Act not only reverses the gains of previous laws but also goes against the spirit of RTE Act of 2009 as it allows a child to work in a family enterprise. It also transgresses international convention such as the International Labour Organization’s (ILO), and UNICEF’s Convention on the Rights of the Child, to which India is a signatory. UNICEF has raised alarm over children employment in family enterprises and reduction in the list of hazardous occupation.
- The Act lacks the provisions relating to regulation, inspection and monitoring systems– Regulation is going to be a big challenge as the Act does not lay down the criteria to determine whether a particular enterprise is a family enterprise or not. The lack of such provisions leaves the life of children at the hands of the employer.
- Penalty provisions also suffer from certain loopholes – The Act prescribes penalty only for employment of children and not for bad working conditions. Penalizing parents are bad in law as it will only increase the burden of indigent parents.
The Child labour is a global and multi-dimensional complex issue and deep-rooted in the socio-economic fabric of the society. The problem of child labour may not rely on any one single approach to deal with. There are many factors which is responsible in giving rise to the problem of child labour which is discussed above in the paper. Many attempts had been made in abolishing the child labour form the society but attempts failed due to lack of proper implementation of laws and schemes which may benefit the beneficiaries. Constantly, the data of working child is increasing day by day and among all over the countries, India is becoming the hub of Child labours. Child labour seems to be the cheap labour amongst all other forms of labour, therefore, they may be easily exploited and indulge in illegal and hazardous works. In the case of People’s Union for Civil Liberties v. Union of India, the same problem has been discussed. Supreme Court had given direction in regard to prohibit child labour in form of bonded labour and all kind of exploitations.
Judiciary had also made many attempts for abolishing the child labour by giving directions and suggestions but in none of the cases, which has been brought before the court, called an immediate ban on child labour. In all the cases, the court is permitting the children to employ in every hazardous industry in preventive form instead of banning them to work in any form of labour. Employers employ children, not for altruistic or charitable considerations, but to minimize labour cost and to maximize their profits. Some element of exploitation is inherent in such a relationship. Therefore, the only way to protect the children from exploitations is to prohibit child labour.
Today’s children constitute tomorrow’s future. However, it is a matter of grave concern that India despite the Constitutional mandate and statutory measures, a good number of children are denied their basic rights and opportunities and thereby they are deprived of the childhood.
After discussing and analysing all the issues which give rise to child labour, the following suggestions have been made to overcome the menace of child labour.
- Child labour has become an increasingly lucrative business since the risk of prosecution is very low. To deal with the issue of child labour more effectively, the prosecution process should be very high.
- Children who are engaged as domestic labour, working as roadside dhabas and mechanic shops have to be rescued and a bridge of education has to be provided including vocational training.
- The policies, programmes and structures to prevent child labour are failing due to inactive support mechanism and lack of proper implementation of laws and policies. There should be proper implementation of all laws and schemes so that the children of poor families do not become victims of exploitation by industries, factories and mills.
- In order to implement the fundamental right of the children under Article 21A it is imperative that the Central Government must issue suitable notifications prohibiting the employment of children in factories and homes.
- The child labour can be prevented by replacing child workers by adult workers. More than half of the population of India is whether unemployed or underemployed. Replacement of a child with an adult will help in the eradication of poverty as well child abuse.
Above all, in spite of depending upon the legislation and judicial pronouncements, we need to take a resolution as a parent/guardian or state, to save our children from their exploitation as child labour which further leads to child abuse. We must take a social responsibility to protect our children from child labour and to nurture them with love, care and also by giving them proper education and helping them to come up with their talent and make our nation proud.
By- Durgesh Kumar Shukla
Master of Laws (Access to Justice)
Tata Institute of Social Sciences, Mumbai
 Census of India, 2001.
 Census of India, 1991 and 2001.
 Census of India, 2011.
 Lok Sabha debates, Seventh Session ( 8th lok Sabha), Vol. XXIII, No.22, Col. 329, 331, ( Dec, 3. 1986). P.P. Jayanti, “Child Labour
 The term ‘child labour’ and ‘working children’ have different connotations, but both the terms are used interchangeably on account of limitations of the available datasets.
 M.N. Rehman, Society, Economy and Education of Deprived, Anupama Publishers, Delhi, 1992, pp. 4-5.
 Article 24, The Constitution of India, 1950.
 Article 39(e), The Constitution of India, 1950.
 Article 39(f), The Constitution of India, 1950.
 Francis Blanchard, “Child Labour” ILO, 1983, pp 3-4.
 Hasnaim, Ali and Khan, Samsuddin. (2012), The Overcoming of Child Labour in India: In perspective of constitutional and legislative framework. Journal of Business Management and Social Sciences Research. (JBM&SSR) ISSN No 2319 – 5614, Vol 1, No 3, December 2012, p 83
 Helen R.Sekar, Child Labour Legislation in India – A Study in Retrospect & Prospect, Noida: V.V.Giri National Institute of Labour, 1997, pp 13-15.
 D.Venkateshwar rao, Child Rights – A perspective on International and National Law, New Delhi: Manak Publications Pvt. Ltd., 2004, p.5.
 Neera Burra, “Child Labour: it’s a Reality tale” The Indian Express December 18, 2007 New Delhi, see also Association for Development (AFD) News Letter Issue. XXIX October-December 2007 Delhi p.6.
 (1996) 6 SCC 756.
 AIR 1982 SC 1473.
 (1998) 8 SCC 485.
 Nilabati Behera v. State of Orissa, (1973) 2 SCC 746; and Rudul Sah v. State of Bihar, (1983) 4 SCC 441 were referred to.
 S.C. Srivastava, Child Labour: Law and its Implementation, v (2017).
 Staff Reporter, “Supreme Court issues notices to central, state governments on child labour” The Telegraph, Calcutta (February 17, 2006). Despite all my efforts to get a copy of this judgment, it has not been possible to get one. No one I enquired from knew about the existence of this judgment.
 Social Jurist, HAQ – Centre for Child Rights and the Andhra-based M.V. Foundation.
 Supra Note 16
 ILR 1997 Kar 2269: 1998 (1) Kar LJ 191.
 (1998) 8 SCC 485.
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