HomeLegal ColumnsStatus of Daily Wage Labourer in the Indian context

Status of Daily Wage Labourer in the Indian context

Introduction

The huge amount of physical and mental work put in by millions of daily wage workers across the world and especially in India is a fascinating yet a disheartening study. Not only their work is quantified into small pockets of “wages” but also this quantification further spirals them downward into the social and the economical strata of the society.

The end of the day wages received by the workers are akin to the concept of ‘pocket money’ only the not-so-subtle nuance is that the former is for existence and the latter’s role is debatable. Thus, the wages form a very fundamental role in the overall being of the workers and their families.

The disparity, especially in India comes to surface when we have already witnessed a huge amount of time and resources being wasted on debating both real wages and wage policy prevalent in the country during different eras. The omnipresent question as to setting up a national floor-level minimum wage along with the implementing of myriad calls of minimum wages across states has always stared into the faces of the policy makers. The author also would like to point out that there is zero correlation between India’s status as an emerging economy and being a part of the G20 League to the grim picture of daily wage earners.

A good policy, according to the author should have clarity in objectives along with a proper and a well-structured strategic design. Financing and the outcomes of the policy follow suit to make it error proof. However, in the context of the wage earners and various policies laid out for them have found wanting and have hugely missed the point of taking everyone to the finish line and not isolating the downtrodden. The current pandemic exacerbated the deplorable state of the daily wage workers in India. Factors like labour market institutions (particularly minimum wages and collective bargaining) influence the wage levels and their distribution. The author would also be the covering the gender disparity across the wage earners and its massive effect on the overall shaping of the economy.

Theories of Wages

“Pay the worker his wage before his sweat is dry”- Quran.

The above mentioned adage means the high regard and the sine qua non a worker plays in the society from time immemorial. Wage remuneration or earning is not a new concept, however, the various theories of wage and the study as to what encompasses what is a fairly new field. The author tries to list some of the most common wage theories.[1]

  1. Subsistence theory- As the name suggests it, only the amount which is sufficient to maintain the labourer and his family is paid. Nothing more, nothing less. David Ricardo was the propagator of this theory at large.
  2. Standard of Living Theory-The standard of living of the labourer is deciphered and he/she is paid wages according to that standard. Here, it is to be noted that ‘subsistence’ of the labourer is not brought into question.
  • Residual Claimant theory- Francis A. Walker explained this theory where factors of production in a business activity viz. labour, land, capital, and entrepreneurship were found as determinants. The ‘leftover theory’, here, the labourer is paid the wages from the residual amount which remains after all the different factors of production have been already paid. This sometimes give rise to disputes as the amount is not fixed beforehand giving rise to ambiguity and the labourer feeling disenfranchised and without a recourse to claim his/her rightful wage.
  1. Wages Fund theory- Contrary to the Residual Claimant Theory and founded by Adam Smith, here the wages are distributed from a fund which is already pooled in depending on the population of the workers. Following the simple principles of demand-supply, here the wages received by the workers is inversely proportional to the number of the workers present.
  2. Marginal Productivity theory- Phillips Henry Wick-steed and John Bates Clark gave this theory according to which wages is determined according to the contribution of the last worker who worked, the so called ‘marginal worker’.

Five Year Plans and wages in India: A simple reconstruction

The urgent need for a well-developed wage structure with a demand to raise the real wages was felt post-Independence. The consciousness grew due to our society and especially our daily workers feeling free from the clutches of the colonial rule.

Primarily an agricultural society (the contribution of agriculture to the overall GDP was a whopping 54.1% during 1951)[2] made the people at the helm of power realize the importance of daily wage workers and their future role if India were to thrive.

First Five Year Plan and its subsequent impact

With agriculture and giving flippant to the economy as its core, the First Five Year Plan was very worker friendly, so to speak. The workers’ right to association, organization and collective bargaining were to be accepted as the basis of mutually satisfactory relationships. Also, The Minimum Wages Act, 1948 fixed the minimum wages for a particular type of employment, which included agriculture too.

Second Five Year Plan and India flexing its muscles

Although, agriculture was still the focus (agriculture contributing 49.1% of the GDP)[3], now a paradigm shift to include other industries’ workers started to come into light. Norms including that of creation of industrial peace and subsequently of a holistic ‘industrial democracy’ were accepted during the Second Five Year Plan (1956–61). Socialism was given an impetus and a strong trade union was seen as a prerequisite to attain the same.[4]

The wage policy got tweaked significantly to achieve this aim and the following pointers were laid down: –

  1. Emphasis on rising real wages by increasing productivity through better layout of plants, improving the working conditions along with the training of the workers and assuring them minimum wages and protection to all was laid down. To bring wages into conformity with the expectations of the working class
  2. Setting up of wage boards (which usually consisted of an equal number of both the representatives of employers and workers and an independent chairman) in individual industries in different areas for the settlement of wage disputes.

The Indian Labour Conference, in 1958, also adopted “A Code of Discipline in Industry” in 1958, which followed the principles of natural justice subjecting all the future differences, disputes and grievances arising to a systematic process of mutual negotiation, conciliation and voluntary arbitration. By forcing the employers to recognize trade unions as bargaining agents, the Code thus helped in “facilitating the process of collective bargaining”.[5]

The wage policy under the Second Plan was investigated by A Tripartite Committee of the Indian Labour Conference which declared certain norms They were:

  1. One earner of was supposed to be having three consumption units as ‘The standard working-class family’ sans the earnings of women, children and adolescent.
  2. The net calorie intake was the basis of calculating the Minimum food requirement of the individuals and their families.
  3. Eighteen yards per annum per person of clothing and seventy-two yards per annum for four persons was the norm.
  4. The Government Industrial Housing Scheme was the nodal authority according to which the rent of the minimum area of a particular place was decided.
The Third Five Year Plan

Bringing gender disparity in employment and wages, the Third Five Year Plan (1961-1966) recognized the need of the hour and pledged to encapsulate the Gandhian principle of “equal pay for equal work. The emphasis also shifted towards generating employment-based policies and the other benefits which follow with it. The need to consider price stability and to link wages to productivity and good industrial relations was emphasized in the Fourth Five Year Plan (1969–74).

Sixth Five Year Plan and the rise of the unorganized sector

Detracting from the earlier plans, the Sixth Five-year Plan (1980-85) focused on the unorganized and not just the organized sector. This included artisans, fishermen, agricultural labourers et al. This plan gave the power to fix and revise the minimum wages and to devise a wage structure without violating the freedom of the parties to negotiate freely. Social factors (minimum basic needs, adjusting real wages for rise in cost of living, allowances for occupational hazards, bonus, social security benefits, among others) and economic factors (capacity to pay, profitability and productivity, consumption pattern, cost of living and regional disparities, among others) were given due preference. Recognizing minimum wages for low-paid workers to achieve a minimum standard of living and to attain industrial harmony for maximum output, this era while admitting collective bargaining as a necessary tool also gave respect to the before mentioned factors for economic progress, particularly in the core sectors.

The Latest Five-Year Plans: Consolidating the obvious

The post-Independence Five Year Plans were robust in the sense that India wanted to prove that it has got able minds and hands to run it. However, the subsequent plans like the Eighth (1992–97) and the Ninth (1997–2002) Five Year Plans again stressed the safe and humane working conditions, social security benefits, improvement in the productivity of labour and reducing malpractices in wage payment. The author would like to argue that maybe the economic liberalization following 1991 had shifted India’s focus towards a more open society to the outside world that sometimes the people already suffering are left behind could have been the case. Shifting the focus towards labour flexibility, labour law reforms and skill development so that foreign countries and businesses get attracted to set up their shops in India, the question of minimum wages was thus raised.

Wage-Setting Institutions

The two wage-setting institutions in India, the role of which will be discussed are as follows-

  1. Wage boards
  2. Collective bargaining
Wage Boards

The idea to provide wage-fixing machinery and to work out a wage structure (for the organized sector) was central to the recommendations made by The Committee on Fair Wages, 1948. At the state level, the wage boards were a tripartite body formed by the government, comprising representative of employers, representatives of workers and independent members which represented the public at large. Their main tasks ranged from recommending wages to getting compensation, setting the gratuity, and also fixing the number of hours for the workers, etc. The cotton textile and sugar industries, influenced by the wave of Swadeshi still around the country saw the rise of the firs wage board set up in 1957.[6] The enormous success in these industries led to the normalizing of wage boards which soon mushroomed throughout the country in huge numbers and in myriad industries mainly on the demands of the worker and the trade unions. The print media, probably given their ‘esoteric’ and ‘erudite’ level in the hierarchy of industries got their wage boards registered as statutory while every other wage board was non-statutory in nature. Maybe a pen is mightier than sword. Maybe. A region-cum-industry approach to determine the wage levels and the structure of wages was adopted throughout the country, however, this soon went out of fashion and since the liberalization of our economy in the early 1990s, the number of these wage boards have dwindled.

This has had a huge impact on the lives of workers and especially on that of various daily wage earners who have found it difficult to make their voices hear over the humdrum of ‘economic growth’ and ‘inclusive growth’. The author would like to make the point of ‘exclusivity approach’ adopted by the industrialists where more often than our daily wage earners are left out of the discussion. The discourse on how “India has cheap labour due to its large population” must shift towards that each worker and their families) are literally living for survival every day, a grim picture unseen by us, either voluntarily or due to our sheer foolishness.

Collective Bargaining

Collective bargaining has been adopted in several developed nations such as the UK and the USA. It has been taken up in India as well in the form of compulsory adjudication but the implementation of the same has been extremely poor.

The term “collective bargaining” was coined by Sydney and Beatrice Webb. Though there is not unanimity between scholars as to the definition of the term, it is essentially taken to mean any sort of agreement between the employers and employees with respect to the conditions of employment and term of service. It involves 2 parties namely- the employers either on their own or represented by the employers’ union/federation and the workers represented by their unions. Sometimes when the law provides for collective bargaining, the trade unions are also referred to as bargaining agents. There has been a long-standing debate that a representative of the public/government must also be allowed to be a part of the bargaining table.

The ILO has divided the subject matter of collective bargaining into 2 categories-

  1. Those which set out standards of employment and regulate employer- employee relations. E.g., wages, working hours, etc.
  2. Those which regulate the relations between the parties to the agreement and do not affect the employer-employee relationship in any way. E.g., methods of enforcing collective bargaining, methods of settling individual disputes, etc.

The International Confederation of Free Trade Union has referred to collective bargaining as a ‘worker’s bill of rights’ and has laid down the following objects of collective bargaining-

  1. To establish recognition of trade unions.
  2. To increase the standard of living of workers and to give them a fair share in the company’s profits.
  • To practically express their demands and to ensure democratic participation.
  1. To settle day to day disputes in the establishment.
  2. To achieve general objectives such as defending and promoting the interests of workers in the country.

Minimum Wage Policy in India: How Far Are We from Security?

By adopting “living wage as an objective”[7], India passed The Minimum Wages Act, 1948 soon after attaining Independence. This showed the far sightedness and the necessary coverage the daily workers should have got during a period of an uncertain future of the country. A tripartite committee comprising employees, employers and government representatives was constituted in 1948 and christened as The Fair Wages Committee (the Committee), which looked after the sole task of maintaining minimum wages across the strata of economic ladder. The recommendation served as steppingstones for future legislations to be shaped up accordingly and the subsequent wage-fixing machinery of the country got fuel from the Committee itself.

How were the Wages defined?

The Committee focused on segregating the wages into various forms. Among the most popular forms were:

1. Living wage

The highest and the most important level, this comprised the basic coverage of clothing, shelter, education of children, health insurance and old age insurance. This basically meant that an all-encompassing approach which looked after oneself from birth till his old age was covered.

2. Fair wage

This basically meant that not only the subsistence but also the standard of living should be looked into while envisaging a wage structure. So that the country keeps on the path of growing employment, this wage structure, after giving due consideration to the national income, productivity and the capacity to pay of the industry concerned, wanted people to come out of the clutches of poverty and inequality for the various generations which were to follow.

3. Minimum wage

The most talked about aspect and probably which is the most abused one too due to inept policy implementations even today, ‘minimum wage’ started off as a noble concept. The basic aim was to provide for the sustenance of life and also to provide a cushion where the worker (and his family) could enjoy basic education, could meet medical requirements and conserve the efficiency of the worker. “The “bare minimum” or the bare necessities were covered via this wage structure, below which, quantification of work for money was considered simply barbaric.”

Recommendations given

Setting up of a wage board for each state and a ‘regional’ board for each industry in order to fix and regulate wages. The Standing Labour Committee, following the guidelines of the Committee given held various meetings in order to establish the ‘statutory wage-fixing machinery’ on the lines of the Minimum Wages Act, 1948.

Implementation and the flawed state of affair

The idea of minimum wage, though operationalized by various central and state policies (although not properly), living wage remains at a theoretical level an no actions have been taken to bring that to paper. Fair wages, on the other hand, though not having a fixed and a precise character were still given due thought by the various wage boards. However, as already mentioned by the author before, the economic reforms in India soon led to a demise of wage boards and subsequently to the concept of fair wages in India.

The Minimum Wages Act, 1948 itself does no good to determine any criteria of the minimum wage by leaving it undefined. The recommendations of the Committee (1949) and the decisions taken by the 15th Session of the Indian Labour Conference (1957) along with the decision given by the Apex in the historic Raptakos Brett judgement (which held that the “need based reforms laid out in the 15th Session of the Indian Labour Conference” should act as the guiding light) serve as the seminal works and the torch bearer to define minimum wages in 1992.

After effects of The Minimum Wages Act, 1948: Post scenario

It was only after the first National Commission on Labour (1966–69) formed that a question of wages was asked extensively. The Commission recommended the formation of a wage policy which would ensure industrial harmony and increase productivity and the workers’ share in it. Also, the Commission took into consideration the basic workers’ level of living and the impact it would have on prices. The Bhoothalingam Committee set up in 1978 recommended the rationalization of wage differentials, wage disparities, the linking of wages with productivity and a national minimum wage.

In 1987, the Regional Minimum Wage Advisory Committees worked to deal with the disparities prevalent in minimum wages across the states in the country. These committees together got together and were renamed as the Regional Labour Ministers’ Conference, which made a number of recommendations including-

  1. Reducing the disparity in minimum wages between states of a region.
  2. Setting up of an interstate coordination council.
  • Consulting with neighboring states while fixing/revising minimum wages. However, there is hardly any evidence to suggest that these recommendations are being seriously followed.
  • Also, in order to protect fixed minimum wages against inflation, they have been linked to the Consumer Price Index for Industrial Workers (CPI-IW) after this was recommended at the Labour Ministers’ Conference in 1988.

Getting forward, in the year 1996, a National Floor Level Minimum Wage was formed based on the recommendations of the National Commission on Rural Labour, 1991. Though statutory backing was not provided, the Floor Minimum wage is revised time and again and it is imperative for the state governments to fix their ‘minimum wage’ above the floor level fixed.

As already discussed, the advent of post liberalization shifted the focus of the country and the second National Commission on Labour (1999–2002) did the same by fixating upon labour flexibility, technological changes, and economic growth as considerations in wage setting. A policy based on a principled set of norms was envisaged wherein attainment of social justice and higher employment levels were given emphasis to. Capital formation and price stability, likewise, came into the milieu.

A statutorily backed National Minimum Wage along with a National Minimum Social Security and Minimum Conditions of Work to ensure the safety and health of workers was suggested by the National Commission for Enterprises in the Unorganized Sector (NCEUS).[8]

The various committees, commissions and wage boards have done their work, but on paper only. The stark reality is disheartening as till date, only a limited proportion of workers (66% to be precise) receive minimum wages and the rest are still in the left out of the coverage. Though a debate has been ensuing and boiling amongst the academicians, scholars, and the like as to what should be the “right” approach to the wage policy, where some even suggesting the introduction of “binding national minimum wage for all workers”, not much has come to fruition due to the red tapism and vote bank politics played during elections.

Diversity in India is what gives it its uniqueness, its binding force. Thus, the debate between trade unions who want a single, consolidated minimum wage structure and employer organizations who want a region-wise and sector-wise wages is diverse and vivid in its nature. The daily wage earners thus get lost in between and are therefore left without any actual way out of this humdrum since different states have different policies. Knowing that these workers are also migrants in many cases, they are thus left with no option but to acquiesce to what the big corporates or the big industries tell them.

Judicial Stance

The main legislative instruments regulating wages in India are:

  1. Minimum Wages Act, 1948
  2. Payment of Wages Act, 1936
  3. Payment of Bonus Act, 1965
  4. Equal Remuneration Act, 1976

The main objective of these laws has been to ensure that labour was not employed in precarious conditions.

In India, the concept of a laissez faire state and payment of wages based on market forces had withered away long back. With the advent of the concept of the welfare state, the government was expected to take active part in determination of such wages.

The wage structure in the Indian context is controlled by various factors such as the strength of trade unions, different industrial relations practices, approach to strike strategy as a consequence of non-agreement, competitive price of products, attitude of competitors, availability of raw materials, etc.

In Workmen v. Management of Reptakes Brett & Co. Ltd., the SC stated that a minimum wage shall consider factors like children’s education, medical requirements, minimum recreation including festivals or ceremonies and provision for marriage, etc.

In Crompton Greaves Ltd. vs Its Workmen, it was held that the wages must be fixed keeping in mind the wages prevalent in the same industry in the region or otherwise.

Article 43 of the constitution has enshrined a DPSP as per which the state must endeavor to secure by way of legislation, a living wage for its workers.

In RB Employees Association v. Reserve Bank, it was held that living wage is that which should not only provide for the essentials but a fair measure of frugal comfort and an ability to provide for evil days and old age.

The factors which need to be kept in mind while fixing wage rates in a socialistic set up are as follows-

  1. Wages cannot be set in vacuum. They depend not just on employers and employees but also on consumer and the community.
  2. Wages must be paid so that the worker enjoys a decent standard of living and he and his family lead a dignified life as provided under DPSPs.
  3. Wages are not set at such high levels as cannot be afforded by the industry.

Exclusion faced by women

Women wages have been ridiculously lower than that to men. The fact that men have already exceptionally low minimum wages (especially the daily wage earners) makes the study of women workers (and daily wage earners) a very painful one.

According to Oxfam, women in India are massively underpaid to their male counterparts; the gender pay gap presently is at 34%.[9] The age-old patriarchy which still holds India by its neck, or the education received by the women or be it whether they are not ‘suited’ for the employment has only worsened the situation vis-à-vis women and the wage gap.

Exclusion faced in mines: Painting our women employees back

If not already the working in mines is hazardous, the fact remains that even here women face huge setbacks. Technological advancement and policy changes forced some Adivasi and marginalized women out of the workforce which also depended on what the males wished the labour force to look like.[10]

Tea plantations and where choice of women does not brew

Although, on the face of it, via movies or social media picture of a woman working in a tea plantation in Assam or Darjeeling might give a high number of women employed in this industry, the actual reality cannot be starker. The fact of the matter remains that by ‘employing’ women into the plantations (by their kin who already are a part of the trade unions) have made sure that their wages remain low, and the actual control is still with the male fraternity. Also, it is argued by the author that women hardly get to exercise their choice and get swayed by what their family members (especially males) tell them.[11]

Exclusion from agriculture workforce: excluding the Annapurna

Landless women labourers, by far are the most distinct and the most visible workforce in the country. These women usually belong to the poorest rural households and also are the marginalized and backward ones. Also, they face serious disadvantages as compared to men to find employment opportunities and whenever they do, they get paid meagerly.[12]

The author has found that the disparity is not only present in these specific case studies but also is there in almost every employment of the country where there is hardly any respite and no end in sight for these women.

Understanding the New Labour Code

Introduction

The bill was introduced with the intent to codify relevant provisions of four existing laws and to increase the legislative protection of minimum wage to the entire workforce. The codification proposes to simplify 32 central labour laws into four codes to bring them in sync with the emerging economic situation. Done to facilitate easier compliance by establishments, promote ease of living and ensure labour welfare and wage and social security for workers.  Further to ensure national minimum wages throughout the country. The 4 laws compiled are – Payment of wages Act, Minimum wages Act, Payment of Bonus Act, Equal Renumeration Act.

Critical Analysis of the Code

The Wage Code is backed by the central government’s claim that it will address the wage crisis by simplifying the multiplicity of definitions and authorities involved. Yet, the reality is somewhat contrary. The Wage Code has made definitions unclear by leaving much to the discretion of government authorities or to the interpretation of judicial bodies. For instance, no attempt has been made to define and outline the methodology for setting minimum wages, leaving the procedure to be formulated by the centre as seen fit.

Another claim by the government was that these codes will bring the vast unorganized sector under its ambit and ensure compliance. Again, contrary to this claim, minimum wage law was meant to cover sectors that suffered from weak collective bargaining power, especially those with a high concentration of casual labour.

The main challenge rather was the faulty and poor implementation of existing laws.

One of the biggest drawbacks of this code is that it did away with the formula stated in Supreme Court ruling in the Raptakos Brett case of 1992. Now the Wage Code leaves the setting of minimum wages to the discretion of administrators, disregarding the rights of workers to wages that are adequate for leading a dignified life. Moreover, there is no clarity on the particular authority designated for setting the minimum wages, or the procedure which is to be followed. The danger of using ambiguous language for establishing minimum wages was revealed in the government’s recent announcement, which set the national floor for the minimum wage under the Wage Code, at a mere Rs 178.  The amount has been referred to as the “starvation wage,” and it is only Rs 2 higher than the previous national minimum wage, which was set two years ago

Additionally, the setting of different state-level minimum wages is now in the hands of respective state governments, so long as they do not place their minimum wages below the floor set by the central government for that state or region. This might lead to a race to the bottom between states that are competing with one another to lower wage rates and bring in greater investments.  The consequence of this competitive federalism, based on labour cheapening between states, would lead to repressed wages throughout the country[13] For instance, this was seen in the case of the Okhla Industrial Area in Delhi, wherein businesses shifted out from Okhla to Haryana and Uttar Pradesh to take advantage of lower minimum wage rates in the latter (WPC 2019)

The other provisions of the code states that the central or state-level advisory boards, whose functions include maintaining checks and balances, and ensuring representation of all stakeholders would not be binding on state governments. Further the composition of the board has been altered and the number of employees has been limited to three members, all of whom would be nominated by the government. The representation of women among the nominated employees has been reduced from 50% (as under previous legislations) to one-third. This move has undone years of work spent to make the government accountable to stakeholders.

The Wage Code also takes away the jurisdiction of courts in providing justice to workers who have faced violations with respect to their wages. The employers are now to approach the quasi-judicial body and appellate authority set up under the provisions of the Wage Code. The government is claiming that the setting up of an appellate authority to redress violations regarding workers’ wages will lead to speedy, cheap and effective resolution of wage disputes. However, it gives the appellate authority, whose membership is not defined, the sole power to adjudicate on wage disputes, which are not subject to review by the courts. This is in clear violation of the Civil Procedure Code, Section 9, which mandates that every law or decision made under its authority be subjected to review by the judiciary.

Conclusion

The need of the hour is a drastic focus shift from policy making to policy implementation.  Further the wage gap that exists between men and women needs to be abridged. This can be done through the means of ensuring women access to education and basic nutrition to create a level playing field for women to represent themselves.  Discrimination based on pure stereotypes e.g., women cannot handle technology, and women can only work in labour intensive environments etc. need to be shunned and done away with. Equal pay for equal work mindset is to be adopted.

The following principles should form the foundation of every policy making or implementation process-

  • The concept of maitri- which talks about universal brotherhood and compassion should be forwarded with zeal (as envisioned by Dr. BR Ambedkar)
  • Right to a dignified standard of living and enhancements of capabilities.
  • Social welfare and the role of the state (DPSPs).
  • Labour day, celebrated on 1st May, should not be a mere symbolism but internalizing and introspecting the hard work a daily wage earner puts in and giving him/her the reward that they deserve should be a priority.

[1] J. R. Hicks, The Theory of Wages, Second ed.

[2] Amarnath Tripathi and A.R. Prasad, “Agriculture development in India since Independence: A study on progress, performance, and determinants”, Journal of Emerging Knowledge on Emerging Markets, Vol.1 Issue 1, 2009.

[3] Ibid.

[4] India Wage Report, International Labour Organization, 2018.

[5] Das DK, “Manufacturing productivity under varying trade regimes: India in the 1980s and 1990s”, Working Paper No. 107 (New Delhi, Indian Council for Research on International Economics Relations), 2003.

[6] Supra note 5.

[7] Enshrined in Article 43, Constitution of India, 1949.

[8] National Commission for Enterprises in the Unorganized Sector, 2006.

[9] Unpaid Work by Women Worth 43-Times Apple’s Annual Turnover: Oxfam, Jan. 21, 2019 ((https://www.ndtv.com/india-news/oxfam-says-unpaid-work-by-women-worth-43-times-apples-annual-turnover-1980618).

[10] Kuntala Lahiri-Dutt, From Gin Girls to Scavengers (Women in Raniganj Colleries), Vol. 33, Issue 44, Nov. 2001 (https://www.epw.in/journal/2001/44/special-articles/gin-girls-scavengers.html).

[11] Kanchan Sarkar, Sharit K Bhowmik, Trade Unions and Women Workers in Tea Plantations, Vol. 33, Issue 52, Sep. 1998 (https://www.epw.in/journal/1998/52/review-labour-review-issues-specials/trade-unions-and-women-workers-tea-plantations).

[12] Martha A Chen, Women s Work in Indian Agriculture by Agro-Ecologic Zone-Meeting Needs of Landless and Land-Poor Women, Vol. 24, issue 43, Oct. 1989 (https://www.epw.in/journal/1989/43/review-womens-studies-review-issues-specials/women-s-work-indian-agriculture-agro).

[13] People’s Union for Democratic Rights, 2017

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Law Wire Team
Law Wire Teamhttps://lawwire.in/
Law Wire Team attempts to delve into pertinent (and sometimes not immediately pertinent) questions regarding socio-politics, Law and their interesting matrix.
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