Contract Labour (Regulation and Abolition) Act, 1970

The Indian Explosive Limited, a urea manufacturer, employed several licensed contractors who in turn engaged workers. The Fertilizer Workers Union sought regularisation of these workers under Rule 25(v)(a) of the Uttar Pradesh Contract Labour Rules, arguing they performed work similar to the company's own workmen and d…

The Labour Enforcement Officer issued a show‑cause notice under Section 7 of the Contract Labour (Regulation and Abolition) Act, 1970, alleging that the Reserve Bank of India’s College of Agricultural Banking had violated the Act. The principal of the college filed an application to quash the proceedings, contending th…

The Supreme Court examined three questions: the meaning of "appropriate Government" under the Contract Labour (Regulation and Abolition) Act, 1970; the validity of the Central Government's 9 December 1976 notification prohibiting contract labour in Central Government companies; and whether such a prohibition automatica…

The appellants, a workers' union, challenged a complaint filed under the Maharashtra Recognition of Trade Unions and Prevention of Unfair Labour Practices Act, 1971, arguing that the employer‑employee relationship with the principal employer was disputed and should be decided under the Industrial Disputes Act, 1947. Th…

The case concerned 464 labourers at the Food Corporation of India's Siliguri depot who were originally employed through a contractor. In 1973 the corporation abolished the contractor and introduced a direct payment system, paying wages directly to the workers via Sardar/Mondal agents. The corporation later, in 1975, re…

The Food Corporation of India (FCI) was directed by the Employees’ Provident Fund (EPF) Commissioner to deposit contributions for workers employed by contractors at its depots in Rajasthan. FCI contended that it was denied a reasonable opportunity to produce evidence identifying those workers because the Commissioner n…

The Steel Authority of India Ltd., a government company, engaged contractors to manufacture steel, and workers employed by those contractors claimed they were permanent employees of the company and sought absorption. The State Government referred the dispute to a Labour Court under Section 10(1)(c) of the Industrial Di…

The State Government of Orissa issued a notification on 28 April 2000 abolishing contract labour for workers in the OAP plant of M/s Paradeep Phosphate Ltd. The Mazdoor Union filed writ petitions seeking enforcement of the notification and regularisation of the affected workers. The company contended that the State Gov…

The Gujarat Transport Department floated a tender for manpower services with conditions that the salary paid must not be less than the minimum wage and that bids must be fixed, not open‑ended. Three bidders qualified; the Technical Evaluation Committee fixed a minimum‑wage figure of Rs 3,00,92,346, rendering the bids o…

The Nashik Workers Union filed several complaints under the Maharashtra Recognition of Trade Unions and Prevention of Unfair Labour Practices Act, 1971 seeking reinstatement and back wages for trainees of Hindustan Aeronautics Limited (HAL). The dispute turned on whether, for HAL, the "appropriate Government" under Sec…

The case concerned workmen employed by a contractor to run a statutory canteen on the premises of Air India, which under Section 46 of the Factories Act, 1948, must provide such a facility. The workmen claimed they were deemed employees of Air India and sought regularisation and other employment benefits. The Supreme C…

The Supreme Court examined whether a security guard allotted by the Maharashtra Private Security Guards Board to a principal employer becomes the employee of that employer, thereby stripping the Board of its power to recall, re‑allot or transfer the guard. The petitioners, trade unions, argued that the guard becomes a …

The petitioners, Anganwadi workers and helpers employed under the Integrated Child Development Services (ICDS) scheme in Gujarat, sought gratuity benefits under the Payment of Gratuity Act, 1972. The Gujarat High Court’s Division Bench held that they were not employees and thus ineligible for gratuity, overturning an e…

Bhuvnesh Kumar Dwivedi was employed by Hindalco Industries Ltd as a labour supervisor from 30‑12‑1992 to 27‑07‑1998. Although the employer periodically terminated his service on the pretext of "sanction expired" and re‑appointed him on short contracts, the workman rendered continuous service of nearly six years. The La…

In Bharat Petroleum Corporation Ltd. v. Mumbai Shramik Sangha (2001), a civil appeal arose from a Bombay High Court order concerning the scope of Section 10 of the Contract Labour (Regulation and Abolition) Act, 1970. Two learned judges of the Supreme Court expressed doubt about the correctness of the Constitution Benc…

The Andhra Pradesh State Road Transport Corporation (AP SRTC) issued a 1988 circular allowing absorption of casual employees but expressly excluding contract labour. Several scavengers employed through contractors filed writ petitions seeking regularisation under the circular. The High Court, on multiple occasions, dir…

The Central Government issued a circular on 8 November 2000 refusing to prohibit contract labour in certain establishments of Rashtriya Chemicals & Fertilizers Ltd. The General Employees Association filed a writ petition under Article 226 seeking quashment of the circular, alleging that the contract labour system was a…

The Supreme Court considered appeals filed by Dena Nath and others against National Fertilizers Ltd. The issue was whether failure by a principal employer to obtain registration under Section 7 of the Contract Labour (Regulation and Abolition) Act, 1970, or by a contractor to obtain a licence under Section 12, would ca…

The All India Railway Parcel & Goods Porters Union sought the regularisation of parcel porters employed on a contract basis, arguing that the work is permanent and perennial and that earlier Supreme Court directions required their absorption as permanent employees. The Railway Administration contended that the work is …

Contract workers employed by Tata Iron and Steel Company, Jamshedpur, performed permanent and regular tasks before 11‑Feb‑1981 and sought permanent employment with the principal employer. The Bihar Government referred the dispute to the Industrial Tribunal under s.10 of the Industrial Disputes Act. The Tribunal held th…

Gardeners were engaged through an agency to maintain lawns within the premises of Bharat Heavy Electrical Ltd (the appellant). Their services were terminated and they raised an industrial dispute, claiming reinstatement and compensation under Section 6‑N of the Uttar Pradesh Industrial Disputes Act, 1947. The Labour Co…

Cipla Ltd employed cleaning staff through a contractor and routinely terminated them after eleven months to avoid granting permanent status. The Maharashtra General Kamgar Union filed a complaint under Section 28 of the Maharashtra Recognition of Trade Unions & Prevention of Unfair Labour Practices Act, alleging unfair…

The Supreme Court examined whether Bharat Heavy Electricals Ltd. (BHEL) was subject to the 24‑April‑1990 notification issued under the Contract Labour (Regulation and Abolition) Act, 1970, and whether the workmen who were engaged through contractors were direct employees of BHEL. The Court held that BHEL’s Haridwar ope…

The workmen, represented by the FCI Labour Federation, sought to compel the Food Corporation of India (FCI) to regularise contract labourers under the Departmental Labour System (DLS) as directed by the Supreme Court in a 2018 order. The corporation had instead regularised the workers under its long‑existing Direct Pay…

The People's Union for Democratic Rights filed a public‑interest writ petition alleging that contractors engaged in the construction of Asian Games projects in Delhi were violating multiple labour statutes, including the Minimum Wages Act, Equal Remuneration Act, Contract Labour (Regulation and Abolition) Act, Employme…

The appellant, Adiraj Manpower Services Pvt. Ltd., a manpower recruitment agency, entered into agreements with Sigma Electric Manufacturing to supply personnel for various manufacturing activities. The Commissioner of Central Excise issued a show‑cause notice alleging that the appellant had failed to assess and pay ser…

Kripa Pandey worked as a driver in the Bihar Caustic & Chemicals Ltd. factory during its construction, being engaged by a contractor under the Contract Labour (Regulation and Abolition) Act, 1970. He was terminated in September 1984 and claimed that the termination was illegal, seeking reinstatement and back wages. The…

The BHEL Workers' Association and other petitioners alleged that about a thousand contract labourers in the BHEL plant at Hardwar were paid lower wages and denied the same conditions of service as directly employed workers, seeking a declaration under Article 32 that the contract labour system was illegal and that they…

The Central Government issued a notification on 08‑09‑1994 under Section 10(1) of the Contract Labour (Regulation and Abolition) Act, 1970 prohibiting contract labour in several categories of work in ONGC establishments. ONGC challenged the notification before the Uttarakhand High Court, which quashed it, but the ONGC …

The petition, filed by a social welfare organisation, alleged that thousands of migrant workers in stone quarries and crushers in Faridabad were subjected to inhuman conditions, forced labour and bondage, violating their fundamental rights under Articles 21 and 23 of the Constitution. The Court treated the letter addre…

The West Bengal Government, under Section 10(1) of the Contract Labour (Regulation and Abolition) Act, 1970, issued a notification on 9 February 1980 prohibiting contract labour in several departments of M/s Indian Iron & Steel Co. Ltd., but expressly excluded the job of loading and unloading bricks in the brick depart…

The Oil and Natural Gas Commission (ONGC) engaged a large number of workers through contractors for its drilling operations in Cachar. The ONGC Contractual Workers Union sought regularisation of these workers' services, leading the State Government to refer the dispute to an Industrial Tribunal. The Tribunal held that …

The Food Corporation of India (FCI) had earlier been subject to a 1976 Central Government notification prohibiting the employment of contract labour for sweeping, cleaning, dusting and watching of its buildings. In 1992 the Central Government withdrew that prohibition, raising the question of whether the 1976 notificat…

The Supreme Court examined two disputes referred by the Central Government under Section 10 of the Industrial Disputes Act, 1947, concerning whether workers engaged through a contractor at Sudamdh Colliery were to be treated as workmen of the principal employer, Bharat Coking Coal Ltd. The Tribunal and the Patna High C…

The case concerned 136 contract workers who had been employed as trolley retrievers at Delhi airports and sought regularisation after the Central Government’s 2004 notification under the Contract Labour (Regulation and Abolition) Act, 1970 (CLRAA) prohibited such contract labour in the Airports Authority of India (AAI)…

The case concerned workers who had been handling coal and iron‑ore at Chennai Port Trust and later claimed regularisation of their services after the activity was shifted to Ennore Port Trust. The workers formed an association, entered into a Memorandum of Understanding (MOU) with the port trust that included an arbitr…

The Kagajkal Thikadar Sramik Union filed a representation under Rule 25(2)(v)(a) of the Contract Labour (Regulation and Abolition) Assam Rules, 1971, seeking equal wages and benefits for contract labourers employed at Hindustan Paper Corporation Ltd. The Labour Commissioner, after an inspection by the Assistant Labour …

Bharat Heavy Electricals Ltd. (BHEL), a public sector undertaking, received a notice under Section 45A of the Employees' State Insurance Act, 1948 for non‑payment of ESI contributions for the period 1981‑1991. BHEL argued that the workers were employed by contractors and therefore sought to implead those contractors as…

The workmen employed in the canteen of Air India, which was operated by Chef Air, a unit of the Hotel Corporation of India (HCI), claimed they were regular employees of Air India. Air India argued that HCI was a separate legal entity and that it had no control over the workers' hiring, wages, or discipline. The Supreme…

A group of canteen workers employed through a contractor filed writ petitions seeking to be regularised as employees of Mishra Dhatunigam Ltd. and other respondents, invoking the statutory duty under the Factories Act to provide a canteen. The Andhra Pradesh High Court allowed the writs, directing the employers to trea…

National Thermal Power Corporation Ltd. (NTPC), a public sector undertaking, was statutorily obligated under Section 46 of the Factories Act, 1948 to provide a canteen for its employees. The canteen was operated by contractors, employing about 54 workers. The workers filed a writ petition seeking regularisation as NTPC…

The Sarva Shramik Sangh, representing canteen workers employed by a contractor of Indian Oil Corporation (IOC), first filed a writ petition seeking abolition of the contract labour system under the Contract Labour (Regulation and Abolition) Act, 1970, which was dismissed for want of prosecution. It then filed a second …

The International Airport Authority of India (IAAI) terminated a licence with a private ground‑handling firm, after which the firm’s workers formed a cooperative society and entered into a contract‑labour agreement with IAAI. The workers later sought absorption as regular employees, alleging that the contract was a sha…

The Supreme Court examined challenges by private employers, including Ficus Pax Private Ltd., to central and state orders issued under the Disaster Management Act, 2005 that compelled private establishments to pay full wages to all workers during the COVID‑19 lockdown. The petitioners argued that the orders were ultra‑…

The petitioners, contract labourers employed through various contractors at SAIL's Rourkela plant for 10‑20 years, filed a writ petition under Article 32 seeking parity in pay and absorption as regular employees, alleging that the contractor arrangement was a camouflage to deny them rights. The Supreme Court held that …

The K.V. Shramik Sangh, a trade union representing contract workers in the Mumbai Municipal Corporation's solid waste management department, filed a writ petition seeking abolition of the contract labour system and absorption of the workers as permanent employees, alleging that the contracts were sham and that the corp…

Mahanadi Coalfields Ltd. (the appellant) had engaged a contractor to transport crushed coal, employing 32 workmen from 1984 to 1994. The workers' union sought regularisation of all 32 workers under clauses of the National Coal Wage Agreement IV, leading to a settlement on 5 April 1997 that regularised only 19 of them, …

The Supreme Court examined whether the Maharashtra Mathadi, Hamal and Other Manual Workers (Regulation of Employment and Welfare) Act, 1969 and the Grocery Markets or Shops Unprotected Workers Scheme, 1970 could be applied to Pepsico India Holding Ltd., which manufactures petro‑chemical products, soft drinks and bottle…

The petitioners, electricians employed through a contractor for the National Thermal Power Corporation (NTPC), sought to be absorbed as workmen of the corporation, arguing that the Madhya Pradesh Industrial Relations Act, 1960 applied to them and that contract labour should be abolished. NTPC contended that it was a re…

The petitioners, workmen employed as sweepers, canteen workers and other staff at international airports, challenged their continued status as contract labour after the Supreme Court’s decision in Air India Statutory Corporation v. United Labour Union which abolished contract labour. They sought regularisation and enti…

The petitioners, railway parcel porters employed on a contract basis in several zones of Indian Railways, sought permanent absorption as regular parcel porters with salary parity to regular employees, invoking the earlier Supreme Court order of 15 April 1991. The Court examined a report by the Assistant Labour Commissi…

The Gujarat Electricity Board (GEB) employed about 1,500 contract labourers at its Ukai thermal power plant through various contractors. After the workers were terminated, the union filed a writ petition seeking reinstatement and enforcement of labour laws. The dispute was referred to an Industrial Tribunal under Secti…

The dispute arose from a Tender Call Notice issued by the SCB Medical College Hospital, Cuttack, which required bidders to submit a "valid labour licence". M/s. Utkal Suppliers (appellant) was awarded the contract, while M/s. Maa Kanak Durga Enterprises (respondent No.1) was disqualified for not having a contract‑labou…

The appellants, trained electricians employed by various contractors to maintain electricity at a government medical college and hospital in Chandigarh, sought regularisation of their services, arguing that the Engineering Department of the Chandigarh Administration exercised complete control over their work and was th…

The Supreme Court examined a batch of appeals filed by Oil and Natural Gas Corporation (ONGC) challenging High Court orders that regularised workmen based on the PCLU judgment. The Court questioned whether the PCLU decision correctly interpreted clause 2(ii) of ONGC’s Certified Standing Orders and whether it had consid…

The Air India Statutory Corporation, originally a statutory authority and later a company, employed union members as contract labour for cleaning and related services. The Central Government, as the appropriate Government under the Contract Labour (Regulation and Abolition) Act, 1970, issued a 1976 notification abolish…

The appellants, who were contract labourers employed by contractors of the Board of Trustees for the Port of Calcutta (CPT), sought a mandamus directing CPT to implement a Central Government notification that prohibited the use of contract labour for sleeper renewal, repair and laying of railway tracks within the port.…

Kirloskar Brothers Ltd., the principal employer, appealed against orders that reinstated six contract labourers (Ramcharan & others) and directed Kirloskar to absorb them as employees. The labour contract with the contractor (respondent No.7) had ended and the contractor dismissed the workers. The Supreme Court examine…

The case concerned 2,040 contract labourers employed in SAIL's captive limestone mine who, after a 1993 prohibition on contract labour under the CLRA Act, continued to work and claimed parity of wages with regular SAIL employees under the NJCS memorandum. The respondents sought relief under Section 20(1) of the Minimum…

The case concerned 407 porters and graders employed at the marketing yards of Nilgiri Cooperative Marketing Society Ltd., who claimed permanency and other benefits, alleging they were workmen of the Society. The State referred the dispute to the Industrial Tribunal to decide whether their non‑employment was justified. …

Lingegowd Detective & Security Chamber Pvt Ltd supplied security personnel to Mysore Kirloskar Ltd. The Authority under the Minimum Wages Act, 1948 ordered Lingegowd to pay minimum wages to its workmen by treating them as engaged in a scheduled employment. Lingegowd challenged the order in a writ petition; a Single Jud…

The Supreme Court dismissed ONGC's appeal against the Bombay High Court's order upholding the Central Government Industrial Tribunal's findings. The dispute concerned whether contract workmen engaged through contractors were employees of ONGC and thus entitled to pay parity, and whether a settlement dated 19 September …

The respondents, contract Radio Operators of ONGC, were ordered by the Madras High Court in 2006 to be absorbed as Marine Assistant Radio Operators or, if no posts were available, to receive pay parity. The corporation complied with the pay‑parity direction but did not create supernumerary Marine Assistant Radio Operat…

Hindustan Steelworks Construction Ltd., a government company registered as a principal employer under the Contract Labour (Regulation and Abolition) Act, 1970, engaged M/s Investigation and Security Services India Pvt. Ltd. as a licensed contractor to supply security staff. The contractor paid the workers lower wages t…

The ONGC Purbanchal Employees Association challenged a High Court Division Bench order that remitted two industrial dispute matters concerning the regularisation of contract workers back to the Industrial Tribunal. The Tribunal had earlier awarded regularisation, an award that was upheld by a Single Judge of the Gauhat…

The Karnataka Government ran a Secretariat canteen through a committee and appointed workers on an ad‑hoc basis. The workers claimed they were state employees entitled to regularisation and pay parity with government staff. The Karnataka High Court, treating the canteen as a Government Hospitality Organisation, ordered…

A news report prompted the People's Union for Democratic Rights to file a writ petition alleging that migrant labourers on the Salal Hydro‑Electric Project were denied statutory benefits. The Supreme Court examined reports of the Labour Commissioner, which revealed that the project, executed by the National Hydro Elect…

The Indian Airports Employees Union filed a contempt petition alleging that the airport authority failed to regularise six sweepers employed in the car‑parking area despite a Supreme Court direction to regularise sweepers after the abolition of contract labour. The respondents contended that the six workers were not co…

The Supreme Court examined an appeal by Bhilwara Dudh Utpadak Sahakari S. Ltd. against judgments of the Rajasthan High Court that upheld a Labour Court finding that certain workmen were employees of the appellant, not of a contractor. The Labour Court had determined that the workmen were under the appellant's officers'…

The Food Corporation of India (FCI) employs contract labour through contractors. Contract labourers, organized by the Food Corporation of India Workers' Union, filed a writ petition under Article 32 seeking departmentalisation or, alternatively, the extension of benefits under the Contract Labour (Regulation and Abolit…