The Bandhua Mukti Morcha case is a landmark judgment of the Supreme Court of India, officially cited as Bandhua Mukti Morcha v. Union of India and Others, 1984 AIR 802. The case originated from a letter written on February 25, 1982, by the petitioner, the charitable organization Bandhua Mukti Morcha, to Justice P. N. Bhagwati, detailing the plight of workers in stone quarries in the Faridabad district near Delhi. The letter was treated as a Writ Petition under Article 32 of the Constitution, which significantly liberalized the concept of Public Interest Litigation (PIL) by dismissing the traditional requirement of locus standi for the enforcement of fundamental rights.
The judgment’s ratio is that the right to live with human dignity, free from exploitation, is an inalienable fundamental right implicit in Article 21 (Right to Life and Personal Liberty) and Article 23 (Prohibition of Forced Labour). The Court held that the State has an affirmative constitutional obligation to ensure the effective implementation of the Bonded Labour System (Abolition) Act, 1976, which was enacted to give effect to Article 23. The Court established a mechanism where, whenever forced labour is alleged, there is a prima facie presumption that the labour is bonded labour for financial gain, shifting the burden of proof away from the vulnerable workers. To solve the problem of non-implementation, the Court issued 21 directives to the Central and State Governments for the identification, release, and rehabilitation of bonded labourers. The case connects directly to the Bonded Labour System (Abolition) Act, 1976, and other labour welfare laws like the Minimum Wages Act, 1948. The foundational principles of the judgment remain unchanged, continuing to guide the state's duty towards the eradication of bonded labour.