V. R. Krishna Iyer: The Renaissance Man of the Bench

Paper Details 

Paper Code: RP-VBCL-26-2025

Category: Research Paper

Date of Publication: April 20, 2025

Citation: Dr. Gopala Anjinappa, “V. R. Krishna Iyer: The Renaissance Man of the Bench", 2, AIJVBCL, 368, 368-380 (2025).

Author Details: Dr. Gopala Anjinappa, Asst. Prof. of Law, Government Law College, Kolar, Karnataka

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ABSTRACT

With the values and ideals in the administration of justice, V. R. Krishna Iyer is hailed as a “Bhishma Pitamah” of the Indian judiciary.  His contributions are legendary. His reformation to the Indian criminal justice system exhibits significant achievement. Justice Iyer’s commitment in the vicinity of the poor and the underprivileged greatly marks a momentous triumph. He is manifested as a human rights champion, a crusader for social justice and the environment, and a doyen of civil liberties. This article hallmarks on Justice Krishna Iyer’s indulgence towards labour issues, prison reforms, social justice, and his abiding respect for life and liberty. The paper focuses on Justice Krishna Iyer's influence on the judiciary, especially in terms of protecting the rights of the underprivileged. Ultimately, this article is dedicated in examining the judgments delivered by Justice V. R. Krishna Iyer and his approach towards the administration of social justice.

Keywords:Justice V. R. Krishna Iyer, human rights, social justice, Constitution, judgments, etc.

INTRODUCTION

Justice V.R. Krishna Iyer’sphilosophy of life aligns with the noble humanist values of the Preamble to the Indian Constitution.He is one of juristic mastery of India’s elegant judges. As a distinguished jurist, Justice V.R. Iyer delivered numerous landmark judgments by interpreting the Fundamental Rights. His style of writing judgments was superlative but natural.  He was determined by the American way of writing judgments. The text of his judgments was an impressive fusion of law and literature. Justice Iyer’s venture as a judge is crucial for outright judges to study and evaluate critically to determine the potential scope and limits of accomplishing the constitutional perception through judicial processes. No matter, Justice Iyer also determined judicial restraint even while discharging judicial activism and thereby sustained the integrity of the judicial profession. He has succeeded to a large extent in providing an outlet for new ways of thinking to trigger the cause of justice on social, economic, and political grounds.

LIFE OF JUSTICE V.R.KRISHNA IYER

Vaidyanathapuram Rama Krishna Iyer popularly known as V. R. Krishna Iyer was a second son born on November 15, 1914 to parents Sri.V.V.Rama Iyer and Smt. Narayani in Vaidyanathapuram village in Palakkad, Kerala. He joined the school in 1920 and further completed his matriculation at Government Victoria College in Palakkad and earned a B.A. degree in English from Anna University, Madras. In 1937, he graduated with a law degree from Madras Law College. On 19thSeptember 1938, he was enrolled as an advocate and began his legal practice in the Malabar area. He was later elected to the Madras Legislative Assembly representing Tellicherry (Malabar area).

On 6thFebruary 1941, Sri. Krishna Iyer married Smt. Sarada. They were blessed with two sons, Ramesh KrishnaIyer and Paramesh Krishna Iyer. The couple shared thirty-three years of marriage until Sarada's passing on 12thAugust 1974, following heart surgery at St. Mary's Hospital in Milwaukee.[1]

As a distinguished individual, Justice Iyer is a legend as a social activist, a lawyer, a minister, a legislator, a reformer, a High Court Judge, and a Supreme Court Judge and a member of a Law Commission. Krishna Iyer, following in the footsteps of his father, who was a prominent lawyer at the Tellicherry and Malabar District Courts, joined him at the district court to begin his own legal career. Justice Krishna Iyer as an eminent jurist, regarded law as an instrument of social engineering, a powerful tool in the hands of society to reach social justice for the common man.

JUSTICE IYER’S EXCELLENCY IN POLITICAL TERRAIN

Before being appointed as the judge, V.R. Krishna Iyer became a member of the Madras Legislative Assembly in 1952 from the Thalassery constituency as an independent candidate with the support of left parties and the Muslim League. In 1957, after the re-organization of States, he was elected to the Kerala Legislative Assembly as an independent and was the cause for the first communist-led government in an Indian State. Justice V.R. Iyer managed portfolios as varied as Law, Justice, Home, Energy, Prisons, Social Welfare, Agriculture, Irrigation, and Cooperatives.

Justice Krishna Iyer has elegantly expressed his views on the grim and bizarre situation in one of his works thus: “The Indian experience about the Executive, Judicial and Legislative instrumentalities over four decades have been one of exploitation darkening into misgiving, misgiving deepening into despair and despair exploding as adventurist violence. The categorical imperative for stability in democracy is, therefore, to see that every instrumentality is functionally kept on course and any deviance or misconduct, abuse of aberration, corruption, or delinquency is duly monitored and disciplinary measures taken promptly to make unprofitable for the delinquents to depart from the code of conduct and to make it possible for people, social activism professional leadership and other duly appointed agencies to enforce punitive therapeutics when robed culprits violate moral-legal norms[2].

OUTSHINE IN LAW COMMISSION

From 1971 to 1973, V. R. Krishna Iyer was a member of the Law Commission of India and served under the supervision of Justice P. B. Gajendragadkar. The first ever National Project for Free Legal Services to the Poor was a Report on Processual Justice to the People by a high-powered committee headed by Justice Iyer. In the field of legal aid, his committee’s report was the first National Presentation of a project for free legal services in the country, way back in 1973.

BENCHMARK IN THE JUDICIARY

Justice V. R. Krishna Iyer truly embodies the spirit of justice and human rights. His landmark judgments and reforms have had a profound impact on the Indian criminal justice system, especially in areas like prison reforms, labour issues, and social justice. His dedication to protecting the rights of the underprivileged and upholding civil liberties has made him a revered figure in the judiciary.From championing the rights of prisoners to advocating for the welfare of labourers, his contributions have been pivotal in shaping a more equitable and humane legal system. His unwavering commitment to life and liberty highlights his deep respect for human dignity.

On July 2, 1968, Justice V. R. Krishna Iyer was appointed as a judge of the Kerala High Court on the initiative of Mr. Menon, the then Chief Justice of the Kerala High Court. He brought new dimensions of compassionate humanism to the legal field and provided direction to the judicial process. He was on the bench of the High Court for three years. Later, Justice V. R. Iyer served as a judge of the Supreme Court of India between 1973 and 1980. He took the Supreme Court in a new direction while evolving profound principles.

The Indian Constitution by and large seeks to promote Rule of Law through many of its provisions. The Constitution makes adequate provisions guaranteeing independence of the judiciary. Judicial review has been guaranteed through several constitutional provisions. The Supreme Court has characterized judicial review as a "basic feature of the Constitution”.[3] Justice Iyer used to reiterate time and again a guiding principle that: The law of all laws is that the 'rule of law' must sustain the 'rule of life'" by climbing down from its high pedestal, to ascertain ground realities for meeting the needs and aspirations of the people in an ever-changing society.[4]

Fali S. Nariman noted in one of his addresses that Krishna Iyer always did what he thought was right – he never bothered about the consequences. In the Bangalore Water Supply case[5], he deliberately widened the spectrum of what was meant by word “industry” under section 2(j) of the Industrial Disputes Act, 1947 overruling what the Supreme Court had previously and almost consistently said about this word and its restricted interpretation. When Parliament intervened to re-define more narrowly the term “industry” in the Act, almost nullifying his judgment, the amendment did not bother him. His approach in this, as in all matters, was influenced only by his own sense of the dominant need of the times. In the same case, after noticing the rival contentions of counsel for each of the parties he said:

“Is it not obvious from these rival thought-ways that law is value-loaded, that social philosophy is an inarticulate interpretative tool? This is inescapable in any school of jurisprudence”[6].

Justice V. R. Iyer was a crusading individualist, for he was someone who exhibited great independence in thought and action and was very unorthodox in his approach and at last a genius of vocabulary, for he was, both praised and criticized for his ‘unjudicial unenglish’ (the love of the long word & odd mintage) and the readers of the law reports had never seen such vocabulary used before and were compelled to expand their own vocabularies.[7]

Justice Iyer’s passionate towards Human Rights

The Supreme Court of India in the late 70s and 80s has played a big role in developing the Indian Constitutional jurisprudence. The major attention in this context has been devoted to the right to life and personal liberty enshrined in the Constitution of India, art. 21. Justice Iyer has played a leading role in this area. Human rights had not been given the right meaning and place in the constitutional interpretation before the advent of Justice lyer on the Supreme Court. It is he who provided a new direction that helped in making human rights vis-a-vis the accused, the under-trial, and the prisoners a reality. It is in this area that the Court realized that the Constitution should be given meaning and interpretation keeping in view the situation and circumstances prevailing.

His verdict in Charles Sobhraj vs Superintendent of Central Jail[8] declaring that handcuffing is offensive to human dignity spawned the judiciary to interpret Article 21 (right to life and liberty) of the Constitution, taking it to new heights.[9]

The modern trend in all spheres of life calls for a new approach to the problem of administration of justice, making it simple, speedy, substantial, effective, and easily available to the common man, departing from the old cumbrous and dilatory manner developed in days of leisure and laissez-faire. Justice Iyer has raised this call through his about 400 judgments, numerous writings, and still more numerous lectures and talks. Indian Constitution has particularly shaped and reshaped through the judicial process and in the field of Constitutional law, fundamental rights and directive principles occupy subgenre’s position[10].

Justice Krishna Iyer overlooked to human rights by introducing the ideals of international covenants into Indian law to justify humanism.  Krishna Iyer J. justified judicial activism on the score that it strengthens Indian democracy, particularly when the courts are spurred by the conviction that legislative processes and administrative agencies have failed to bring society closer to the meaning of its constitutional values. He transcended the domain of jurist or a judge of law and became a Sage of law who has given us a clear vision of what the Laws should be and are going to be, in the coming future[11].

Life, especially the right to life, claimed his judicial adoration. In the Maneka Gandhi case[12], Justice Krishna Iyer expanded the interpretation of “right to life” and “personal liberty”. Also, he focused on the feature of the interlinking of the provisions of the Constitution of India, art. 14, 19 and 21, confined as to that these provisions are inseparable. In this, the confiscation of Maneka Gandhi’s passport by the authority was questioned and thus Justice Iyer observed that: 

“The watershed between a police state and a people’s raj is located partly through its passport policy…The policing of a people’s right of exit or entry is fraught with peril to liberty unless the policy is precise, operationally respectful of recognized values and harassment proof.” 

This shows his liberal attitude to protect individuals from state-aided abuses. 

Justice Iyer as a progenitor of Public Interest Litigation (PIL)

The sprouting of the PIL was initially shown by Justice Krishna Iyerin Mumbai Kamgar Sabha v. Abdul Thai[13], while disposing of an Industrial dispute regarding the payment of bonus to workers. In the words of Justice Krishna Iyer, ‘Public interest litigation is the incarnation of judicial activism in its people-oriented litigation dimension and environmental preservation. Justice becomes a living reality only if PIL becomes a pragmatic facility for the common people. New public interest jurisprudence was invented, the old ‘locus standi’ rules were blown out, epistolary litigation was encouraged and an action was evolved for giving relief to the disadvantaged. Procedural ‘due process’ was restored to center stage, overruling earlier decisions. Consequently, this radical transformation gave high international stature and visibility to the Supreme Court. It was an explosive enlargement of the court’s jurisdiction. It carved out a niche in the common citizens’ hearts whose respect and adoration for the higher judiciary reached glorious heights. Justice Krishna Iyer’s prolific judgments, his gentle and disarming demeanor as a judge, his unrivaled grasp of facts and law, his empathy for the disadvantaged, and his courtesy and consideration for the young lawyer appearing before him was a unique blend of judicial virtues[14].

In the 1970s, the judicial system was attacked because of its inaccessibility. Thus, he introduced and penned down the report ‘Nyaya panchayats’ to provide a solution to the problem. He suggested, instead of the expansion of legal aid, that one can meet the problem by creating informal parallel institutions and diluting judicial procedure. This vision was later developed into the institution of Lokadalats, tribunalization at the intermediate level and Public Interest Litigation at the highest level of the judiciary. 

Krishna Iyer, along with Justice P.N. Bhagwati, laid down the foundations for filing PILs (Public Interest Litigations) in a series of cases. PIL letter petitions were initially addressed to them personally, and one such letter was addressed to him from jail as a writ petition, i.e., the one of Sunil Batra. Commenting on this, he said: 

“Freedom behind bars is part of our constitutional tryst…If wars are too important to be left to the generals, surely prisoners’ rights are too precious to be left to the jailors”. 

Thus, Professor Upendra Baxi said about him that from the Supreme Court of India he made it the Supreme Court for Indians’. 

Krishna Iyer’s commitment to social justice was always staunch from the very beginning. In the Ratlam Municipality case[15], the concept of ‘polluters pays’ was emphasized. Justice Krishna Iyer started the trend for the judges to go to the grounds to see the actual situation rather than seating in the courtroom. In this case, the responsibility of the government and the industry in connection with the pollution and the cost of the pollution were dealt with for the protection of the larger interest of the society. 

Justice Krishna Iyer was a vocal opponent of capital punishment. He prioritized judicial decisions that emphasized life-saving virtues, making death sentences a rare verdict from his bench. In the case of EdigaAnamma[16], where a woman convicted of a planned murder was sentenced to death by the sessions court and the High Court upheld the sentence, an appeal was filed to the Supreme Court to overturn the death sentence. Justice Krishna Iyer, demonstrating his belief in the reformative theory of punishment, commuted the death sentence to life imprisonment. His decision was based on several factors, including gender, age, socio-economic background, and psychological compulsions. While he did not advocate for the complete abolition of the death penalty, he believed that various factors should be considered in such cases rather than solely focusing on the crime committed, taking into account the broader social context.

In the matter of reservation, Justice Iyer’s interest was towards reservation policy. In the celebrated case, his judgment in State of Kerala v. N.M. Thomas[17], Justice Iyer is a classic exposition of the constitutional commitment to the weaker section[18]. The question was whether art. 16(1) itself permitted the classification of backward classes to enable the State to confer certain benefits and grant some concessions in favour of persons belonging to Scheduled Castes and Scheduled Tribes. The significant judgment was towards constitutional commitment to the weaker sections.

The segregation of under-trail and convicted prisoners and directions for expeditious disposal of cases of the pre-trial prisoners are the greatest reforms introduced by Justice Iyer’s landmark decisions. In several judgments on prison reforms, Justice Iyer issued directions for providing more humane treatment to prisoners within the framework of the existing law. In the Sunil Batra case (Sunil Batra v. Delhi Admn., (1978) 4 SCC 494, 509), he observed, “Karuna is a component of jail justice. Basic prison decency is an aspect of criminal justice.” In this judgment, he formulated extensive guidelines for the exercise of the power under Section 56, Prisons Act in the matter of imposition of bar feters on convicts. A little later, in the Prem Shankar Shukla case[19],he ruled that handcuffing of undertrial prisoners is permissible only in very exceptional situations. His passionate plea for amelioration of prison conditions and early prison reforms will be remembered for a long time to come. Justice Krishna Iyer, in Lingala Vijayakumarv. Public Prosecutor[20], stressed the need to keep first offenders who were young away from hardened criminals in jail, to provide the former with opportunities to reform themselves into better citizens. Justice Krishna Iyer gave various guidelines about the treatment of prisoners to reduce their criminal tendencies.

In S.H. Sheths’ case[21], Justice V.R. Krishna Iyer have clearly laid down that it is the duty of the Chief Justice of India to elicit and ascertain, if necessary, by asking directly the judge concerned or from other reliable sources. The executive cannot and ought not to establish rapport with the Judges which is, the function and privilege of the Chief Justice., all relevant material relating to the judge."[22]

In the Ratlam Municipality case[23],the Constitution of India, art. 21 was interpreted as including the right to a wholesome the environment, changed the whole approach of the courts in matters concerning environment. He gave a new life to the Code of Criminal Procedure, s. 133 of, which gives powers to the District Magistrate to avert public nuisance in a particular locality. The Court ordered the Municipality to provide basic civic facilities to the public without making lame excuses.  This Judgment became an eye-opener for the public-spirited individuals and encouraged them to file litigations to solve local environmental issues. This reformed the whole system and several cases have been filed before different courts seeking remedies against environmental pollution.

In Akhil BharatiyaSoshitKaramchari Sangh’s case[24], Justice Krishna Iyer was equally conscious that the system of reservation for SC / ST and others shall in no way distract from the maintenance of an efficient administration and the advancement of Scheduled Castes or Scheduled Tribes the maintenance of efficient administration shall not be impaired. It is an expeditious development of SCs and STs in occupying several renowned positions in public life that indicates if given some more opportunities, they shall make India certainly great.

Justice Iyer further observed that:

‘The current thinking is that while Fundamental Rights are primarily aimed at assuring political freedom to the citizens against excessive State action, the Directive Principles are aimed at securing social and economic freedoms by appropriate State action. The Directive Principles are made unenforceable in a limited sense because no Court can compel a Legislature to make laws. But that does not mean that they are less important than Fundamental Rights or that they are not binding on the various organs of the State. They are all the same fundamental in the governance of the country and it shall be the duty of the State to apply these principles in making laws. The Directive Principles should serve the Courts as a Code of Interpretation...A Constitution, such as ours, must receive generous interpretation so as to give an its citizens the full measure of justice so proclaimed. While interpreting the Constitution the expositors must concern themselves not so much with words as with the spirit and sense of the Constitution which could be found in the Preamble the Directive Principles and other such provisions.

The contributions of Justice V. R. Krishna Iyer, as a pro-socialist judge, to labour jurisprudence are legendary. Justice Iyer reiterated that the Constitution of India, art. 39, 41, 42, 43 and 43A - directives followed by Articles 14 and 16 fundamentals are our 'innuendo' captions and 'Headlines' and 'social justice' to be Hallmark of our Labour jurisprudence[25]. 

The Indian Express News Papers Pvt. Ltd., v. Indian Express Newspapers Employees Union[26]highlights the matter of economic justice concerning non-journalist employees.Justice Krishna Iyer felt the requirement to ensure a fair and just wage structure for the non-journalists, having due regard to the paying capacity of the respective newspaper establishment, the employer’s agreement and the emoluments of employees engaged in capable establishments. Justice Krishna Iyer remarked that, ‘a free press can summon its flaming vigor only if its journalistic and non-journalistic wings go into full swing with courage and contentment to make the printed end-product that issues daily from the machine so that the office of education and information the Fourth Estate must perform does not suffer. The community itself has a vital concern in the working conditions of the dual human groups whose invisible work is crystallized daily and moved into mass circulation. In a democracy, news media and the men behind have a special value. Therefore, a few legislative and non-legislative measures have taken care of the working conditions of the journalists and the non-journalists. We are concerned here with non-journalists and that portion of an award which has conferred standardized gratuity benefit on them’[27].

Justice Krishna Iyer created history in delivering justice to the working class. Bonded labour is a form of forced labour analogous to slavery. Justice V. R. Krishna Iyer rightly called bonded labour as ‘quasi-slavery’[28].

Justice Iyer was a great judge and jurist during his tenure in the Supreme Court. He was not a traditional judge who examines evidences and studies law based on which the verdict was delivered but was more of a social scientist who had law as his tool. He exclusively focused within justice within the four corners of law. Justice Iyer’s service at the bench came to an end when he retired on November 14, 1980.

CONCLUSION

Justice Krishna Iyer has rendered an excellent service in the domain of the judiciary. No doubt, Justice V.R Krishna Iyer was an absolute champion of justice for the downtrodden and has given significant contributions to society as a distinguished jurist.  It is evident that, the transformation of Indian Jurisprudence has its seeds in the chivalrous decisions from the Bench of Krishna Iyer during his reign in the Supreme Court. Even after retirement at the age of 65, Justice Krishna Iyer became an unrivalled master of social justice, constitutional values and the rule of law. Justice Iyer was headed as the Chairman of the Kerala Law Reforms Commission during and made a report on January 26, 2009 recommending 63 new enactments and 30 amendments to the existing laws. He proposed for panchayat courts and also environmental courts. Justice Krishna became a public asset whose every minute was devoted to and drawn upon by the people, high and law.

An analysis of the article reveals that Justice Iyer, as a judge, substituted his wisdom and interpreted the law to satisfy the needs of the suppressed and thereby, uphold and promote social justice through developing a sense of social sensitivity among the people. In the same manner, every single judge has to owe with a commitment to social justice while delivering the judgments. A judge has to contribute materially to the intellectual discourse in developing an analytical attitude through which social realities can be evaluated and enveloped by ideals of social justice. They must break the obsolete conceptions of social hindrances prevalent in the society that inhibit social growth. Judges need to prepare new tools, innovate new strategies and evolve a new jurisprudence, with an obligation for accountability not to any party in power nor to the opposition nor to the classes that vehement but to the people at large who are denied of their basic human rights as the vision of Justice Krishna Iyer. 

Justice Iyer's legacy continues to inspire and guide the judiciary in its role as the protector of the needy and the marginalized. His work reminds us of the power of the judiciary in fostering social justice and ensuring that the law serves as a tool for empowerment and protection for all.

* Asst. Prof. of Law, Government Law College, Kolar, Karnataka 

[1] Life’s long voyage of Sri. V.R. Krishna Iyer, Sarada Krishna Satgamaya Foundation for Law And Justice, V.R.Krishna Iyer National Foundation of Law<https://justicevrk.com/lifes-long-voyage-of-sri-v-r-krishna-iyer/> assessed (04 February, 2025)

[2]Krishna Iyer V.R., Justice at Crossroads (Deep and Deep Publications, New Delhi, 1994) 265.

[3]Minerva Mills Ltd. v. Union of India[1980] AIR SCC 591.

[4] Justice V.R. Krishna Iyer, “Ministry of Law & Justice” (2015) 4

accessed <lawmin.gov.in/sites/default/files/2015>accessed January 31, 2025

[5]Bangalore Water Supply & Sewerage Board v. A. Rajappa[1978] AIR SC 548

[6] Fali S. Nariman, “Salute to the Pride of the Thalasserry Bar”in V.R. Krishna Iyer (ed.). Dynamic Lawyering, (Universal Law Publishing, 2009) 155

[7]P.B. Sahasranaman,“Speaking for the Bench: Selected Judgments of Justice V.R. Krishna Iyer”, (Oxford University Press, New Delhi, 2012)318-319.

[8] (1978) AIR SC 1514

[9]‘Justice Iyer, a people's judge’ DECCAN HERALD (05 December 2014), 01:51 IST <www.deccanherald.com/india/justice-iyer-peoples-judge-2228159> accessed 01 February, 2025

[10]ChanderShailja, ‘Justice V.R. Krishna Iyer on Fundamental Rights and Directive Principles’ (Deep & Deep Publications, New Delhi, India, 1992)

[11]Dr. Pauly Mathew Muricken, ‘Justice Krishna Iyer: A Man of Light and Learning; A Seeker After Justice’, LiveLaw.in (February 11, 2015) LiveLaw.in

<www.livelaw.in/justice-krishna-iyer-man-light-learning-seeker-justice/>assessed January 31, 2025)

[12]Maneka Gandhi v. Union of India (1978)AIR SC 897.

[13](1976) AIR SC 1455

[14]Anil Divan, ‘A Unique Blend of Judicial Virtues’,THE HINDU (November 15,2014)

<www.thehindu.com/opinion/op-ed/Comment-on-Justice-Krishna-Iyer/article62114948.ece>assessed February 02, 2025

[15]Municipal Council, Ratlam v. Vardhichand and others(1981) SCR (1) 97

[16][16]EdigaAnamma v. State of Andhra Pradesh (1974) AIR SC 799

[17](1976) 1. SCRp.906

[18]Krishna Iyer V.R., Justice at Heart: Life Journey of Justice (1sted. Eastern Book Company2016)

[19]Prem Shankar Shukla v. Delhi Admn. (1980) 3 SCC 526

[20](1978) AIR SC 1485

[21]SankalchandHimatlal Sheth v. Union of India (1978) 1 S.C.R 423

[22]Sumit Mitra, ‘SC Judgment Strips Judiciary of much of its aura of Respectability”, India Today(October 21, 2013)

<www.indiatoday.in/magazine/nation/story/198201312013-10-21>assessed (January 29, 2025)

[23]Municipal Council, Ratlam v. Vardhichand and others(1981) SCR (1) 97

[24]Akhil BharatiyaSoshitKaramchari Sangh (Railway) Represented v. Union of India and Ors.(1981) AIR SC 298

[25]Bhanwar Lal v. Rajasthan State Road Transport Corporation(1985) ILLJ 111 Raj

[26]AIR 1978 SC 1137

[27] Sharath Babu and Rashmi Shetty, Social Justice and Labour Jurisprudence: Justice V.R. Krishna Iyer’s Contributions (SAGE Law 2007)

[28]Dr. Abdul Majid, Legal Protection to UnorganisedLabour (Deep and Deep Publications 2000)28.