## Facts

- A public-interest organization reported that workers in Faridabad, Haryana stone quarries and crushers labored in harsh conditions, many as inter-state migrants recruited through middlemen.
- Allegations included inability to leave work, long hours for inadequate wages, and denial of basic necessities such as shelter, clean drinking water, sanitation, and medical care.
- The petition asserted serious health harms from stone dust and unsafe working conditions, and alleged sexual exploitation of women workers.
- Multiple labor and welfare statutes were alleged to be routinely ignored, including laws addressing mines safety, migrant workmen, contract labor, minimum wages, and bonded labor abolition.
- The court treated the organization’s letter as a constitutional petition and appointed commissioners to investigate conditions on site.
- Commissioners’ reports broadly confirmed severe deprivation, wage diversion by contractors/middlemen, and widespread statutory noncompliance.

## Issues

1. Whether a letter from a public-spirited organization can constitute “appropriate proceedings” to invoke constitutional jurisdiction for enforcement of fundamental rights.
2. Whether an organization lacking direct personal injury has standing to seek relief for bonded/forced laborers unable to access courts.
3. Whether the court may appoint commissioners, rely on their investigative reports, and relax adversarial procedure in public-interest litigation.
4. Whether the quarry conditions constituted bonded or forced labor prohibited by constitutional guarantees and implementing legislation.
5. What affirmative duties the Union, the State, and quarry/lessee employers have to identify, release, rehabilitate affected workers, and implement labor-welfare statutes.

## Decision

- The court held the petition maintainable and treated the letter as a constitutional petition because the affected workers were poor, vulnerable, and practically unable to approach the court.
- The court accepted expanded standing for public-spirited organizations to seek enforcement of others’ fundamental rights in such contexts.
- The court upheld appointment of commissioners and reliance on their reports for fact-finding, subject to the opportunity of authorities and employers to respond.
- The court found that conditions indicated bonded/forced labor and violations of constitutional protections, including the prohibition on forced labor and the guarantee of life with dignity.
- The court issued detailed, affirmative directions to government authorities and quarry/mine operators to:
  - identify, release, and rehabilitate bonded laborers;
  - implement dust-control and health-and-safety measures;
  - provide drinking water, sanitation, and medical facilities; and
  - ensure compliance with applicable labor statutes governing wages, contractors, and migrant workmen.

## Legal Principles

- Constitutional access to court for enforcement of fundamental rights may be invoked through informal petitions when affected persons cannot realistically litigate themselves.
- Standing rules and procedural technicalities may be relaxed in public-interest litigation to prevent fundamental rights from becoming illusory for marginalized groups.
- Courts may employ non-traditional fact-finding (including appointed commissioners) in rights-based cases involving vulnerable populations, and may rely on such reports with fair opportunity to contest.
- The right to life includes the right to live with human dignity, informed by constitutional directives concerning worker welfare, health, and protection of weaker sections.
- “Forced labor” includes labor extracted through economic compulsion and lack of meaningful alternatives, not only physical coercion.
- Constitutional remedies may include affirmative, supervisory directions to secure implementation of welfare legislation where persistent administrative failure results in rights violations.

## Conclusion

The court converted a letter into a public-interest constitutional case, validated investigative fact-finding through commissioners, and ordered government and employers to eradicate bonded/forced labor and enforce labor-welfare laws as necessary to secure dignified living and working conditions.


Bandhua Mukti Morcha v. Union of India, A.I.R. 1984 S.C. 802 (India 1983)