Legal Provisions Involved: Article 23 of the Constitution of India.

Judgement By: Supreme Court of India.

Judge/Bench: Justice Pankaj Mithal and Justice Prasanna B. Varale.

Facts

Teachers were appointed under the Samagra Shiksha Scheme in Uttar Pradesh on contract with a fixed monthly honorarium of ₹7,000. They were not allowed to take up any other job. Although their contracts were renewed year after year and proposals to increase their pay were approved, their honorarium remained almost the same and was even reduced later. This led the teachers to approach the courts.

Key Legal Provisions

Article 23 of the Constitution of India

Issues Raised

Whether teachers can be made to work for years on very low and unchanged pay that is below minimum wage levels.

Arguments of the Case

The teachers argued that low and stagnant pay forced them to continue working in unfair conditions. The State claimed that fixing honorarium was a policy decision.

Judgement

The Supreme Court held that keeping teachers on low honorarium for long periods, while stopping them from doing other work, amounts to forced labour under Article 23. The Court said honorarium cannot remain stagnant and must be revised regularly. Once increased, it cannot be reduced. The Court directed payment of ₹17,000 per month and allowed the teachers’ appeals, while dismissing the State’s appeals.

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