Page |1

A PROJECT ON
FIXATION OF MINIMUM WAGE UNDER THE MIMIMUM WAGES
ACT, 1948

Submitted by:
Nikita Ganesh
15040142014
BBA LLB- A
2015-2020

Prof. Gyanashree Dutta

Alliance School of Law

Alliance University, Bangalore
05th April, 2019
 Page |2

ABSTRACT

The workmen in the unorganized sector in India forms up to 92 percent of the total workmen.
They do not have any job assurance, social and employment security. For their protection the
government of India enacted the Minimum Wages Act, 1948. It is one of the earliest labour
legislations, and was enacted immediately after India attained Independence. The act is legally
non-binding, but statutory in nature. The main objective of the act was to provide a minimum
wage to the workers in unorganized sector to protect them from exploitation from their
employers. The act provides provisions for the procedure of fixation of minimum wage. Even
after the implementation of the act, the workers from these informal sectors are still exploited
and are under paid, leading them to poverty. This is because there are several loop holes in the
statute and drawbacks that hinders in attaining the objective of the act.

This paper will take into account the efforts taken by the government in fixation of a minimum
wage and analyze whether or not they are effective in nature. It will also study why even after
the implementation of the act, many workers in the unorganized sector are still not paid the
minimum wage which leads them below the poverty line. This will help in bringing out the real
impact of the act and the issues raised on the effectiveness of the same.

KEY WORDS- minimum wage, appropriate government, average daily wages

 Page |3

INDEX OF AUTHORITIES

CHAPTER-1 Pg.4-7
1.1 Introduction Pg.4
1.2 Research Problem Pg.6
1.3 Literature Review Pg.6
1.4 Scope and Objective Pg.6
1.5 Research Methodology Pg.7
CHAPTER-2 (FIXATION OF WAGES) Pg. 8-11.
2.1 General Scheme of Minimum Wages Act Pg.8
2.2 Fixation of Minimum Rates of Wages Pg.8
2.3 Procedure for Fixing Wages Pg.11

CHAPTER-3 (PRINCIPES APPLIED IN Pg. 12-13

FIXATION OF WAGE)
CHAPTER-4 (ISSUES AND CONCERNS Pg. 14-15
REGARDING FIXATION OF WAGES)
4.1 Norms of Fixation Pg.14
4.2 Coverage Pg.15
4.3 Implementation Pg.15
CHAPTER-5 (JUDICIAL RESPONSE) Pg.16-17
CONCLUSION Pg. 18-19
BIBLIOGRAPHY Pg. 20-21
 Page |4

CHAPTER-1

1.1 INTRODUCTION

The Indian economy is characterized by dualism that is the existence of a well organized sector
along with a decentralized sector with a large population that is self employed. According to the
NSSO1 Employment- Unemployment survey of 2017-2018, 922 percent of the total workmen
are informal workers. These workers contribute more than 60 percent of India’s GDP growth.

The workmen in the unorganized sector do not have any job assurance, social security and
employment security. In order to address this issue, the government of India has been focusing
on a strategy in terms of skill development, social protection and labour reforms including
stricter enforcement of the Minimum Wages Act, 1948.3

The Minimum Wages Act, 1948 derives its importance from Article 23 enshrined in the
Directive Principle of State Policy of the Constitution which says that the state shall endeavor to
secure all workmen and ensure decent standard of life.4 Further, Article 39 of the Constitution
also reinforces that the state shall make policy that both men and women shall have equal rights
of livelihood and there shall be equal pay for equal work for both men and women.

Minimum wages legislation is the main labour legislation for the workers in the unorganized
sector. In India, the policy on fixing minimum wage in sweating employments and to promote a
fair wage agreement is enumerated in the Minimum Wages Act, 1948. This is because the labour
in the unorganized sector are vulnerable to exploitation due to illiteracy and do not have effective
bargaining power and the intervention of the government becomes necessary.

1
NSSO- National Sample Survey Office
2
Government of India, Ministry of Statistics and Programme Implementation ‘Labour and Employment- Statistical
Year Book India 2018’ < http://mospi.nic.in/statistical-year-book-india/2018/201 > accessed on 1 April, 2019
3
Ms. A. Srija, ‘Implementation of Minimum Wages Act, 1948’(2014) Global Journal oh Human Social Science:
Political Science,
http://niti.gov.in/writereaddata/files/document_publication/Publication%20in%20Global%20Journal.pdf, accessed
on April 1, 2019
4
The Constitution of India, Art. 23
 Page |5

The question therefore arises as to how the above mentioned articles are implemented through
the prism of the Minimum Wages Act, 1948 in the context of fixation of Minimum Wage The
Minimum Wages Act, 1948 provides for the fixation of minimum wages to prevent exploitation
of labour through payment of low wages. The Act requires the appropriate government to fix
minimum rates of wage5 and to review and revise the minimum rates of wages at intervals not
exceeding five years.6

The minimum wage rate be fixed at a) time rate, b) piece rate, c) guaranteed time rate and d)
overtime.7 The Act provides that different minimum wage rate may be fixed for a) different
scheduled employments, b) different work in same employment, c) adult, adolescent and
children, d) different locations or e) male and female. Minimum wage may be also be fixed by
a)an hour, b)day, c) month, or d) any other period as may be prescribed by the notified
authority.8

However the question arises as to the implementation of the said act and the issue and concerns
in relation to the fixation of wages under the Minimum Wages Act, 1948. The Minimum Wages
Act does not provide any stipulated criteria for fixing the minimum wage.

The Minimum wages are expected to cover the essential costs of accommodation, food and
clothing of a small family. The Minimum Wages Act, while being very progressive has led to
many specific problems. There are poor norms of fixation, enforcement and implementation of
the act in various parts of the country, because of this there is a need for a meaningful minimum
wage policy.

Taking into consideration the poor norms of fixation of minimum wage, this paper will deal with
the issues and concerns in relation to the fixation of minimum wage under the Act. One of the
reasons this is of grace importance is because, as previously stared, 92 percent of the total
workmen in India belong to the unorganized sector who provide more than 60 percent of India’s
GDP. Taking this into consideration, it is imperative to protect these workers from exploitation.
Despite there being an act to protect them from unfair wages, there are certain loopholes in the
fixation of wages in the act, these issues and concerns will be dealt with in detail in this paper.

5
Minimum Wages Act, 1948,s 3(1)(a)
6
Minimum Wages Act, 1948,s 3(1) (b)
7
Minimum Wages Act, 1948, s 3(2)
8
Minimum Wages Act, 1948, s3(3)(b)
 Page |6

1.2 RESEARCH PROBLEM

The following Research Problem has been identified-

Whether the fixation of wages under the Minimum Wages Act is effective in nature?

1.3 LITERATURE REVIEW

 Ms. A. Srija, ‘Implementation of Minimum Wages Act, 1948’(2014) Global Journal oh

Human Social Science: Political Science - This paper helped in understanding the various
issues concerning the implementation of the Minimum Wages Act, 1948
 ILO Recommendation No. 30 of 1928- The ILO recommendation threw light on the
various problems concerning the fixation of minimum wage and proved various
recommendations to ensure protection of workers of the unorganized sector. This report
helped in understanding what could be done in order to establish a standard principle in
fixation of a minimum wage.

 One Man Committee Report on the Working of the Minimum Wages Act, 1948, New
Delhi: Government of India, Ministry of Labour (1996) at 266- This report helped in
understanding the various drawbacks of the Minimum Wages Act, 1948 and what can be
done to remove the same for effective implementation. It helped in drawing an effective
conclusion on what can be done to improve implementation of standard rate of wages.
 Mr. Kailas Laxman, ‘Fixation of Minimum Wage’ (2014), Shodhganga- This paper gave
in depth information as to why the fixation of minimum wage is not strictly practices by
the appropriate government. Such information helped in reaching a conclusion as to what
can be done for effective implementation of the same.

1.4 SCOPE AND OBJECTIVE

The scope and objective of this paper will be to analyze the issues and concerns in relation to the
fixation of wages under the Minimum Wages Act, 1948. It will also deal with whether the
fixation of wages under the Minimum Wages Act is effective to protect the workers in the
unorganized sector from being under paid and exploited. For this purpose, the provisions of the
 Page |7

act are studied in detail along with various labour reports and NSSO surveys. Various case laws
are also taken into consideration to analyze the courts perspective on the same issue.

1.5 RESEARCH METHORDOLOGY

This research is a Doctrinal research. Doctrinal research is the theoretical study where mostly
secondary sources of data are used to seek to answer one or two concepts. This research shall
involve referring to role and contribution of banking in women empowerment, several research
publication, data available on internet and various committees in India devoted towards the
women empowerment have been used.
 Page |8

CHAPTER 2

FIXATION OF MINIMUM RATES OF WAGES

2.1 THE GENERAL SCHEME OF MINIMUM WAGES ACT, 1948

The Minimum Wages Act, 1948 aims at making a provision for the statutory fixation of
minimum wage rates in a number of industries in the unorganized sector. The Act required the
Central and State Governments to fix minimum rates of wages payable to employees in the
scheduled employment.9

The object of the Act was dealt with in the Supreme Court in Y.A Marmarde v. Authority under
the Minimum Wages Act10, the court observed that the object of the Act as stated in the preamble
is to provide fixation of minimum wages in certain employments to of ignorant or less organized
members of the society.

There is a provision in the Act for addition of employments to the schedule annexed to the Act.11
The Act also provides for setting up of machinery for the fixation, revision and co-ordination for
the minimum wages.

The Act however, does not prescribe any principle for fixation of the minimum rates of wages. It
only lays down the procedure to lead to a rate, which the scheduled employers must pay.

2.2 FIXATION OF MINIMUM RATES OF WAGES

Section 3 of the Minimum Wages Act, deals with the fixation of wages. Section 3(1) gives power
to the appropriate government to fix the minimum wage payable to the employees employed in
an employment in Part I or Part II of the Schedule and in an employment added to either Part by
notification under Section 27.

9
Minimum Wages Act, 1948 s.5
10
Y.A Marmarde v Authority under the Minimum Wages Act (1972), AIR 1721, 1972 SCR (1) 161
11
Minimum Wages Act, 1948 s. 27
 Page |9

Provided that the appropriate government may in respect of employees employed in an

employment specified in Part II of the Schedule instead of fixing minimum rates of wages under
this clause for the whole State fix such rates for a part of the State or for any specified class or
classes of such employment in the whole State or part thereof.

Section 3(1) a also empowers the appropriate government to review the rates at such intervals
that it deems fit and such intervals should not exceed 5 years.

The constitutional validity of Section 3 was challenged in Bijoy Cotton Mills v. State
of Ajmer12, the Supreme Court held that the restrictions imposed upon the freedom of contract by
the fixation of minimum rate of wages, though they interfere to some extent with freedom of
trade or business guaranteed under Article 19(1)(g) of the Constitution, are not unreasonable and
being imposed and in the interest of general public and with a view to carrying out one of the
Directive Principles of the State Policy as embodied in Article 43 of the Constitution, are
protected by the terms of Clause (6) of Article 9.

Notwithstanding the provisions of Section 3(1)(a), the “appropriate Government” may not fix
minimum rates of wages in respect of any scheduled employment in which less than 1000
employees in the whole State are engaged. But when it comes to its knowledge after a finding
that this number has increased to 1,000 or more in such employment, it shall fix minimum wage
rate.13

Undoubtedly the appropriate government has been given a wide range of powers under this
provision. Often, a majority of the state governments have failed in the revision of the minimum
rates of wages within the interval of five years.14

The Kerala High Court in Association of Planters of Kerala v. State of Kerala15said that

“A failure to fix or revise minimum wages was not only a statutory violation but
is a breach of fundamental right enshrined in Article 23 of the Constitution. A duty is a
cast upon the State by provisions of the Article 23 to fix and revise the minimum rates of

12
Bijoy Cotton Mills v. State of Ajmer (1955), AIR 33, 1955 SCR (1) 725
13
Minimum Wages Act, 1948 S. 3 (1A)
14
Mr. Kailas Laxman, ‘Fixation of Minimum Wage’ (2014), Shodhganga
http://shodhganga.inflibnet.ac.in/bitstream/10603/63042/7/07_chapter%202.pdf, accessed on 2 April, 2019
15
Association of Planters of Kerala v. State of Kerala (1996), (74)FLR 2288
 P a g e | 10

wages. The continuance of rates of wages since seven years, which would be less than the
minimum payable is illegal and the workers are entitled to retrospective fixation or
revision from the date it is due for revision.”

Under section 3(2) of the Act, the appropriate government may fix- a minimum rate if wages for
the time work, piece work, remuneration to apply in the case of employees employed on piece
work for the purpose of securing to such employees a minimum rate of wages on time work
basis, minimum rate to apply in substitution for the minimum rate which would otherwise be
applicable in respect of overtime work done by employees.

Section 3(3) provides that different minimum rates of wages may be fixed for –

1. different scheduled employments;

2. different classes of work in the same scheduled employments;

3. adults, adolescents, children and apprentices;

4. different localities

Further, minimum rates of wages may be fixed by any one or more of the following wage
periods, namely:

1. by the hour,

2. by the day,

3. by the month, or

4. by such other large wage periods as may be prescribed; and where such rates are fixed by
the day or by the month, the manner of calculating wages for a month or for a day as the
case may be, may be indicated. However, where wage period has been fixed in
accordance with the Payment of Wages Act, 1986 vide Section 4 thereof, minimum
wages shall be fixed in accordance therewith.
 P a g e | 11

2.3 PROCEDURE FOR FIXING MINIMUM WAGE

The Act under Section 5 provides two methods for fixing the minimum rates of wages in respect
of any scheduled employment.

Under the first method, the Appropriate Government may appoint as many committees and
subcommittees necessary to hold enquiries and to advice it in respect of the fixation of wages or
revision of the same.16

It was held in Edward Mills Co. v. State of Ajmer17 that Committee appointed under Section 5 is
only an advisory body and that Government is not bound to accept its recommendations.

When fixing minimum wages under Section 5(1)(b), the appropriate Government shall by
notification, in the Official Gazette publish its proposals for the information of persons likely to
be affected thereby and specify a date not less than 2 months from the date of notification, on
which the proposals will be taken into consideration.

The representations received will be considered by the appropriate Government. It will also
consult the Advisory Board constituted under Section 7 and thereafter fix or revise the minimum
rates of wages by notification in the
Official Gazette. The new wage rates shall come into force from such date as may be specified in
the notification.

However, if no date is specified, the notification shall come into force on expiry of three months
from the date of its issue. Minimum wage rates can be revised with retrospective effect.18

16
Minimum Wages Act, 1948 S. 5(1)(a)
17
Edward Mills Co. v. State of Ajmer (1955) AIR 25, SCR (1) 735
18
Shubhi Pandey , ‘Fixation of Minimum Wage under Minimum Wages Act’ https://www.legalbites.in/law-notes-
labour-law-minimum-wages-fixation-procedure-minimum-wages-act-1948/ accessed 3nd April 2019
 P a g e | 12

CHAPTER 3

PRINCIPLES OR CRITRIA APPLIED TO FIXATION OF MINIMUM WAGES

The minimum wages act does not contain any principles, criteria or norms to be followed in the
fixation of minimum wage rates. Each enquiry committee appointed under this act is this free to
choose the principles or standards it will follow.

The ILO Recommendation No. 30 (1928) concerning the Application of Minimum Wage- Fixing
Machinery throws some light on this issue. It provides that the wage-fixing authority should
“take into account the necessity of enabling the workers concerned to maintain a suitable
standard of living.”19

The ILO Convention No. 131 of 1970 concerning minimum wage fixing with special reference
to developing countries provide elements that are to be taken into consideration in determining
the level of minimum wage. They are- (a) the needs of workers and their families, taking into
account the general level of wages in the country, cost of living, security benefits and (b)
economic factors, including the requirements of economic development, levels of productivity.20

However the practice followed by the enquiry committees appointed under the At has no been
consistent with this.

The first Committee to go into the investigation of the criteria followed by the enquiry
committees was the one man committee appointed by the Government of India to study the
working of the Minimum Wages Act in 1996. In the report of the said committee, it has pointed
out the extremely low rates of minimum wages fixed in certain employments of certain states.
“These rates cannot be considered by any standards to be just or fair.”21

19
ILO Recommendation No. 30 of 1928, Article III
20
ILO Convention No. 131, 1970, Article III
21
One Man Committee Report on the Working of the Minimum Wages Act, 1948, New Delhi: Government of
India, Ministry of Labour (1996) at 266.
 P a g e | 13

There was a change in the attitude of the enquiry committees appointed under the Act with
regards to fixation of minimum wages can be found in the later 1980’s.22 The sub- committee of
the Parliamentary Consultative Committee for the Ministry of Labour (Gurudas Das Gupta
Committee) in its Report (1988) on the problems of the unorganized workers in agriculture
sector noted that the West Bengal Government foxed minimum wages on the assumptions of-
(a) Consumption of food equivalent of 2200 calories per unit per day
(b) 3 adult consumption units in a family
(c) consumption of 72 yards of clothing a year per family
(d) an amount equivalent to 25% to cover housing, fuel, light and education expenses

The sub- committee felt that minimum wages should be liked to the movement in Consumer
Price Index Number of cost of living element and also revised every 2 years or on a raise of 50
points in the Consumer Price Index.23

It can therefore be said that the only relevant consideration for fixing the minimum rates of
wages is the minimal requirement of the workers and his family. The main objective of the act
should be securing the sustenance wage to the workmen.

22
Mr. Kailas Laxman, ‘Fixation of Minimum Wage’ (2014), Shodhganga
http://shodhganga.inflibnet.ac.in/bitstream/10603/63042/7/07_chapter%202.pdf, accessed 2 April, 2019
23
Report of the National Commission on Rural Labour, New Delhi: Government of India, Ministry of Labour
(1991) at 180
 P a g e | 14

CHAPTER-4

ISSUES AND CONCERNS REGARDING THE FIXATION OF MINIMUM WAGE

Minimum wages expected to cover the essential costs of accommodation, food and clothing of a
small family. Even through the Minimum Wages Act is progressive in nature, there has been
several issues and concerns with regard to the fixation in rates in various states of India.

4.1 NORMS FOR FIXING THE MINIMUM WAGE

The act does not set out a minimum wage in rupee term, but it just suggests that there must be a
living wage24. The act also stipulates hat minimum wage rates are to be revised keeping in mind
the inflation. The guidelines laid down by the 15th Indian Labour Conference (ILC) and the
Supreme Court suggest that a minimum wage for 8 hours of work should be high enough to
cover all the basic needs of the workers, his/her spouse and 2 children.

However, many states while fixing the minimum wage do not provide dearness allowance. As a
result, real wages of workers keep eroding due to inflation, pushing them into the poverty line.25

Another inadequacy is that though the Minimal Wages Act, 1948 requires wages to be revised
every 5 years, this rarely happens. The act also has a clause which states that if the wages are not
revised, the existing wages will continue. This has led to greater unaccountability by the labour
departments, leaving many workers to live below the poverty line.

Different wages are fixed for the same work in different sectors. For example- a watchman in a
shop or commercial establishment may be fixed higher or lower wage than a watchman in an
industry. To overcome this deficiency, several states like Himachal Pradesh, West Bengal,
Andhra Pradesh etc, have rationalized all the different occupation categories into 4- unskilled,
semi-skilled, skilled and highly skilled. This way only one application will be available to all
industries.

Even though this system gives a clear and detailed information of minimum wages, it has no
been adopted by all the states.
24
“Living Wage” is a level of income sufficient to allow workers to support their families.
25
https://paycheck.in/root_files/080415_minimum_wages_in_india.pdf
 P a g e | 15

4.2 COVERAGE

In order to have minimum wage fixed, the employment or industrial activity had to be included
in the schedule of Employments. The creation of the exclusion that there needs to be at least
1000 workers engaged in that activity does not ensure the minimum wages to those workers
under this act. This leaves them outside the purview of the Minimum Wages Act.

4.3 IMPLEMENTATION

The main problem relating to the fixation of minimum wage is the poor implementation. The acts
empowers the appropriate government to fix a minimum wage for the workers in the
unorganized sectors. Many of the minimum wages has not been revised within the period of 5
years as stated in the act. Such failure in the implementation of act is not only due to the loop
holes in the act but also an outcome of the lapse of the administration.

The workers in the unorganized sector are manifold in nature and work under millions of
employers and this becomes difficult to cover them under law. This diversity leaves them
vulnerable to exploitation. Many workers being illiterate are not aware of their rights or do not
report the same because of the fear of losing their jobs.
 P a g e | 16

CHAPTER-5

JUDICIAL RESPONSE ON FIXATION OF WAGES

Only few cases have come before the Supreme Court and the High Court in regarding the aspect
of norms or criteria followed in the fixation of wages by the appropriate government.

In Unichoyi and Others v. The State of Kerala26, the Supreme Court held that,

“…the minimum wage must ensure not only the sustenance of the employee and his
family but also preserve his efficiency as a worker and that is what is contemplated by the
act. It is an error to think that the minimum wage is just what a worker requires to cover
his physical needs and to keep himself above starvation.”

In W.C.F Federation v. State of Kerala27,while dealing with the question of fixation of minimum
rates of wages under the Act, the Kerala High Court held that, the only relevant consideration for
the fixing of minimum wage under the Act, is the minimal requirements of the workers
concerned.

Further in the case of Crown Aluminum v Their Workmen 28, the apex court observed that,

“No industry has the right to exist unless it is able to pay its workmen at least a bare
minimum wage…employment of workers on starvation basis cannot be encouraged or
favoured in modern democratic welfare state. If an employer cannot maintain his
enterprise without cutting down the wages of his employees below even a bare
subsistence or minimum wage, he will have no right to conduct his enterprise on such
terms.”

In regards to the powers of the appropriate government in fixation of minimum wages under
Section 5 of the Act, the Supreme Court in Chandra Bhawan Boarding v State of Mysore29 held
that,

26
Unichoyi and Others v The State of Kerala (1962) AIR 12, 1962 SCR (1) 946
27
W.C.F Federation v State of Kerala (1968) AIR 1968 (Ker) 19
28
Crown Aluminum v Their Workmen (1958) AIR 30, 1958 SCR 651
29
Chandra Bhawan Boarding v State of Mysore (1970), AIR 2042, 1970 SCR (2)600
 P a g e | 17

“Minimum wage does not mean a wage which is just sufficient to meet the bare
sustenance of an employee and his family, it also includes expenses necessary for his
other primary needs such as medical expenses, expenses to meet some education for his
children and in some cases transport charges, etc.”

Interesting aspect of these decisions is that the judiciary has given due regard and recognition to
the question of definition of the term minimum wages. Though there are no set norms prescribed
by the Act for the quantification of the minimum rates, the judiciary has given importance to the
needs of the workers.
 P a g e | 18

CHAPTER-6

CONCLUSION

In conclusion it can be observed that the fixation of wages under the Minimum Wages Act is not
effective in nature, as previously stated, even though the Act provides for a procedure for the
fixation of wages, they have not set any rigid principle for the same. There are also various
issues regarding the implementation and coverage of the act as discussed.

In spite of vast number of workers in unorganized sector, and their substantial contribution to the
national economy, they are amongst the poorest sections of India’s population. It is therefore
imperative that urgent steps are taken to improve their condition.

Infrequent revisions and inadequate cost of living adjustments have been a marked feature of
minimum wages in India. The rates of minimum wages so fixed in few states, is not enough even
for two times meal in a day, leave aside the needs of health, education and shelter. In specific
terms, the issues and problems of the wage policy in both organized and unorganized sector,
relate to the elements like need based minimum wage, protection of the real wages through
compensation for rise in the cost of living, incentives for increases in productivity, allowances
for hazards of occupation, wage differentials for skills, etc.

There however has been two major initiatives for providing social security to the workers in the
informal sector.(a) The National Rural Employment Guarantee (NREG) Act, 2005 and (b) Social
Security for Unorganized Sector Workers.

The NREG Act, 2005 id meant for the working poor in villages to take care of the problem of
underemployment and to thus increase the income.

The Social Security scheme covers heath and maternity, life and disability and old age security in
the form of state pension for those belonging to poor households and Provident fund for others.

Minimum Wage legislation in India requires the active support of the workers and trade unions.
It would also require sincerity on the part of the labour departments in each state to determine the
minimum wage rate.
 P a g e | 19

As discussed, implementation of government policies and legislation is the main problem in the
organized sector. Also, low productivity in the informal sector, lack of gainful employment,
affect the bargaining capacity and put such workers in a vulnerable position. Therefore,
improvement of trade unions and Non Governmental Organizations can also play an important
role. Example- Self Employed Women Association (SEWA) in Ahmedabad. This is trade union
that works towards efficient fixation of wages for women workers.

The need of the hour is not only to increase the basic rates of minimum wage but the basic
approach towards the whole issue. The prevailing system of minimum wages, instead of
abolishing the poverty, is in fact increasing it. Initiatives like strengthening the enforcement
machinery, simplifying the procedure relating to coverage and revisions of minimum wage rate,
linking the rates with the Consumer Price Index Numbers (CPI), and increasing the involvement
of various workers' organizations in the implementation of the Minimum Wages Act, are some of
the steps advocated to improve the situation.
 P a g e | 20

BIBLIOGRAPHY

Acts Referred-
 Minimum Wages Act, 1948
 Constitution of India

Cases Referred-
 Y.A Marmarde v Authority under the Minimum Wages Act (1972), AIR 1721, 1972 SCR
(1) 161
 Bijoy Cotton Mills v. State of Ajmer (1955), AIR 33, 1955 SCR (1) 725
 Association of Planters of Kerala v. State of Kerala (1996), (74)FLR 2288
 Edward Mills Co. v. State of Ajmer (1955) AIR 25, SCR (1) 735
 Unichoyi and Others v The State of Kerala (1962) AIR 12, 1962 SCR (1) 946
 W.C.F Federation v State of Kerala (1968) AIR 1968 (Ker) 19
 Crown Aluminum v Their Workmen (1958) AIR 30, 1958 SCR 651
 Chandra Bhawan Boarding v Sate of Mysore

Research Papers Referred-

 Mr. Kailas Laxman, ‘Fixation of Minimum Wage’ (2014), Shodhganga

 Ms. A. Srija, ‘Implementation of Minimum Wages Act, 1948’(2014) Global Journal oh
Human Social Science: Political Science

Reports Referred-

 Government of India, Ministry of Statistics and Programme Implementation ‘Labour and

Employment- Statistical Year Book India 2018
 Report of the National Commission on Rural Labour, New Delhi: Government of India,
Ministry of Labour (1991) at 180

 ILO Recommendation No. 30 of 1928, Article III

 ILO Convention No. 131, 1970, Article III
 P a g e | 21

 One Man Committee Report on the Working of the Minimum Wages Act, 1948, New
Delhi: Government of India, Ministry of Labour (1996) at 266