Reviewed case brief

Sanjit Roy v State of Rajasthan

AIR 1983 SC 328

## Summary

article-23forced-labourminimum-wagesfamine-relief-work
Court
Supreme Court of India
Year
1983
Subjects
Labour Law II
Reviewed
2026-07-20

Rule established

Payment of wages below the statutorily prescribed minimum wage to workers engaged on famine relief or drought relief works amounts to forced labour within the meaning of Article 23 of the Constitution, and cannot be justified merely because the work is offered as relief during a scarcity or emergency; the state cannot use economic distress as a ground to pay less than minimum wages.

Facts

    Issues

      Held

        Ratio decidendi

        How to use it in an exam

        Editorial source

        AIR 1983 SC 328; landmark authority connecting sub-minimum wages to forced labour under Article 23, cross-verify citation before exam use

        Educational summary only. Read the reported judgment or an authorised law report before relying on the case professionally.