EVIL IMPACT OF INDUSTRIAL REVOLUTION ON SOCIAL SECURITY SYSTEM IN INDIA

CHAPTER 1

INTRODUCTION

For the efficient functioning of a working unit an amicable environment, cooperation between the workers and the employers, reasonable remuneration and proper working condition are the prerequisites. From the laissez faire to the ‘welfare state’, the socio-economic conditions have faced drastic changes, not only in India but also across the world.

The industrial position that prevailed in the pre-independence era of India does not remain pristine. The industrial revolution in India brought with it certain inhumane as well as unjust aspects of the colonial era. To cope with these problems, and provide social security industrial legislations were enacted in India. To keep pace with the changing socio-economic conditions in India, the Legislature as well as the Courts had to check the unfavourable growth of the industrial legislations.

Industrial legislation finds its origin from the industrial jurisprudence, which is a development of the 20th century world. In India, industrial jurisprudence prevailed before the Independence, but it was in the rudimentary form. Industrial revolution was the emanating factor behind the growth of the industrial jurisprudence. Industrial revolution brought with it the most inhumane aspect of the human life. It saw the exploitation of a man by a man. The maximization of profit, even at the cost of the life of the labourers, was paramount goal of the employer. ‘Freedom of contract’ was the evident result of the laissez faire. The employer was free to fire the employee, at his arbitrariness.

Thus the employees were always at the loss.
To protect the interest of the employees, the legislature and courts, in India took a giant step to give birth to the industrial jurisprudence in India- former trough the enactments and the latter through the judgments. The scope of industrial jurisprudence not only covers the protection of interests of the employees but it also aims at securing a cordial relationship between the employers and employees in a working unit. 

1.1 Concept Of Social Security

The International Labour Organisation (ILO) defines Social Security as "the security that society furnishes through appropriate organization against certain risks to which its members are perennially exposed. These risks are essentially contingencies against which an individual of small means cannot effectively provide by his own ability or foresight alone or even in private combination with his fellows. The mechanics of social security therefore consists in counteracting the blind injustice of nature and economic activities by rational planned justice with a touch of benevolence to temper it.”

Modernization and urbanization have resulted in radical socio-economic changes and give rise to new conflicts and tensions consequent upon the erosion of age old family and fraternal security. The transition from agricultural economy to an industrial economy brought in special accompanied problems that called for social security.

CHAPTER 2

EVIL IMPACT OF INDUSTRIAL REVOLUTION ON SOCIAL SECURITY SYSTEM IN INDIA

As per the economic policy of the British government, they never wanted to make India an industrial base, rather they wanted to make India a supplier of raw materials for their industries. Instead of promoting industries in India, they continued to de-industrialise and ruralise the Indian economy.
Further with the advent of industrial revolution in England, the British government revved up its efforts to further exploit the Indian economy. As a result, in 1947, when the British left, India represented a ruined economy, a sick society and the present danger of the evil effects of neo-colonialism. However, the evil impact of industrial revolution can be classified into Social Evils and Economic Evils, which are discussed as below:

2.1.         Economic Evils: The artisans lost the psychological satisfaction that they derived in producing goods themselves. In the industries, they had to produce only a part of the finished goods.  The labourers were underpaid. They could just earn from hand to mouth. The wages were sufficient to provide them with the daily bread, but at the cost of other necessities of their life. The term of employment was not secure. The employers were free to exercise their arbitrariness in sacking the labourers. The factory workers had to suffer from the periodic unemployment and under-employment. 

2.2.         Social Evils: The overcrowded cities, due to the large-scale immigration of the village population in the cities led to the industrial slums and acute housing problems. It had its adverse impact on the health of the workers and also led to the sanitation problems in the cities. The working condition in the factories was hazardous. Moreover, the long hours of duty, with no rest and no facility of recreation marred the welfare of the workers. The machines were taken care of by the factory owners, with little regard for the safety of the workers. Workers were exposed to serious accidents caused by the improperly managed machines in the factory. These accidents were not taken seriously by the factory owner. The victims of such accidents did not have any right to compensation.

Due to the inadequate wages, the wives and children of the workers were exposed to the exploitation by the factory owners. They were employed at low wages without regard to their physical conditions.

CHAPTER 3

LABOUR PROBLEMS IN INDIA

The factory owners paid their sole attention towards the maintenance of the machines irrespective of the health and working conditions of the workers. The employers neglected the conditions of the workers as the manual labour was abundantly available to them. The workers were underpaid. They could not raise their voice. They were illiterate and poor, so were ignorant of their rights. Taking the advantage of this situation, the employers dictated their own terms.
    The government also did not interfere in the matter as it was deemed to be a freedom of contract. The situation worsened further. The government could not just see it as a neutral player and it had to interfere. Moreover, some of the philanthropic agencies like the Servants of India Society and Social Service League raised voice against these problems. Later some industrial social workers also raised voice against these problems. Initially, they lacked in the resources and bargaining power but they were successful in mobilising the public voice against these problems.

Later, the factory owners also realised the seriousness of the problem and also that a contended worker will add to the productivity of the factory. 

Later the Government also, could not confine itself to a neutral spectator. The Government also realised that it was in the interest of the national economy as well as the labourers that constitute a bulk of population in India. Thus the drive for the welfare of the labourers and for the protection of the Indian economy compelled the Government to intervene in the situation.

CHAPTER 4

EVOLUTION OF INDUSTRIAL JURISPRUDENCE TOWORDS SOCIAL SECURITY AND CHANGE IN LABOUR RELATION POLICY IN INDIA

The evolution of Industrial Jurisprudence in India can be traced back to the period of post Independence. Before the Independence, the industrial jurisprudence existed in a rudimentary form. The paramount concern of the Pre-independence industrial jurisprudence was the amelioration of the working condition of the workers at the factories. There was hardly any deal with the social justice to the working class. It was only after the commencement of our Constitution, that the adequate provisions for the social justice to the workers were inserted.
    Before the Independence, India was not only a great agricultural country, but also a manufacturing country. But the British Government, as a matter of their policies always tended to discourage the Indian industries. This led to a widespread nationalism in India, which laid emphasis on the boycott of the foreign goods. Further a Non-Cooperation Movement saw its birth that is also called Swadeshi movement, which emphasized on the use of indigenous goods and boycott of the foreign goods.

 The aspect of industrialization in India was based on the program of planning, which was accepted after thirties.

 It is important to take into consideration that the plantation industry of Assam was the first to attract the industrial legislation. The situation there was that the employers  exercised hard practices against the employees. The employees were not allowed to leave the tea gardens. A number of Acts were passed from 1863 onward, but they only protected the interests of the employers. Some other Acts were also passed to regulate the condition. But the Workmen’s Compensation Act, 1923 was the landmark Act.

4.1. INDIAN CONSTITUTION AND SOCIAL JUSTICE
Industrial Jurisprudence was not in a much developed form before the commencement of the Constitution of India. Before the Independence, the paramount concern of the Government was to ameliorate the condition of the factory workers. It was after the commencement of the Constitution that the paramount concern of the Government shifted towards the social justice for the labourers, who constituted the bulk of the population. 
Bhagwati J., in a landmark case opined that;

 “concept of justice does not emanate from the fanciful notions of any particular adjudication but must be founded on a more solid foundation.

And Justice Gajendra gadkar also opined that;

“the concept of social and economic justice is a living concept of revolutionary import; it gives sustenance to the rule of law and meaning and significance to the idea of welfare state”.

   The Indian Constitution also enshrines the idea of social justice as one of the objectives of the State. Some of those provisions are as follows:

1.     The State shall strive to promote the welfare of the people by securing and protecting as effectively as it may a social order in which justice, social, economic and political.

2.     The State shall, in particular, strive to minimize the inequalities in income, and endeavor to eliminate inequalities in status, facilities and opportunities, not only amongst individuals but also amongst groups of people residing in different areas or engaged in different vocations

3.     The State shall, in particular, direct its policy towards securing

a)     that the citizen, men and women equally, have the right to an adequate means of livelihood; 

b)    that the ownership and control of the material resources of the community are so distributed as best to sub serve the common good;

c)     that the operation of the economic system does not result in the concentration of wealth and means of production to the common detriment;

d)    that there is equal pay for equal work for both men and women;

e)     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;

f)      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

4.2 SOME IMPORTANT LABOUR ENACTMENTS IN INDIA

The following few legislative measures have been adopted by the Government of India to promote social security schemes for industrial workers.

a)     The Indian Factories Act of 1948 provides for the health, safety and welfare of the workers.

b)    The payment of wages Act, 1936, regulates the k\timely payment of wages without any unauthorized deductions by the employers.
The Minimum Wages Act, 1948, ensures the fixation and revision of minimum rates of wages in respect of certain scheduled industries involving hard labour.

c)     The Industrial Disputes Act, 1947, provides for the investigation, and settlement of industrial disputes by mediation, conciliation, adjudication and arbitration. There is scope for payment of compensation in cases of lay-off and retrenchment. 

d)    The Industrial Employment (Standing Orders) Act, 1946, requires employers in Industrial establishments to define precisely the conditions of employment under them and make them known to their workmen.  These rules, once certified, are binging on the parties for a minimum period of six months.

e)     The Indian Trade Unions Act, 1926, recognizes the right of workers to organise into trade unions, when registered, have certain rights and obligations and function as autonomous bodies. 

f)      Workmen’s Compensation Act, 1923: The Workmen’s Compensation Act was passed in March 1923, and was put into effect on 1st July 1924. This Act followed the British model, but was adapted to suit Indian conditions. Was-time injuries were also covered by the Act. The 1962 Amendment raised the wage limit covered under the Act to Rs.500 per month. It also amended the clauses bearing on industrial diseases, and revised the rates of compensation. With effect from 1st October 1975, the wage limit coverage under this Act has been raised from Rs.500 to Rs.1000 per month.

g)     Employees’ State Insurance Act, 1948: Two conventions on health of workers in industry, commerce and agriculture were adopted in 1927 by International Labor Conference. The question about health insurance was also discussed by the Royal Commission on Labor, and a tentative scheme of health insurance was proposed in its comprehensive report in 1931. Its recommendations on the adoption of a health insurance scheme were not accepted by the Government of India because of financial difficulties. All these built up a lot of pressure on the government.

The one-man committee of Professor B.P. Adarkar, set up in March 1943, submitted its report on a scheme of health insurance for industrial workers in August 1944. It recommended a compulsory and contributory health insurance scheme for workers in perennial factories in three groups of industries, namely textiles, engineering and minerals and metals. Bearing all these modifications and recommendations in mind, the Government of India passed the Employee’s State Insurance Act in April 1943, which provides cash benefit in contingencies of sickness, maternity and employment injury, but did not provide security in such contingencies as unemployment and old age. The dependents of workers who died as a result of any employment injury were paid compensation in the form of a pension.

The E.S.I. Scheme stated with coverage of about 1.20 lakh industrial workers in Kanpur and Delhi on 24th February 1952. It has continued to progress over all these years. By the end of March 1976, there were 388 centers covering nearly 22 million beneficiaries under this scheme. The total number of employees and insured persons under the scheme at the end of 1995-96 was respectively 66.13 and 73.03 lakh insured persons.

The ESI Scheme offer both direct and indirect medical care. The direct method is called the “Service System” by which the ESI Corporation provides medical care, either through its own Employees’ State Insurance Hospital or through reservation of beds in State Government hospitals. The indirect method is known as the “Panel System”, under which medical care is provided through private doctors selected by the State Government with the approval of the ESI Corporation.

The benefits provided by the Act are:

·        Sickness Benefits;

·         Maternity Benefits;

·         Disablement Benefit

·         Dependents’ Benefit;

·         Funeral Benefit; and

·        Medical Benefit.

All workers, earning less than Rs.3000 per month and employed in power-run factories employing 20 or more persons are covered by this scheme. However, it does not cover workers employed by seasonal factories. An insured person under ESI Scheme is not eligible for similar benefits under the Workmen’s Compensation Act and State Acts relating to maternity benefits.

CHAPTER 5

IMPACT OF ILO ON INDIAN LABOUR LAWS

(A Step Towards Social Security To Labours)

The International Labor Organization (ILO) was set up, with an aim to develop the conditions of labours and to provide the social security not only in India but around the world, in the year 1919. India was the instituting member of ILO which now expanded its primary membership to 145 countries. Indian Labor Organization through its resolutions and recommendations supports countries to lure their own set of labor legislations for the well conduct of the labor class, and the preservation of their rights. The primary objective of action in the ILO is the creation  of the International Labor Standards in the form of Resolutions and Recommendations. Countrywide policies, procedure and help in developing actions.

The basic principles of labour policy of the I.L.O.:-

1.     Labour is not a commodity.

2.     Freedom of expression and of association is essential to continued progress.

3.     Poverty anywhere constitutes a danger to prosperity everywhere.

etc.

Labor Law controls matters, such as, remuneration, labor employment, and conditions of employment, trade unions, industrial and labor management relations. They also include social legislations regulating such characteristics as reimbursement for accident triggered to a worker at work place, maternity benefits fixation of minimum wages, and distribution of the company’s profit of the organization’s workers, etc. Most of these acts regulate rights and the responsibilities of employee.

The Indian Labour Organization tools have provided procedures and useful framework for the development of legislative and administrative procedures for the protection and progression in the interest of labor. To that point the impact of ILO Resolutions as a regular for reference for both labor legislation and practices in India, rather than legally binding norm, has been substantial. Ratification of a Resolution enforces legally binding responsibilities on the nation concerned and, consequently, India has been very careful in ratifying Resolutions. It has always been in the exercise in India that we ratify a Resolution when we are entirely satisfied that these laws and practices are in conformity with the appropriate ILO Resolution. It is now measured that a better course of action is to proceed with India have so far ratified 39 Conventions  of the ILO, which is much better than the position obtaining in many other countries. Even where for special reasons, India may not be in a position to ratify a Convention, India has generally voted in favor of the Conventions reserving its position as far as its future ratification is concerned

Major impact of ILO on Labor legislations in India With the evolution and expansion of small plants, factories and industries in the Indian subcontinent starting in the mid of  the nineteenth century, new possibilities for employment were generated, resulting in a ongoing migration of the labor from poor rural areas to factories and mills located basically in urban areas.

During time, in the lack of any control on organization’s labor by the state, the employers were very less concerned for the need of their workers; wages were very low, very long working hours, and unsatisfactory the employees’ employment conditions. The situation led to the depiction of a large number of labor legislations beginning since the year of 1881.

a)     These labor legislations includes,

b)    The Factories Act 1881,

c)     Workmen’s Compensation Act -1923,

d)    Mines Act 1923,

e)     Trade Unions Act-1926,

f)      Trade Disputes Act -1929,

g)     Payment of Wages Act -1936,

h)    Employment of children act- 1938 and

i)       Maternity Benefit Act in 1939.

The ILO guidelines provided basic principles on which most of labor legislations were drawn. By observation on various amendments and enactments in labor laws it can be easily seen that the ILO have a countless impact on the Indian Labor Laws. A large number of laws were passed to incorporate the guidelines of the resolutions of the ILO.

All these revised and ratified legislations create provisions for the common welfare and protection of importance of the Indian labors. The constructive effect of ILO is seen in form of appreciation of many new kinds of rights that were previously not available for the Indian labor class, but were made available after creation of ILO.

CHAPTER 6

RECENT TRENDS IN LABOUR LAW

The experience in India during the last 50 years has been that the Supreme Court of India, various High Courts, Industrial Tribunals and Labour Court have enriched the country with a variety of precedents of labour demands by their sweat and toil and missionary research from almost a barren and fallow field of labour jurisprudence. They have handed down to the world community jurisprudence, as living as dynamic, as valid as sound, which has redeemed the lost faith of industrial masses in law and justice. Their contribution to the development of labour law and redemption of social values of law and justice, is unparallel in the world history of jurisprudence, far exceeding the contribution made by Equity in England. Adjudication of industrial demands being a complicated task, the Tribunals have to go into the merits of each issue which necessarily means examination, analysis and appreciation of the labour economics, the sociological approach and the relevant technical aspects of every issue. The demands concerning labour problems have often been subjected to expert studies and researches by high powered bodies of International Labour Organization, Indian Labour Conference, Labour Investigation Committees, Wage Boards, Pay Commissions and various Government bodies, etc.
In fact, these Reports and Recommendations have often been adopted by the Supreme Court, High Courts and Industrial Tribunals as guidelines. According to Section 10 of the Industrial Disputes Act 1947, the appropriate government is empowered to refer a dispute to the Tribunal. This power of the appropriate government is independent of the fact whether conciliation proceedings have been held or not. However, in practice, a dispute is referred to the Tribunal/ Labour Court for adjudication by the appropriate government after considering the failure of conciliation report received from the conciliation officer.

6.1. CONSOLIDATION, SIMPLIFICATION AND RATIONALIZATION OF LABOUR LAWS

Codification of labour laws is a desirable long term goal. However, certain practical difficulties may arise in operationalising this. In view of this the Working Group agreed with the suggestion of the Second National Commission on Labour and NCEUS that labour laws should be consolidated in a few cognate groups to reduce multiplicity of laws for better enforcement and more effective compliance. This should also help in moving closer to a uniform labour policy on common issues. The Working Group therefore recommends that labour laws should be clubbed under the following four major cognate groups: -

1.     Laws governing Industrial Relations

·        The Industrial Disputes Act, 1947

·        The Industrial Employment (Standing Orders) Act, 1946.

·        The Trade Unions Act, 1926

An attempt may be made to consolidate the above laws into one law i.e. Industrial Relations Act.

2.     Laws governing Wages

·        The Equal Remuneration Act, 1976

·        The Minimum Wages Act, 1948

·        The Payment of Bonus Act, 1965

·        The Payment of Wages Act, 1936

The above four Acts may be consolidated into one Act i.e. Payment of Wages Act.

3.     Laws governing Social Security

·        The Employees’ State Insurance Act, 1948

·        The Employees’ Provident Funds and Miscellaneous Provisions Act, 1952

·        The Payment of Gratuity Act, 1972

The definition of establishments, eligibility criteria, etc. in the above Acts may be harmonized for purposes of consolidation.

4.     Laws governing Working Conditions & Welfare

·        The Factories Act, 1948

·        The Maternity Benefit Act, 1961

·        The Workmen’s Compensation Act, 1936

·        The Contract Labour (Regulation and Abolition) Act, 1970

·        The Inter-State Migrant Workers(RE&CS) Act, 1979

The above individual Acts will need harmonization of definitions and coverage before they can be consolidated. Simplification and rationalization of labour laws will require examination of labour laws individually. In the process provisions which have outlived their existence may be deleted. If necessary, certain laws may be considered for being repealed. A consensus will have to emerge from the stakeholders regarding this.

6.2. Indian Prime Minister Narendra Modi Launched Key Labour Reforms, Promised Better Work Culture

Prime Minister Narendra Modi unveiled some key labour reforms that rely on trust and promote the ease of doing business on Thursday 16^th October, 2014, and said the measures will go a long way in changing India's work culture, promoting social security and skilling the youth.

The prime minister also unveiled the Shram Suvidha portal, a Labour Inspection Scheme, and also the portability of social security through a Universal Account Number for Employees Provident Fund. He also launched Apprentice Protsahan Yojana of the labour ministry.

These efforts are a great example," said Modi amid applause. "This is Minimum Government, Maximum Governance."

"The Shram Suvidha portal simplifies compliance of 16 labour laws with on online form," he said.

The prime minister added: "E-governance is easy governance. It builds trust for transparency."

On the issue of social security of labour force, the prime minister expressed concern that as much as Rs.27,000 crore was lying unclaimed with the Employees Provident Fund Organisation.

"This money belongs to poor workers of India," he said, adding the portability provided under the Employees Provident Fund through one universal account number will put an end to such large sums of money being locked up and not reaching the intended beneficiary.

The prime minister said the "Shramev Jayate" initiatives were essential elements of the "Make in India" vision, paving the way for skill development of youth in a big way, and creating opportunities for India to meet the global requirement of skilled labour.

He said skilled labour has not been given due dignity in the society and was generally regarded as lower to other forms of work.

"A compassionate approach would result in the Shram Yogi (labourer) becoming a Rashtra Yogi and hence, a Rashtra Nirmaata (nation-builder). There is need to change outlook,"

Referring to apprenticeship encouragement scheme of the labour ministry, he said it will help meet needs of skilled workforce.

Labour ministry officials said the Apprentices Act, 1961, had been enacted to regulate apprenticeship training in the industry.

They said a major initiative has been taken to revamp the existing apprenticeship scheme with the aim of increasing apprenticeship seats to more than 20 lakh in the next few years.

The officials said that information about schemes such as National Old Age Pension Scheme and Aam Aadmi Bima Yojana will be captured in the card issued under the revamped Rashtriya Swasthya Bima Yojna for labour in the unorganized sector.

CHAPTER 7

CONCLUSION

Mahatma Gandhi had once said,

 'A nation may do without its millionaires and without its capitalists, but a nation can never do without its labour'.

Industrialisation creates a number of social and economic problems like employment of women and children, minimum wages, trade unions, insanitary living quarters and deplorable working conditions in the factories, etc.  Labour laws are, therefore, enacted to facilitate their solutions, as ordinary civil laws are inadequate to meet them.  The State has adopted a progressive policy, and is keeping pace with the labour policy of the Government of India and the standard laid down by the International Labour Organisation.  This has produced a plethora of legislation and their administration.  These laws also deal with the regulation of industrial relations between the management and the workers.
But It’s virtually without debate that the Indian labour law regime requires a comprehensive overhaul. Central and state legislations need to be examined in totality to understand how permissions and compliances required can be made as few and as simple as possible, without adversely affecting rights of workers.

1.     There has been consistent decline in real minimum wages.

2.     Growing casualisation and contractrisation of labour and decline in proportion of permanent work force have become order of the day.

3.     There is an urgent need for simplification of labour legislation. This need is two-fold. Firstly, the laws must be drafted in such a way that they can be understood by an ordinary study thereof done by an average man for whom they are meant. Secondly, little is done to remove ambiguous interpretations, phrases and provisions and they are left to be adjudged by the tribunals. As far as possible such ambiguities must be removed and proper legislative clarification incorporated at appropriate places.

4.     Collective bargaining has been accepted as the best method of settlement of industrial disputes but the existing laws do not provide any framework for regulating it. A good number of industrial differences can be alienated by legislative engineering in this field also.

5.     The present plethora of legislation serves s minority of industrial labour. The rural labour, the urban labour in the unorganised sector, the tribal forest and scheduled caste labour have by and large not received much attention. Similarly, the small scale industries, the petty shops, establishments, self-employed sectors also deserve a distinct treatment. Legislative engineering should, therefore, be employed for extending benefits of social justice to these neglected segment of labour and also for protecting the small sectors from the onslaughts of aggressive trade unionism.

While it is desirable to move to a system where workers can be employed on negotiated terms and where the distinction between permanent and contract employees are entirely dissolved, there are three levels of protection that would need to be in place before that happens:

1.     A national legislation on minimum wages and standards, so that under no circumstance can a worker (in a factory, service company, household or tea-shop) be employed at standards inferior to that.

2.     Sanctity for collective bargaining agreements, so that the overwhelmingly superior bargaining position of the employer over individual employees does not lead to exploitative terms of employment; and

3.     Social security measures such as unemployment insurance and retraining facilities, so that loss of employment does not mean that a worker has to starve.

Once a simplified regime incorporating these safeguards comes into effect, the enforcement of these provisions will also be considerably easier and less expensive.

          A comprehensive reading of this short project report reveals that there has been considerable change in the social outlook towards labour legislation in India, and Technological evolutions with active role and support of ILO have also contributed in the simplification of labour legislations to make them more labour-friendly and thereby promoting social justice.

BIBLIOGRAPHY

A.  Books Referred:

a)     An Introduction to Industrial and Labor and Industrial Law, S.K. Puri, 2015, 11^th Edition (Allahabad Law Agency)

b)    Social Security and Labour Law, S.C. Srivastava, 2014(EBC)

c)      

d)    The Constitutional law of India, J.N. Pandey, 2008, 47th Edition

e)     Indian Constitutional law, Prof. M.P. Jain, 2008, 5th Edition

f)      D.D. BASU, Constitutional Law of India, (8th Edn. Vol. 3),

B.   Websites Referred:

a)     mrunal.org/2012/07/economy-social-security-epfo.html

b)    https://www.ssa.gov/policy/docs/ssb/v16n5/v16n5p11.pdf

c)     workspace.unpan.org/sites/internet/documents/unpan92408.pdf

d)    www.legalservicesindia.com/article/article/social-security-826-1.html

e)     ssrn.in

f)      en.wikipedia.org/labourlaw_in_india

g)    academia.edu.in