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Comparison Of Unfair Labour Practices In India And Pakistan

INTRODUCTION

“All Labour that uplifts humanity has dignity and importance and should be undertaken with painstaking excellence”- Martin Luther King Jr.

The researcher analyses the Labor law regulations and unfair trade practices in the Industrial sector. For the purpose of this paper, the researcher tries to analyze the Garment Industry. Even persons who have studied labor regulations frequently use the terms Textile and Garment Industry interchangeably, yet they are neither synonyms nor alternatives for one another. They have quite distinct connotations as individual phrases. Jute, handlooms, power looms, silk weaving, readymade garments, and so on are all part of the textile industry.  Textile industry is a genesis while the garment industry is one of the species.

The fundamental reason for choosing the Garment Industry for the purpose of this paper  is that, of all the Textile Industries, it is the Garment Industry that generates the most profits and contributes the most to foreign exchange flows. And the garment industry is the one that employs the most women skilled workers. Over the course of two decades, the garment industry went from being unorganized to being organized. And the majority of garment industry workers are illiterate. As a result, the researcher decided to narrow down the study universe from being textile industries to garments industries.

This paper is an attempt in a direction to discuss about the importance of Textile Industry in Indian Economy and conceptual analysis then it moves on to analyze the Social Security available to Textile Industry workers as a whole along with the practicalities of implementation of such social security laws.

In any democratic country, the peaceful and fair industrial relations are the prerequisite for the economic development which will guarantee the economic justice to the people. For this to occur, an environment needs to be created which will enable both the employer and the workmen to come together to protect the interests of both through the practices of effective collective bargaining on instances of disputes. Such an environment can only be created when the relationships are based on the fair labour practices which demand accountability from both the sides.

Unfair labor practice refers to activities which violate relevant employment legislation concerning transgression carried out on by an employer. Unfair labour practices have been recognized as the key factor to adversely affect the procedure of collective bargaining which obstructs further industrial harmony. It is unfair treatment by an employer of an employee. When employers decline to bargain with a union that has authorization to represent its employees or discriminates against an employee from engaging in union activities. Unfair labor also occurs when unions serve as a cause for an employer to discriminate against an employee, strike or picket a health-care establishment without giving the necessary notice.

In the rest of this paper, we will try to explore and discover the situation in detail and how it plays the key role in establishing the harmonious industrial relations which is the mainstay of the economic progress and development in a democratic country in the context of India and Pakistan.

IMPORTANCE OF TEXTILE INDUSTRY IN INDIA

In India, the textiles industry accounts for roughly 14% of industrial output, 4% of GDP, and 27% of foreign exchange inflows. It also employs over 45 million people directly, making it the second largest employer behind agriculture. The readymade garment (RMG) industry is a major employer in India’s cities and a major contributor to the country’s economy. It has evolved from a primarily informal to a largely formal, factory-based business that is heavily reliant on labour inputs over the last two decades.

The largest RMG manufacturing centers, which are located in Bangalore (Karnataka), Tirupur and Chennai (Tamil Nadu), and the National Capital Region (NCR), employ well over a million women and men. Women outnumber men in the southern NCR, while men outnumber women in the northern NCR. A large proportion of RMG sector employees are first generation industrial workers, with many being internal migrants.[1]

Despite India’s vast domestic market, the RMG business is mostly export-oriented, with a considerable amount of manufacturing headed for OECD countries. Large and mid-sized manufacturing companies in the sector are part of a worldwide value chain. Industry competition, both within India and mostly from Asian, countries, has a direct impact on their business strategies and practices. National and state labour rules and regulations bind Indian manufacturers, which differ from those in competing countries.

Labour is critical to the sector’s current competitiveness and long-term viability. In a constantly changing economic climate, workers’ skill levels, productivity, and motivation, the industry’s capacity to attract and retain the correct amount and quality of workers, domestic labour laws and regulations, and workers’ living circumstances and expenses in metropolitan areas are all crucial.

Despite the fact that the textile sector contributes significantly to the country’s economy, there is no dedicated regulation that addresses the textile industry and its workers. The textile sector, on the other hand, is supervised by the Factories Act of 1948. As a result, the Textile Industry in Toto is subject to all of the working conditions outlined in the Factories Act.

Conceptual Analysis Related to Social security and other benefits

Before we discuss the Social Security benefits accessible to garment industry workers, we must first determine which legislation this industry falls under. We can begin by debating whether the garment sector is classified as an industry under the Industrial Disputes Act 1947 or as a factory under the Factories Act 1948. Another question is whether the garment industry is covered by both the Workmen’s Compensation act 1923 and Employees Provident Fund Act 1952.

Whether the garment industry falls under the purview of the ID Act.

“Industry” is defined as “any business, trade, undertaking, manufacture, or calling of employers, as well as any calling, service, employment, handicraft, or industrial occupation or avocation of workers.” Because the definition is unclear, we must interpret this notion using the term “public utility service.”

The definition of term “public utility service” has been provided under S.2(n) of ID Act.[2]

Cotton is also listed as a Public Utility Service in the First Schedule of the Industrial Disputes Act, under the 5th entry. As a result, it is apparent that the garment business is covered by the Industrial Disputes Act.

  • Whether Garment Industry is a factory under Factories act

The factories act provides for the safety of the workers who are employed under a factory. To determine if that enactment protects the health and safety of garment workers, one must first determine whether the garment industry falls within the definition of “factory” under the Factories Act.

The definition of term “factory” has been provided under S.2(m) of factories act,1948[3]

By reading the definition, it is evident that Garment factories are likewise covered by the Factories Act, and their health and safety are thus protected.

Social Security under Employees Provident Fund Act and Workmen Compensation Act

Employees Provident Fund Act and Employees Compensation Act are the cornerstones of Indian social security legislation. Both enactments have provisions for the garment industry. S.2(e) of the Employees Provident Fund Act defines the term Employer.[4]

Garment workers who suffer from Occupational Diseases are likewise protected under the Employees Compensation Act. The disorders induced by dust in the garment industry are included as an occupational sickness in Schedule III of the Employees Compensation Act.[5]

Myths And Realities Of Social Welfare Of Workers Of Garment Industry

Around 8 million people work in the garment industry in India, which has a population of 1.26 billion people. However, India lacks particular legislation that addresses the social security benefits provided to workers in these industries.

Analysis of Labour Laws

Other benefits

 Many current workers access benefits from their employer such as Employees’ State Insurance (ESI) and Employees’ Provident Fund (EPF) (79% each) and on-site health care (51%). Other benefits are less widely available – such as paid annual leave (22%), on-site child care (7%) maternity leave and paid sick leave (9% each). Some trade union informants maintained the EPF system is abused. For example, employers can insist their workers quit to avoid paying out higher amounts of EPF due when they stay longer in the company. The same worker will then be re-hired using a new ID card. There is also the issue of “wage theft” when the employer deducts EPF from the wages but 5 An inconsistency is noted between the figure of 46% of current workers saying they had taken paid leave in the prior 12 months and responses reported in section iv. below, where it is stated that only 22% of current workers reported being entitled to take paid annual leave.

This could be due to errors in survey administration, possibly the exclusion of the word “paid” in the question. The figure of 46% does appear on the high side in the light of other findings of the survey. 21 does not deposit it into the worker’s account. As noted above, one government official stated that workers actually prefer factories where statutory deductions like ESI and EPF are not withdrawn from their earnings, as they cannot access these benefits in practice and would prefer to take the cash instead.

The benefits provided to workers that were listed by the manufacturer informants included separate toilets for men and women, subsidized meals, crèche, subsidized transport, good infrastructure such as ventilation and good quality personal protection equipment, on-site medical facilities, a rest room for the sick, as well as cultural activities and an annual sports day. Some union officials claimed the law and its requirements are not always followed; for example, “the law requires a crèche, but you’ll see a factory with 4-500 workers and you will not see a crèche.” As with leave, the lack of facilities or benefits does not in itself constitute an indicator of forced labour. It would only constitute this if the employer deliberately manipulated such entitlements in order to exact work against the worker’s free choice. Evidence from the quantitative survey seems to show that most workers are registered for the ESI and EPF. However, there are no data about the one-fifth of workers who said they do not enjoy these entitlements.

VARIOUS SCHEMES

  • WOMEN EMPOWERMENT SCHEME OF 8.3.2019.[6]

Women handloom weavers have been provided a 100 percent subsidy to build weaving sheds under this scheme. This scheme has benefited 1, 71,882 women thus far. Women weavers have received seven national awards as a result of this.

  • GROUP INSURANCE SCHEME FOR POWERLOOM WORKERS 1.01.2008.[7]

The primary goal of this system is to offer coverage for power loom weavers in the event of natural death, accidental death, and partial or permanent disability as a result of an accident. The premium for this scheme is Rs. 470/-, with the worker contributing only Rs. 80/- and the rest being covered by the government.

  • SHIKSHA SAHAYOGA YOJAN.

Workers registered in this scheme are also eligible for an educational award of Rs.600/- every half year for two children in grades IX to XII, for a maximum of four years.

  • PILOT PHASE OF TEXTILE INDUSTRY WORKERS’ HOSTEL SCHEME.[8]

The Scheme’s goals are to offer safe and secure housing for the workforce, as well as to promote better retention of the workforce by providing decent housing in/near the textile parks, hence increasing productivity. During the remaining 12th Five Year Plan period, the Scheme aims to build workers’ hostels for approximately 3,750 workers.

The shocking fact about the Ministry of Textiles is that there are less plans for worker welfare or social security than there are for increasing foreign direct investment. Even if we look at study reports produced by ministries, we find statistics regarding the  “Study on Enhancing Export Competitiveness,” “Report on Technological Upgradation Scheme,” “Short Time Revival Plan for CCIC,” “Foreign Direct Investment Scenario in Indian Textile Industry,” “Assessing the Prospects of Exports for Indian Textile and Clothing Sector,” and “Foreign Direct Investment Scenario in Indian Textile Industry.”

According to the Indian Fact Sheet of the Clean Cloth Campaign, India’s garment workers are not even paid the minimum wage by their employers, and they suffer from asthma, bladder cancer, hearing loss, and skin illnesses as a result of their constant exposure to dust and noise.

When it comes to health hazards, garment workers are exposed to chemicals, cotton dust, and noises on a regular basis. Workers in the textile business, particularly those involved in dyeing, printing, and finishing, are exposed to a variety of chemicals. Textile operations use benzidine-based chemicals, optical brighteners, solvents and fixatives, crease-resistance agents that release formaldehyde, flame retardants that contain organ phosphorus and organobromine compounds, and antimicrobial agents.

Cotton workers are exposed to considerable levels of cotton dust while processing and spinning cotton. They are also exposed to pesticide and soil particles. Textile workers have respiratory problems as a result of exposure to cotton dust and other particles. Excessive exposure to cotton dust causes the fatal disease of byssinosis, also known as brown lung, in those who work in the textile industry. Chest tightness, coughing, wheezing, and shortness of breath are all symptoms of this condition. Most textile manufacturing units, particularly those in developing nations, have been shown to have high levels of noise. Long-term exposure to excessive noise levels has been shown to damage the eardrum and cause hearing loss.[9]

Unfair Labor Practices in India

In India when the Industrial Disputes Act,1947 was enacted there was no clear provision as to define what exactly is an ‘Unfair Labour Practice’ nor were there any provisions checking anf preventing it. Later on, through the amendment act of 1982 (brought into force with effect from 21st August,1984) clause was inserted in sec. 2 defining ‘unfair labour practice’ to mean the ‘practices specified in the fifth schedule’.[10]

Sec 25T bars the commission of the Unfair trade practices by the employers as well as the workmen and section 25U recommends stringent penalties and punishments for commission of unfair labour practices. The Fifth schedule was also introduced by the same amending act which categorizes unfair labour practices into two categories which are as follows,

Unfair Labour practices on part of employer or trade union of employers.

  • An employer has no right to interfere, restrain or coerce an employee from exercising their right to organise, form, join or assist a trade union or to engage in concerted activities for the purpose of collective bargaining or other mutual aid or protection.[11] The act bestows on all employees that they are free to join any trade union they wish to and the employer has to respect their decision rather than challenging it.
  • Employers will be held liable if they offer any support to trade unions either financially or by taking an active interest in the issues of the trade union. This was laid down in order to create a clear distinction between the interest of the employer and the employees and to ensure that the employer does not use his influence and professional position to influence trade unions in taking certain decisions. This provision was also laid down in order to do away with favoritism among trade unions by employers and to ensure that all trade unions are treated equally and that they function independently without the influence of employer.
  • An employer cannot encourage or discourage a workman from joining a particular trade union. An employer has no relation with any employee trade unions and should not influence his employees to join or leave a trade union, these decisions need to be taken by the employees themselves on their own accord. [12]
  • Employers are expected to treat all workers equally and should give appraisals and promotions to employees based on their merit and not because they are part of a trade union.[13] If employers give promotions to employees based on involvement with trade unions, this will create dissatisfaction among the employees and will lead to unrest in the work place.  Employers are not allowed to show favoritism to a set of employees regardless of merit.
  • Employers have the right to terminate the service of workmen on grounds of punctuality, laziness, non-efficient, etc.; however, if an employer terminates the service of an employee based on untrue and malefic grounds then the employer will be liable for performing ‘Unfair Trade Practice’. Employers cannot discharge or transfer employees based on any reason other than professional and work-related reasons. The employee has the right to know the reason for being discharged or transferred from a particular job and cannot be victimized by the employer.
  • Employers are not allowed to make any workmen who were on a legal strike to sign any bond of conduct before resuming work. As long as the strike is legal the employer has to allow the workmen to resume work.
  • Employers will be said to be performing unfair trade practices if he recruits a worker during a legal strike or if he uses force against any worker or if a worker is supposed to testify against the employer and the employer discharges him from his job before such testimony is made.
  • An employer cannot hire workers permanently and treat them as ‘badli workers’ (temporary workers) just so that they do not get entitled to any of the privileges that permanent employees are supposed to get.
  • An Employer cannot refuse to collectively bargain with a recognized trade union nor can he fail to implement any settlement, award or agreement between employer and employees.

 Unfair labour practices on part of workmen or trade union of workmen.

  • Workmen aren’t allowed to conduct, take part or initiate any strike that is deemed to be illegal under the ID Act,1947.[14] Participation in such illegal strikes can lead to termination of services of employee by employer.
  • Workmen too have certain constraints with respect to Unfair labour practices and hence need to ensure that they do not indulge. In such activities lest they become liable under Unfair practices.
  • Workmen aren’t allowed to compel any other workmen for joining a trade union or supporting a trade union for a particular cause. Every employee has the right to choose whether he wants to be part of a certain union or not, and cannot be forced or threatened into joining any union.
  • Recognized trade unions are supposed to act in good faith when collectively bargaining and can’t refuse to bargain based on irrelevant and petty grounds.[15] The focal objective of collective bargaining is to reach an suitable solution and this can only be done if both parties, i.e. workers and employers come together and deliberate & discuss the problem at hand.
  • No worker’s or trade unions are allowed to interfere with the employers or exhibit their support at the residence of the employer. There needs to be a difference between personal and professional life .
  • Inciting of violence in workplace and destruction to property or goods of the industry and workmen will come under the ambit of unfair trade practices.
  • No workmen shall preclude another from working by use of physical force or intimidation.

Leading Case Laws In India With Respect To Unfair Trade Practices

HD Singh vs Reserve Bank of India[16], in this case the Reserve Bank of India had delivered a confidential circular directing the officers that workmen like the appellants shouldn’t be engaged uninterruptedly but should as far as possible be offered work on rotation basis. The SC in this case held that RBI indulged in methods which amount to unfair labour practice.

Kapurthala Central Co-op Bank Ltd vs Presiding officer, Labour court, Jullundur [17]: A division bench of Punjab and Haryana High Court held that the cessation of the service of the workmen on completing 230 days of period, despite that their work was adequate and satisfactory, disabling them from completing 240 days as required by Sec. 25B Industrial Disputes Act with a view to deprive them of the safeguard of Sec 25F amounts to unfair Labour practice mainly so when other persons were employed in their place.

Resident Engineer, Rajasthan SBCC ltd vs Om Prakash[18]: A single judge of Rajasthan High Court held that if the labor was not of a perpetual nature and the project was likely to be completed after some time then it could not be held that giving recurrent appointment letters for each tenure is Unfair Labour Practices under sec. 25T of the ID Act, 1947.

Unfair Labour Practices in Pakistan

Labour law in Pakistan

Pakistan’s labour regulations are based on legislation inherited from India at the time of the Indo-Pak subcontinent’s division. The laws have developed over time to meet changing socioeconomic situations, industrial development, population and labour force explosions, trade union growth, literacy levels, and the government’s commitment to development and social welfare. To achieve the aforementioned goals, the Islamic Republic of Pakistan’s government has implemented a number of labour policies since its independence to reflect the country’s transition from martial law to democracy.

Under the Constitution labour is regarded as a ‘concurrent subject’, which means that it is the responsibility of both the Federal and Provincial Governments. However, for the sake of uniformity, laws are enacted by the Federal Government, stipulating that Provincial Governments may make rules and regulations of their own according to the conditions prevailing in or for the specific requirements of the Provinces. The total labour force of Pakistan is comprised of approximately 37.15 million people, with 47% within the agriculture sector, 10.50% in the manufacturing & mining sector and remaining 42.50% in various other professions.

Pakistan Industrial Relations Ordinance, 1969

This ordinance takes effect to revise, consolidate, and rationalise the law governing the creation of trade unions, the regulation and improvement of employer-worker relations, and the avoidance and resolution of any problems or conflicts that may arise between them. WHEREAS, it is necessary to revise, consolidate, and rationalise the laws governing the creation of trade unions, the regulation and improvement of employer-worker relations, and the prevention and resolution of any problems or conflicts that may arise between them. Furthermore, section 15 and 16 of this act deals with the Unfair labour practices on the part of Employer and on the part of workmen, Same is discussed in detail below.

In accordance with section 15[19] of the aforementioned act No employer or employer’s trade union may impose any condition in a contract of employment that restricts a person’s ability to join or leave such employment or the Union. Furthermore, no discrimination should be made by an employer against any individual in regard to employment, advancement, working conditions, or pay based on the fact that the person is not a member of a union. Employer’s abilities to threaten, harm, fire, discharge, or remove a worker from employment because the worker wishes to organise a trade union or is promoting a particular trade union are likewise limited.

Similarly as per section 16[20] of the said act No workman or trade union of workmen shall persuade a workman to join or refrain from joining a trade union. Moreover, no workmen can intimidate any person to become, or refrain from becoming a member of a trade union. Furthermore, a worker cannot compel an employer to accept a demand using intimidation, coercion, pressure, threat, confinement to or expulsion from a location, dispossession, violence, physical injury, or the disconnection of telephone, water, or electricity utilities, among other ways.

Case study on Unfair Labour Practices in Pakistan.

Lahore garment factory

Millions of employees in Pakistan’s garment industry are currently victims of exploitation and abuse. In recent years, these unseen laborers have made infrequent appearances in the national media, nearly usually for the wrong and frequently disastrous reasons. Workers from Khaadi, a famous Pakistani apparel brand, staged nationwide protests in May 2017, bringing attention to the country’s critical and widespread garment industry concerns. Khaadi fired 32 workers after they demanded their rights under Pakistani law, which sparked the riots. Hundreds of workers were fired indiscriminately, working conditions were unclean, working hours were excessively long, and wages were below the statutory minimum wage.[21]

Ali Enterprises garment factory, Karachi

The worst industrial tragedy in Pakistan’s history occurred on September 12, 2012, when a fire at the Ali Enterprises garment factory in Karachi killed at least 255 people and injured more than 100 more. A multitude of anomalies were discovered, as well as an almost complete lack of fire and safety systems. Survivors claim that management did not make prompt steps to save the workers, preferring instead to save their merchandise.

Analysis

On close perusal one can identify how both the Countries have very similar provisions with respect to tackling Unfair Labour Practices, the only difference is in the operation of each act and type of industries that come under the particular acts. The Industrial Disputes Act, 1947 extends to the whole of India and regulates Indian labour law so far as that concerns trade unions as well as Individual workmen employed in any Industry within the territory of Indian mainland.

While in case of Pakistan, all essential labour laws should be revised by the Pakistani federal and provincial governments to guarantee compliance with key international labour standards. Pakistan’s Industrial Relations Act of 2012, as well as provincial laws, fall short of ILO requirements. International and domestic companies that manufacture in Pakistan should make supplier factory lists public, join collective brand initiatives, and develop grievance redress procedures for all workers, with workers’ freedom of association incorporated as a core part of all binding and non-binding brand agreements.

Conclusion

Despite the fact that there are several health concerns in the textile industry, the government has showed no interest in protecting the health of these workers. The attitude of India’s Ministry of Textiles shows that it is more concerned with capital than with worker welfare. It is obvious that the textile industry generates more profit and foreign cash for India, so in order to increase productivity, one must also focus on worker protection and welfare. Focusing solely on capital investment while providing no incentives or safeguards for labour generates no results.

Unfair Labour practices are still prevalent in a lot of industries and in the researcher’s opinion the existing laws with respect to tackling such practice is appropriate however implementation needs to be focused on in both countries. Therefore, as per the above discussion, we come to the conclusion that every kind of unfair labour practice disturbs and leaves an impact on the industrial relation which, in turn, disturbs the industrial peace and ultimately industrial productivity is affected. It is not only connected with the employer and employees but the community as a whole. Therefore, for the sake of the community unfair labour practices must be stopped.

[1] Fundamentals: Insights into working conditions in India’s garment industry, International Labour Office, Fundamental Principles and Rights at Work (FUNDAMENTALS)- Geneva: ILO,2015 ISBN:978-92-9-129808-3(Print);978-92-2-129809-0(Web PDF), accessed on: 19.04.2022, at 5.00pm.

[2] “Public utility service” means-

(i) any railway service 5[or any transport service for the carriage of passengers or goods by air;]

6[(ia) any service in, or in connection with the working of, any major port or dock;]

(ii) any section of an industrial establishment, on the working of which the safety of the establishment or the workmen employed therein depends;’

(iii) any postal, telegraph or telephone service;

 (iv) any industry which supplies power, light or water to the public;

(v) any system of public conservancy or sanitation;

(vi) any industry specified in the 7[First Schedule] which the appropriate Government may, if satisfied that public emergency or public interest so requires, by notification in the Official Gazette, declare to be a public utility service for the purposes of this Act, for such period as may be specified in the notification:

 Provided that the period so specified shall not, in the first instance, exceed six months but may, by a like notification, be extended from time to time, by any period not exceeding six months, at any one time, if in the opinion of the appropriate Government, public emergency or public interest requires such extension;

[3] ‘factory’ means “any premises including the precincts thereof –

(i) whereon ten or more workers are working, or were working on any day of the preceding twelve months, and in any part of which a manufacturing process is being carried on with the aid of power, or is ordinarily so carried on, or

(ii) whereon twenty or more workers are working, or were working on any day of the preceding twelve months, and in any part of which a manufacturing process is being carried on without the aid of power, or is ordinarily so carried on; but this does not include a mine subject to the operation of the Mines Act, 1952 , or a mobile unit belonging to the armed forces of the union, a railway running shed or a hotel, restaurant or eating place.”

[4] “Employer” means-

(i) In relation to an establishment which is a factory, the owner or occupier of the factory, including the agent of such owner or occupier, the legal representative of a deceased owner or occupier and, where a person has been named as a manager of the factory under clause (f) of sub-section (1) of section 7 of the Factories Act, 1948 (63 of 1948), the person so named; and

(ii) In relation to any other establishment, the person who, or the authority which, has been ultimate control over the affairs of the establishment, and where the said affairs are entrusted to a manager, managing directing or managing agent, such manager, managing director or managing agent. Schedule 1 to the Act provides for list of industries to which Central Provident Fund is applicable and such list have a mention of Textile Industries, which means that the Provident Fund Scheme can be made use of by the workers of Garment Industries.

[5] The employment compensation Act Assessed on  https://labour.gov.in/sites/default/files/EC%20Act.pdf.

[6] https://wcd.nic.in/schemes-listing/2405

[7] Guidelines for Group Insurance Scheme For Power loom Workers Assessed on  https://www.india.gov.in/group-insurance-scheme-powerloom-workers?page=1.

[8] Guidelines for Pilot Phase Of Textile Industry Workers’ Hostel Scheme

Assessed on http://texmin.nic.in/sites/default/files/final%20Workers_Hostel_Guidelines_Final.pdf.

[9] Neelam Singh, Safety and health issues in workers in clothing and textile industries, International Journal of Home Science 2019; 2(3): 38-40.

[10] N.U.K. Sherwani, Industrial Relations in India, Anmol Publishing Pvt. Ltd., New Delhi, 2000; 2.

[11] Kesar Singh Bhangoo, Dynamics of Industrial Relations, Deep and Deep Publications, New Delhi, 1995;.2.

[12] S.R. Mohan Das, Industrial Relations – The Coming Decades” Indian Journal of Industrial Relations. July 1990; 26(1): 80.

[13] C.K. Johri, “Industrial Relations as regulated by Law: Suggestions for Change”, Indian Journal of Industrial Relations, April 1996; 31(4) 440.

[14] N. U. K. Sherwani, Industrial Relations in India, Anmol Publishing Pvt. Ltd., New Delhi, 2000; 2.

[15] Sudha Deshpande and Lalit K. Deshpande, “Impact of Liberalization on Labour Market and Industrial Relations in India”, Indian Journal of Labour Economics, July -September, 1996; 39, (3):553.

[16] 1986 AIR 132

[17] 185 (2) 88. Pun.L.R.74

[18] (1999) ILLJ 1225 Raj

[19] Section 15, Industrial Relations ordinance, 1969.

[20] Section 16, Industrial Relations ordinance, 1969.

[21] “No Room to Bargain” Unfair and Abusive Labor Practices in Pakistan, Human Rights Watch, 2015. https://www.hrw.org/report/2019/01/24/no-room-bargain/unfair-and-abusive-labor-practices-pakistan.

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