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Which is the landmark case which expanded the scope of Article 23 of the Constitution of India ?

  • A.Glaxo Laboratories v. Presiding Officer, Labour Court, Meerut, (1984) 1 SCC 1
  • B.Vishaka v. State of Rajasthan, (1997) 6 SCC 241
  • C.PUDR v. Union of India, (1982) 3 SCC 235
  • D.M.C. Mehta v. State of Tamil Nadu, (1996) 6 SCC 756

Answer: C

The case is PUDR v. Union of India (1982).

In this case, about workers employed on the Asiad construction projects in Delhi, the Supreme Court held that paying a worker less than the minimum wage is 'forced labour' within Article 23, because economic compulsion that leaves a person no real choice is as much force as physical coercion. It also held that Article 23 is enforceable against private persons, not only the State.

The other cases concern different provisions: Vishaka laid down guidelines against sexual harassment at the workplace under Articles 14, 15, 19 and 21, M.C. Mehta v. State of Tamil Nadu dealt with child labour under Article 24, and Glaxo Laboratories was a labour case on standing orders and misconduct.

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