Bijay Cotton Mills Ltd. v. State of Ajmer
Rule established
Minimum Wages Act is constitutionally valid. Securing living wages is a reasonable restriction on freedom of trade under Article 19(6).
Facts
- Bijay Cotton Mills and other employers in Ajmer challenged the Minimum Wages Act, 1948
- Argued the Act violated Article 19(1)(g) (freedom to carry on trade/business) by compelling payment regardless of employer's financial condition
- Also argued it violated Article 14 (discriminatory: applied only to scheduled employments, not all industries)
Issues
- Whether the Minimum Wages Act, 1948 violates Article 19(1)(g)
- Whether fixing minimum wages without regard to employer's capacity to pay is constitutionally permissible
Held
- Act is constitutionally valid
- Securing living wages for labourers is in the interest of the general public
- Constitutes a reasonable restriction under Article 19(6)
- Legislature is competent to fix minimum wages even without considering individual employer's capacity to pay
Ratio Decidendi
The Minimum Wages Act is a valid exercise of legislative power and a reasonable restriction on the freedom of business under Article 19(6). The State's obligation to secure living wages for workers overrides an employer's claim to unfettered freedom of trade.
How to use it in an exam
- First authority to cite when asked about constitutional validity of minimum wages
- Pair with Crown Aluminium Works (1958) for the "no right to exist" principle
- Key line: "The Court upheld the Minimum Wages Act as a reasonable restriction under Article 19(6), holding that securing living wages is in the general public interest."
Source
Source: AIR 1955 SC 33
This is an educational summary, not the judgment itself. Cite the reported version in professional or academic work.