Ms. P. MEGHNA,
Army Law College, Pune
Ms. VAISHNAVI SARAVANAN,
Army Law College, Pune
Migration for work can be traced back to as old as the medieval period, an era characterised by political, economical and social migration. Ever since, millions of people across India have migrated for work to far of lands to earn and prosper. However, the ongoing pandemic of COVID-19 has caught these migrant workers in a spot of trouble not just medically but economically. The paper delves into the effects of the lockdown which was imposed to contain the virus but has resulted in creation of a tragic situation for the migrants as they struggle to survive. Covering the effects of lockdown on these migrants, this paper aims to explain the ground realities and their plight as they begin their journey home, back to their villages. The authors also describe the pitfalls in the existing laws governing the migrants and their work and compensations. The current predicament raises questions on the enforcement of the labour laws; whether the laws are sufficient to protect the rights of the labour in the existing conditions? What powers are available with the legislative to aid the workers? Are the measures undertaken by the Governments a mere eyewash? The paper attempts to answer the aforementioned questions in addition to a glimpse of the international standards and a comparative study of response of different nation to similar situation.
Migration refers to the geographical movement of people across boundaries. Coupled with fertility and mortality, migration plays an important role in demographics as people from under developed regions move to regions with higher economic development and opportunities. The history of migration is the history of people’s struggle to survive, prosper, to escape insecurity and poverty, and to move in response to opportunity. Over decades, people have migrated within India (Internal Migration) and also to other countries (Emigration). The census 2011 has indicated a staggering number of 139 million of inter and intra state migration. Most of them are seasonal and unregistered migrants.
India, as the rest of the world has seen many epidemics – Cholera, Smallpox, Plague, and Swine Flu among many. However, nothing like the life threatening pandemic of the novel Coronavirus which emerged in the Wuhan city of China in December 2019. Leading to more than 200,000 deaths across the globe and more than 100,000 infected in India alone, the virus later renamed as COVID-19 by the World Health Organisation (WHO), has left many in a scrounging condition especially the migrant workers. To battle the pandemic, systematic measures were undertaken by the Indian Government by first imposing a Janta curfew on 22nd March 2020 followed by a lockdown. This resulted in closing down of all businesses, manufacturing units, constructions, and public transport leaving nearly 80 million of those 139 million migrants stranded at different places during the lockdown. With uncertain future and lack of basic needs, money and employment, most of the migrant workers demanded travel arrangements from the Government and many started on foot to their villages. Suo moto cases had been taken up by the High Courts and the Supreme Court. The Supreme Court which took cognisance of the misery of the stranded workers, issued notices to the Government to provide shelter, food and travel arrangements for the workers.
This paper is divided into the following parts –
- An overview of the facts regarding the migrant workers’ in the lockdown period,
- The authors shall analyse policies of the Government to deal with the migrant crises,
- The authors shall examine the scope of the existing labour laws, especially in a healthcare calamity such as the current pandemic.
- The authors shall draw a comparison with the response of United States of America by reflecting upon its new CARES Act and its benefits
2. THE INDIAN STORYLINE
Before we explore and examine the prevalent laws, it is essential to list out the details of the incidents which have led to this crossover. The migrant numbers mentioned by the finance minister, Nirmala Sitharaman is 80 million who are fragmented across the country. While wondering how this was arrived at, one cannot help but take into account the background and the different reasons these people migrated. There are several of them who belong to the educated population who had moved in for work in the offices of large companies but there are many who had moved for shorter durations as seasonal migrant workers. Although, the educated lot had successfully returned or had a shelter in the place of migration, the seasonal migrants with the abrupt loss of employment and lack of any savings in addition to no mode of transportation available to head back to their villages fell deeper into the trench of uncertainty and hopelessness. They are often those poor who reached the cities in search of odd jobs and ended up working in the factories, at construction sites, as domestic help etc. Most of them dwelled in slums or factories’ dormitories which have been shut down owing to the lockdown. This aggravated the misery of the workers. According to CMIE, 122 million people have been rendered jobless with 23.98% unemployment rate as on 27th May 2020. Hundreds and thousands of migrants had taken to road to protest, demanding aid and assistance from the Government authorities. Despite the virus looming over their heads, the workers experienced and expressed a different fear altogether. Their fear of death due to starvation and unhygienic conditions outweighed that of the virus. They continued to build pressure over the Governments which resulted in Shramik trains but many were left out as there was no record of their numbers. The Governments struggled to count them amidst the distress which led to millions walking for thousands of kilometres covering the length and breadth of this country to reach their homes.
Another important event that occurred during the same time is the pressure from those Indians who got stranded in foreign countries without any help and were desperation to come ‘home’. Although akin to the condition of the migrants in India but the situation was highly dissimilar. It is interesting to see how the Government has responded to these and assisted both kinds of migrants – through Shramik trains within India and Vande Bharat Mission and Samudra Setu Operation for those outside.
3. THE JANUS FACED POLICIES: ANALYSING THE RELIEF PACKAGE
As the nation faced its worst ever migrant crisis, the Union and the State Governments gave out their relief package to all effected by the virus and the subsequent lockdown. The finance minister listed the package given by the Union Government in five trances. Giving out the relief package to the migrants, farmers and the poor of this nation, the Union Government promised 5 kilograms (kg) per person and 1 kg chana per family for two months; an affordable rented accommodation under PM Awas Yojana; one ration card applicable throughout the country; creation of job opportunities under Compensatory Afforestation Management & Planning Authority (CAMPA); registration of workers under EPF among few in addition to the transport availability to reach their villages. In addition to the Central Government schemes, the State Governments have provide relief –
- Rajasthan announced its skill development programme
- Tamil Nadu assured a Rs 20,000 per month paying jobs and benefits
- Karnataka announced assistance by proving ration kits
Under the Pradhan Mantri Garib Kalyan Package which is a part of the Taxation laws (Second Amendment) Act, 2016 and PM Garib Ann Yojana, has come to rescue of the Union Government which has focused on feeding the poor by providing food grains to nearly 80 crore individuals that is almost two thirds of the total population who are under BPL and survive on daily wages such as migrant labourers, rural and urban poor for free of cost for the next 3 months. By removing the requirement to show the ration cards or ID proof for availing this scheme, it looks like the Central Government is taking the right measures to ensure no poor goes hungry. It also articulated that the poor and migrant workers are their responsibility. Not having to provide ration cards is a commendable step taken by the Government because according to PDS Control (Order) 2001 only ration cards holders can get ration from any fair price shops at their registered state. But as mentioned above that there are about 80 million migrants and most of them stranded in foreign states without possessing ration cards are in trouble and solely depend on daily wages for food. So this scheme becomes their only hope to save them from starvation.
Despite announcing the much needed relief schemes, the Government has failed to help the migrants in the present. Since most of them are future oriented, they have failed in its essence which was to aid the migrants today as they neither have money nor food. Although, the relief is a systematic and well thought plan in the long run, it is an unsuccessful package which does not abate the pain and distress of the workers immediately.
The PM Awas Yojana also known as “Housing for all by 2022” was started in 2015 for urban poor sector and in 2016 for the gramin sector. The only objective of PMAY was that every Indian should posses their own house by 2022 as a mark of Mahatma Gandhi’s 150th Birth Anniversary. The promise of housing availability to the migrant is nothing new but a mere reference to the existing one. Moreover, since the aim was 2022, the number is of less than the number of migrants and their availability shall be made over a longer time frame. There is a demand for 1.12 crore houses in urban and 2 crore 95 lakh in gramin sector with only 87 lakh houses completed with about 1.7 million homeless which means that the workers on the street who have no shelter and their suffering will continue in the heat of the harsh summer.
There are arguments favouring the announcement regarding the grain distribution. But on the flip side, mere grains distribution is not sufficient. A migrant family needs much more than that. To address the immediate woes of the workers and their families, a simpler technique of money transfer and distribution would have helped. For instance, there are certain workers who do have food to last them some days but have no money to avail transport to reach their native faster. What use would it be to give them grains when money was the answer to their agony?
The expectation from the Governments was much higher than what has been received. The workers are out of any work. Therefore, the promise of higher recruitment in the MGNREGA and CAMPA schemes gave some relief and respite. However, neither of these schemes is new. Mere increase of job availability through which the earning is pittance is not enough to support the families of the migrant workers. Furthermore, in her address, the finance minister stated that the new scheme will provide jobs to 30 million workers. But as aforementioned, the migrant numbers are more than double (80 million) which leaves the majority of the workers unemployed. As most of the relief is ‘in kind’, the purpose of the relief is not met leaving the migrants to struggle to survive.
4. ADDRESSING THE PITFALLS OF THE LABOUR LAWS
It is crucial to list the inherent pitfalls that the law poses and discuss the effects of the constraints in the laws. Article 19(1) (g) of the Indian Constitution protects the right “to practice any profession or carry out any occupation, trade, or business.” The Article 16(2), a fundamental right, prohibits discrimination on the grounds of race, caste, gender, place of birth, religion for employment and the Directive Principles of State Policies (DPSP), Article 39 guarantees the right to means of livelihood.
The Epidemic Diseases Act, 1897
The Act came into existence in the colonial period when the bubonic plague broke out in Bombay. The Act has hence been used during the H1N1 influenza, commonly called the swine flu outbreak among other epidemics the country has faced. It was amended through an ordinance on 22, April, 2020. The Act prior to the amendment covered the extent of the applicability of the Act in the country, the requisites to contain any such epidemics, the powers of the Central Government to take measures and regulations to prevent and contain the epidemic, if the laws prove to be insufficient, the penalty for disobeying of the rules and regulations constituted under Section 188 of the Indian Penal Code, and that filing of any suit against any action taken with bona fide intention shall not be entertained. The amended version covers more area with respect to any violence against any healthcare service personnel by defining the terns ‘act of violence’, ‘healthcare personnel’, ‘property’ and the penalty for such acts. It was a much needed amendment which came promptly after such violence was seen in parts of the country. While it is a praiseworthy step, the ordinance could have added a few more clauses in the Act pertaining to the human rights of many. The Act does not consider the resulting aspects of the epidemics. The Act which was formulated on 4, February, 1897 did not take into account the greater levels of migration which have occurred in the past few decades. Hence, there is no inclusion of the regulatory mechanism to deal with the repercussions of the epidemic. Although, the non inclusion can be justified by the dependency on the Inter-State Migrant Act, 1979, neither of the Acts provides solutions to current migrant crisis. This makes the Act insufficient and ineffective, some even calling it a “century-old blunt act.” The archaic Act entrusts the Government to make the rules and regulations whenever required, and leaves superfluous power with the Government which can be rather capricious in handling and respond differently each time. What we require is an established, strong and durable law which can be looked up to when such a crisis arises.
The Disaster Management Act, 2005
To fight COVID-19, the Government relied on the Disaster Management Act which was enacted on 23 December 2005. The Act has been used for the first time since its inception. The Central Government declared the virus as a natural disaster which gave the Central, State and District authorities’ power to give directions to contain the pandemic. Under the Section (10) (1) the Government issued a lockdown restricting movement on 27 March 2020. It further issued a notice on 29 March condemning the migrant movement for “violating the lockdown measures”. The Act was designed to aid disasters such as earthquake, floods, explosions or gas leaks with a wide ambit to provide relief to the effected and mitigate the effects. However, whether it can be used to deal with the pandemic is unclear. The pandemic in itself had a grave impact but the measures (lockdown) undertaken under this Act have proven to be a greater subject of distress to the migrants. The Act provides for relief to the effected from the disaster itself but does not cover the others such as the migrants. The migrant crisis can however be considered as an effect of the disaster in which case gives the Governments the power to take the appropriate action to help the tormented, and helpless migrant workers, the Act failing in its implementation. The Sections 71, 72 and 73 state –
- Bar of jurisdiction of court.—No court (except the Supreme Court or a High Court) shall have jurisdiction to entertain any suit or proceeding in respect of anything done, action taken, orders made, direction, instruction or guidelines issued by the Central Government, National Authority, State Government, State Authority or District Authority in pursuance of any power conferred by, or in relation to its functions, by this Act.
- Act to have overriding effect.—The provisions of this Act, shall have effect, notwithstanding anything inconsistent therewith contained in any other law for the time being in force or in any instrument having effect by virtue of any law other than this Act.
- Action taken in good faith.—No suit or prosecution or other proceeding shall lie in any court against the Central Government or the National Authority or the State Government or the State Authority or the District Authority or local authority or any officer or employee of the Central Government or the National Authority or the State Government or the State Authority or the District Authority or local authority or any person working for on behalf of such Government or authority in respect of any work done or purported to have been done or intended to be done in good faith by such authority or Government or such officer or employee or such person under the provisions of this Act or the rules or regulations made there under.
The aforementioned provisions make it extremely difficult for a migrant worker who is suffering from financial setback and falling into further poverty access legal recourse for justice. The Act also gives all encompassing power to the Government bodies which had ignored the suffering of the migrant workers.
Inter-State Migrant Workers Act, 1979
The interstate migrants are governed by the Inter-State Migrant Workers Act, 1979. Prior to the introduction of this Act, the State of Orissa became the first to recognise the extremity of the harsh conditions of the migrant workers (called Dadan) from Orissa who have migrated to other states and pass the Orissa Dadan Labour (Control and Regulation) Act, 1975. Post this, the Central Government took up the issue and through a committee recommendation, passed the Inter-State migrant workmen (Regulation of Employment and conditions of Service) Act, 1979. One of the major drawbacks that are Act suffers with is it applies to only those establishments with five or more interstate migrant workers as stated in Section 1, sub-section 4, clause (a) of the Act. The relief and the protection the Act offers is not applicable to those working in an establishment with lesser numbers. This leaves a chunk of the migrant population at the mercy of the contractors who may or may not take cognisance of their plight. While the Act itself focuses on the organised sector, the unorganised/informal sector is left out of the governance. According to Economic Survey of India, 90% population depends on informal sector for employment which leaves only a part of the 10% workforce governed by the Act. Further, it also excludes those migrants who work individually, therefore, failing to protect the unregistered migrants. Another area where the law fails is to state the rules and regulations in case of such epidemics and disasters. The lack of foresight and initiative from the Union Governments over decades despite several epidemics and disasters has resulted in the current migrant crisis with nearly no legal solution available as yet except any guidelines issued by the Governments or orders and rulings of the Apex Court.
Although, this Act states that the journey allowance to the worker’s native has to be borne by the contractor, such payments have not been made. Despite mentioning explicitly that all the workers are required to be paid wages in accordance with the Minimum Wages Act, 1948, the 89% of the migrants continue to starve without receiving their wages from their employers and less than 5% of these migrants were enrolled. In spite of having a statute in place, the recent hardships which the migrant labourers confronted, our law and correspondingly the legal system failed these voiceless citizens due to ineffective implementation and insufficient enactment.
The Contract Labour (Regulation and Abolition) Act, 1970
The contract labourers in India constitute a staggering 46% in the industry. These labourers are governed by The Contract Labour (Regulation and Abolition) Act, 1970 which aims to regulate employment of these workers and abolish their exploitation. The Act is applicable to any establishment which has more than twenty contract workers making the Act cover most of the companies, especially the big and medium sized. However, for those companies with less than twenty, with even nineteen contract workers the applicability ceases. Section 1, sub section (5) states that –
(5) (a) It shall not apply to establishments in which work only of an intermittent or casual nature is performed.
Explanation.– For the purpose of this sub-section, work performed in an establishment shall not be deemed to be of an intermittent nature—
- if it was performed for more than one hundred and twenty days in the preceding twelve months, or
- if it is of a seasonal character and is performed for more than sixty days in a year.
In such cases, wherein the work duration is less than the aforementioned, even if it is a contractual labour, he/she shall not be eligible for the benefits arising out of the Act. The Act provides for guaranteed amenities and payment of wages for the labour to be given by the contractor. But, if the contractor fails to do so, the principle employer will become responsible for it. Although, the Act seems to cover for any non-performance by the contractor, during the COVID – 19, the lack of revenues for both has resulted in non payment of the wages, which combined with conflicting responsibilities and interests of the contractor and the principle employer has led to confusion and non execution of obligations by the contractor and principle employer leaving the contractual migrant workers helpless. In Maharashtra General Kamgar Union v. Cipla Ltd, the Court held that any complaint filed against the principle employer for unfair labour practices by stating that he was in fact the employer shall not be maintainable.
If in any case, the principle employer becomes the provider of amenities and payment of wages by virtue of valid contract between the contractor and the principle employer or due to lack of performance by the contractor and the principle employer has either terminated the contract worker or has not given the wages or amenities, the migrant contract labour is left with no option but to suffer in silence as has happened in the crisis.
However, the major hiccup is the lack of implementation and inability to achieve its objective so far. Even through the Act was passed in the year 1970, many migrant workers are not provided with accommodation or safety measures as provided by the Act. It is reported that many sleep on the factory floor. It is highly distressing that in spite of the Act in place, a large population is still exploited and endure such excruciation.
The Minimum Wages Act, 1948
The Act which came into existence before the constitution immediately after independence aims to regulate the wages of the workers and to protect them from the unmerciful employers. The Act was promulgated to guarantee minimum wages in order to maintain the basic standard of living especially of the lower strata of the population. Despite the existence of the Act, many workers have not been paid for months. This is a huge failure on the part of the implementation of the Act albeit ensuring a bare minimum pay under normal circumstances. Like all other laws in India, this also faces the same problem of not covering the unnatural circumstances.
Unorganised Sector Social Security Act, 2008
The Unorganised Workers’ Social Security Bill was introduced in 2007 to streamline all the existing schemes introduced by the Government for the unorganised sector and was later referred to the Parliamentary Standing Committee on Labour. It was enacted on May, 14, 2008. It allows the Government to formulate various schemes for the welfare of the unorganised workers. It also provides for constitution of National Social Security Board and the State Social Security Board to recommend, administer and monitor the various social security schemes. Despite enacting the Act with bona fide intentions, the Act doesn’t define the term ‘social security’ leaving high levels of ambiguity in application if the law. The obscurity has lead to different interpretations of the term. The social security required by the migrant workers is monetary assistance in order to access the basic requirements to survive but whether such assistance is covered in the definition is unknown and the vague conclusions drawn are based on loose interpretations. Another major defect the Act suffers from is the non availability of a judicial recourse in case of any violations, an impediment for the workers.
The Code on Social Security Bill, 2019 was tabled in Lok Sabha which streamlining the existing Acts into a single code and establishing a fund which shall be the corpus for the pensions, medical cover provided, disability benefits. It also aims to reduce the PF contribution. This code would have proven to be helpful in claiming the much needed financial aid by the workers. Unfortunately, the bill has not been passed yet.
5. POSITION OF ILO AND THE USA IN DEALING WITH THE MIGRANT CRISIS
International Labour Organisation (ILO)
Before the advent of federalism, there was no relationship between servant and master. Max Webber’s popular protestant ethics which focuses on performing one’s duty and hard work forged a relationship between feudal lords and slaves. After the industrial revolution in England had begun the factory system, which led to exploitation of labourers by making them work in inhumane working conditions with no rest. Workers conditions were dreadful which even included children working in mines. These circumstances resulted in Mines Act which prohibited children working in mines. It aggravated workers and led to multiple riots all over, so the transformation from Laissez-Faire to Welfare State resulted in trade unions, better working conditions for labourers. International Movement in 1836 from England to Brussels addressing injustice against labourers resulted in the formation of International Labour Organization (ILO) which safeguarded labourers from exploitation. For creation of secured employment and to increase standard of living all nations throughout adopted more than 70 ILO conventions.
In accordance with the Termination of Employment Convention, 1982, ILO provides for the unemployment benefits that can be availed as a consequence to the unemployment cause due to the pandemic. A similar social security benefit is given for under the Social Security (Minimum Standards) Convention, 1952 which needs to be followed. Further protection in terms of wage payment is given under the Protection of Wages Convention, 1949 which also provides for settlement payment in case a person is terminated.
The specific regulations given by the ILO state (under The Migrant Workers Recommendation, 1975) that –
- The migrant workers’ health should be taken care of as well as their families.
- They must be given social security throughout the time period
- The Government must bore the cost of return of the migrant and their families in case the migrant faces expulsion and returns to his native
The United States of America (US) has been the virus hotspot for a very long time reporting 1,793,530 cases. In US, there are millions of undocumented or illegal immigrants who form a major part of the labour force. The Pew Research Centre reported a hundreds and thousands of Mexicans the largest immigration into US, forming 50% of the undocumented migrants among the total 10 million illegal immigrants. Along with many of these migrants, 36 million Americans have sought for unemployment aid. To aid the unemployed, the US Department of Labor has depended on the State Unemployment Solvency Trust Fund which helps the unemployed workers of US. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) was passed on 27 March 2020 with $2 trillion. The Act provides for direct payments of $1200 to individuals and $2500 for married couples who are in the lower income strata of the society and adjusted incomes. Additional benefits are provided to them in access of insurance, tax benefits, increased paid leave, skill development programmes and other services. It also provides for $600 compensation for unemployment due to the pandemic. The existing Fair Labor Standard Act does not include provisions for such large mass unemployment which maybe temporary in nature. This more specific Act shall not only regulate the aid in this pandemic but will be relied upon in future.
In spite of facing similar adverse conditions and probably less severe, India has unable to come to the public rescue like the US has by enacting the CARES Act. The Act which will benefit thousands of unemployed people in the US should have been taken as an example by the Indian Government instead on relying upon the existing old laws which provide no legal framework to fall back on.
6. SUGGESTIONS AND CONCLUDING REMARKS
In the light of what is stated above, the authors have observed that the country suffers from paucity in foresight and forethought in law and policy formation. COVID-19 is a health emergency with a massive magnitude of economic loss causing a humanitarian crisis. A crisis which seems India is not yet ready for. The migrants, who are the drivers of India’s economy, endure agony in silence. As the country moves forward, they are the forgotten and fade away and seem to be only remembered either during such crisis. As easy it may be to more forward without giving much thought, lakh of people migrate from rural areas to the urban everyday for a better life but are met with only empty dreams, harsh circumstances and extreme exploitation.
In order to prevent reoccurrence of similar crisis, certain steps have to be taken. While the public and famous influencing personalities have taken it upon their shoulders to support the migrants and help them reach their native, the government needs to devise newer and more comprehensive plans, policies and laws protecting the interests of migrant workforce. What is also required is a complete reformation in the existing laws with that of more specific ones with a larger scope and without murky provisions. Keeping all the shortcomings in mind, the authors propose few recommendations –
- The register for the entire migrant workforce along with all their details should be made and kept updated. The provision for the same has been provided under the Inter-state Migrant Workers Act, 1979.
- Based on the database then available, a Guaranteed Minimum Income or Universal Basic Income program should be carried out and given to all those who earning is less than the prescribed minimum earning, specially the migrant workers who earn less than the prescribed minimum earning.
- In addition to that a self-declaration approach to access the benefits should be taken and provision for the same should be made.
- Currently most of the benefits are given on the basis of the ration cards which are separately registered in different states. Speeding up the process of unifying them and providing with one ration card applicable in the entire country (One nation one ration card) is necessary.
- All the benefits henceforth should be directly given to the beneficiaries without depending on the intermediaries. A mechanism for the same should be developed. For example, in the current case, direct transfer of money to the Jan Dhan accounts.
- Although, a cumbersome task, a unified code for governing of all migrants – the daily wage workers, seasonal workers, contractual workers should be created.
- The Epidemic Act requires major amends to be able to deal with pandemics and similar situations in the future. Provisions for dealing with related humanitarian loss and crisis such as the migrant crisis should be added to it.
- A newer and a more flexible relief plan should be in place which only needs minor amends to fit to the situations as they arise and can be implemented immediately.
- The access to justice system must be made easier for the public and especially for the poor, migrants workers.
It is essential to unite as a country and address the pitfalls. Many provisions and statutes are available for legal and social protection and recourse. But as every nation must, India also needs to keep evolving and learning from the past mistakes and ensure relevant and futuristic laws are there. Such crisis must always be dealt with sensitivity. Initiatives discussed in this paper do suffer from certain setbacks, but fixing them and implementing them will benefit as a whole. It is not just the policy makers but also the implementers, the citizens of this country that shall make a difference and lead the nation to a higher pedestal and create a more welcoming, socially and economically secure place of these workers to break free from the shackles of helplessness and hopelessness. As it is said, we can’t help everyone, but everyone can help someone. Therefore, the government and the people must take charge to create a better and safer tomorrow.
See also https://www.weforum.org/agenda/2017/10/india-has-139-million-internal-migrants-we-must-not-forget-them/
 See In Re: Problems And Miseries Of Migrant Labourers v. For on 26th May 2020,
 Zia Haq, World Bank to fund $1bn for mobile safety nets for Covid-19 hit migrants in India, Hindustan Times, https://www.hindustantimes.com/india-news/world-bank-to-fund-1bn-for-mobile-safety-nets-for-covid-19-hit-migrants-in-india/story-zkurNHI2rqyZ8aVElOSQIP.html
 https://unemploymentinindia.cmie.com/. See also Anirban Nag, India’s Jobless Rate Jumps to 27.1%, Survey says, Bloomberg, (May, 5, 2020) https://www.bloomberg.com/news/articles/2020-05-05/india-s-jobless-rate-jumps-to-27-1-as-lockdown-hurts-cmie-says
 Nikunj Ohri, Nirmala Sitharaman Announces Measures For Farmers, Migrant Workers, Bloomberg/Quint, (May, 15, 2020), https://www.bloombergquint.com/coronavirus-outbreak/nirmala-sitharaman-announces-measures-for-farmers-migrant-workers
 Kundan Pandey, COVID-19: Is govt’s Rs 20 lakh crore stimulus a relief or more stress, DownToEarth, (May, 20, 2020), https://www.downtoearth.org.in/blog/economy/covid-19-is-govt-s-rs-20-lakh-crore-stimulus-a-relief-or-more-stress-71246
 The Law Library of Congress, Legal Responses to Health Emergencies, https://www.loc.gov/law/help/reports/pdf/2015-011358%20FINAL%20RPT.pdf
 The Epidemic Diseases Act, 1897 See The Epidemic Diseases (Amendment) Ordinance, 2020
 The Law Library of Congress, Legal Responses to Health Emergencies, https://www.loc.gov/law/help/reports/pdf/2015-011358%20FINAL%20RPT.pdf
 Yogima Seth Sharma, National database of workers in informal sector in the works, The Economic Times, Jan,
 Stranded Workers Action Network (SWAN), 21 Days and Counting: COVID-19 Lockdown, Migrant Workers, and the Inadequacy of Welfare Measures in India, (April, 15, 2020)
 Ravi Ananthanarayanan, Contract workers make up 46% of workforce of India’s largest industrial companies, Live Mint, (March, 19, 2014) https://www.livemint.com/Money/zSFof4LqBrTfX3dxvp8Y2I/Contract-workers-make-up-46-of-workforce-of-Indias-largest.html
 Maharashtra General Kamgar Union v. Cipla Ltd, (1996) 98 BOMLR 727
 Jeet Singh, A Review of Unorganised Workers’ Social Security Act, 2008, RGICS, (Jan, 1, 2018), https://www.rgics.org/wp-content/uploads/policy-issue-briefs/Issue-Brief-Unorganised-Workers-Social-Security-Act-A-Review.pdf
 ILO, https://www.ilo.org/global/standards/WCMS_739937/lang–en/index.htm
 What’s the State of illegal immigration in US?, BBC NEWS, (July, 7, 2019), https://www.bbc.com/news/world-us-canada-48629658