Rehabilitation Delayed May Amount to Rehabilitation Denied: Supreme Court Issues Nationwide Directions for Bonded Labourers

The Supreme Court has held that the State’s duty towards bonded labourers does not end with their rescue, observing that delay in rehabilitation may, in substance, amount to its denial. It issued nationwide directions fixing timelines for release certificates, immediate financial assistance and rehabilitation of rescued bonded labourers.

A Bench of Justice Vikram Nath and Justice Aparesh Kumar Singh directed uniform implementation of a revised Standard Operating Procedure across all States and Union Territories. The Bench kept both writ petitions pending to monitor compliance.

Background: Rescued in 2019, Paid in 2022

The first petition was filed under Article 32 by Surendra Manjhi, a survivor of bonded labour. He was rescued with several others from a brick kiln in District Shahjahanpur, Uttar Pradesh, on 28.02.2019. The labourers had been taken from their native districts in Bihar on the pretext of repaying a bonded debt and were allegedly subjected to exploitative working conditions.

Manjhi received immediate financial assistance under the Central Sector Scheme for Rehabilitation of Bonded Labourers only in 2022, nearly three years after his rescue. According to the rejoinder, of 42 labourers issued release certificates, only 25 received ₹20,000 each, while 17 were still awaiting payment. The State of Bihar also pointed out that some release certificates issued by Uttar Pradesh authorities were not in the prescribed format.

A second petition, filed by the National Campaign Committee for the Eradication of Bonded Labour and others, raised broader concerns about the continued prevalence of bonded labour and weak implementation of the Bonded Labour System (Abolition) Act, 1976. It was tagged with the first petition on 18.08.2026.

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The Court considered the Union of India’s compliance affidavit dated 15.05.2026, suggestions submitted by Petitioner No. 2, Bachpan Bachao Andolan, and the submissions of Attorney General for India R. Venkatramani and Advocates Abhishek Jebaraj and Sanjana Grace Thomas, appearing for the petitioners.

Supreme Court on Rehabilitation of Bonded Labourers

Opening the judgment, the Court observed: “Freedom from bondage, however, cannot be secured by the act of rescue alone.”

The Bench noted that the problem was not the absence of a legal framework but its implementation. It held: “The release of a bonded labourer cannot be treated as the completion of the State’s obligation when the conditions necessary for a life of dignity remain unfulfilled.”

Referring to Manjhi’s case and the 17 unpaid labourers, the Court said: “These circumstances demonstrate that rehabilitation delayed may, in substance, amount to rehabilitation denied.”

On inter-State rescues, the Court held that “the entitlement of a rescued labourer cannot be made dependent upon differences in administrative practices or jurisdictional arrangements between States.” It also held that immediate assistance ought not to be withheld merely because investigation or criminal proceedings are pending.

The Court described the proceedings as non-adversarial, noting that the petitioners, the Union, the States and other stakeholders share the common objective of eradicating bonded labour.

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Key Directions

  • Uniform SOP: All States and Union Territories must implement the revised SOP dated 14.05.2026 within six months. The Union must issue supplementary guidelines, in consultation with the NHRC, within three months.
  • Release certificates: Complaints are to be verified ordinarily within 24 hours, and release certificates issued ordinarily within 24 hours of identification, in a language the rescued persons understand. The Union will prescribe a uniform format recognised by all States.
  • Financial aid: Immediate assistance is to be disbursed ordinarily within seven days of the release certificate, and an individual rehabilitation plan prepared within 90 days of rescue.
  • Scheme revision: The Union must decide within three months on proposed revisions, including enhanced assistance and interim subsistence support.
  • Inter-State coordination: Every State and UT must designate a nodal officer within six months. No dispute between States shall delay payment to an eligible beneficiary.
  • The 17 labourers: Uttar Pradesh and Bihar must jointly verify their status within one month and pay outstanding assistance preferably within three months, and in any event within six months.
  • Monitoring: The NAVJIVAN Portal is to be used for tracking cases, with monthly reviews by State-level Monitoring Committees and a district grievance officer to resolve complaints ordinarily within 30 days.
  • Children and follow-up: Child protection laws must be followed, and District Vigilance Committees must review rehabilitation for at least one year after release.
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Compliance Timeline

The Union of India must file a compliance affidavit within four months. States and Union Territories must comply within six months and file affidavits within two weeks thereafter. The matters will be listed after seven months.

Case Title: Surendra Manjhi & Anr. v. Union of India & Ors.

Case No.: Writ Petition (Civil) No. 511 of 2022 with Writ Petition (C) Diary No. 32325 of 2026

Bench: Justice Vikram Nath and Justice Aparesh Kumar Singh

Date: November 2, 2026

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