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Conceptual Analysis On Child Labour Protection Act, 1986

Children square measure perpetually thought-about next to the pious versions of the Almighty UN agency perpetually attempt to drill happiness, joy, innocence and hope. the long run of a nation is set by the means it treats its child's and its ladies, after all, child's imply a hope, a hope to strengthen not solely the economy of the country, however conjointly to supply the country with virtuoso human resources UN agency have access to the fundamental amenities essential for the existence not to mention the tenets of the education in Asian country.

A child mustn't be subjected to figure at the expense of his or her education and dreams. Child labor robs minors of the chance to relish their childhood, visit college, and have a good shot at success. It condemns them to a lifetime of restricted opportunities. It is, therefore, necessary to confirm that each child is protected and not exploited for reasonable labor.

It's not simply the responsibility of the bogeys to eliminate child labor however conjointly that of the govt and also the society because it is that the ethical duty of each subject for the country to confirm that the childhood of our child's is protected and not barred with instances like that of child labor that arise out of poorness and helplessness. The paper focuses on numerous problems relevance} child labor at the side of reference to some judicial pronouncements.

The Child has been the topic of special laws and legal provisions. Thanks to its tender years, weak body, and inadequately developed mind and understanding, each child wants protection against ethical and physical damage and exploitation by others. within the childhood of its life, the child wants special care service to comprehend its full potential for growth and development. There square measure regarding three hundred Central and State Statutes regarding child's.

These are enacted with Associate in nursing intention to guard and facilitate children and reach the goal of child labor welfare enshrined in our National charter. More these laws square measure applicable to child's in numerous spheres of life, that square measure regulative, protecting and punitive in nature.

Laws square measure seeking to guard and promote the rights of child. Beneath the law, child's square measure entitled to special care, help and essential wants and that they ought to lean the best priority within the allocation of resources. The paper aims in analyzing child labor from numerous views by bearing on some judicial pronouncements by shaping the term child labor from numerous viewpoints and analyzing numerous Articles in Indian Constitution for defence of child Rights.

Null- the present legislation's aren't enough to forestall child labor. Alternate - the present legislation's square measure enough to forestall child labor.

Research downside
The existing legal framework isn't enough to prevent the activity of child Labor thanks to Inefficiency of statutes

Research Question
  • Whether the present framework is enough to forestall the activity of child Labor?
Research sources
In this paper, the investigator has opted the sources square measure primarily collected through secondary knowledge like books, journals and numerous e-sources.

Factors accountable for child Labor
There square measure many reasons concerning causes and abuse of child labor in Asian country. Indian Socioeconomic condition of is such it provides bedrock for the event of child labor in several forms.

A number of the necessary factors are:
  1. Economic Factors:
    poorness is that the root reason for child labor in Asian country that square measure thanks to numerous reasons like unequal distribution of land property and assets. Economic compulsions produce pressure on poor oldsters to place their child's for physical exploitation in early age of life.
  2. Poor Implementation of Law:
    energetic perspective of implementation Agencies also are the most cause main cause for this Evil. Whether or not it's agricultural or industrial atmosphere, the child exploitation is frequent. As re portable by the Committee on the child labor in 1980 is that the worker initial, worker child labor as a result of their accessible on reservation jealous standing Kansas affliction my feeling of guilt and shame No he station to try to to during a standing even be that means job. National Commission of labor conjointly got wind that very often it's a sense of sympathy instead of the will 828 that weight inside players in implying child work.
  3. Cast directed Society:
    class structure is deeply decayed in Asian country and also the most of the ancestral work is administrated by one cluster. There's bound business that is administrated by a specific cluster. In our society bound 'goods trade square measure associated with a specific community and youngsters starts learning regarding the trade from these elements solely.
  4. Lack of Awareness:
    Lack of awareness of the fogeys and guardians also are one in every of necessary cause for child labor. The importance of education in long run isn't proverbial to folks so that they target short term profit through swing their child aborning force
  5. Early Marriages:
    Marrying at Associate in nursing early age may be a chief contributory component to over population. Young mother and father square measure capable of sire an entire heap of child's thanks to the very fact they keep fertile for a protracted time. Having several youngsters with little or no resources to support those ends in child labor. Older youngsters square measure forced to figure so you'll assist their mother and father facilitate the circle of relatives.
In addition to on top of, there square measure different many causes like population, lack of Social Security in family, social acceptance of learning parental business and lacuna in child labor relating law.

Concept of Child Labor
The general plan of child at international level is that a baby suggests that every individual below the age of eighteen years unless at a lower place the law applicable to the child, majority is attained earlier (Article one. child Conventions, 1989). This Convention protects varied kinds of rights in conjunction with human rights of the children. But at national level, utterly completely different statutes or legal texts have followed different cohort for outlining kinds of child's.

This variation is manly supported the subject matter jurisdiction of the relevant statutes. The Constitution of Asian country acknowledges child up to the age of fourteen years in Article 21A, twenty four and 51(k). The child Labor (Prohibition and Regulation) Act 1986 acknowledge fourteen years where as a result of the Juvenile Justice (Care and Protection) Act 2000 keep the regulation eighteen years. The ultimate analysis suggests that fourteen years is regulation at no cost education and prohibition of any type of labor and eighteen years is for complete criminal liability.

Not all work done by child's need to be classified as child labor that is to be targeted for elimination. Children's or adolescents' participation in work that does not have an impact on their health and personal development or interfere with their schooling is sometimes thought to be being one factor positive.

This includes activities like serving to their people around the home, aiding in an exceedingly} very in private control corporation or earning currency outside school hours and thru school holidays. These kinds of activities contribute to children's development and to the welfare of their families; they provide them with ability's and skill, and facilitate to prepare them to be productive members of society throughout their adult life.

According to International Labor Organization, the term child labor is sometimes printed as work that deprives children of their childhood, their potential and their dignity, that is harmful to physical and mental development.

It refers to work that:
  1. Is mentally, physically, socially or virtuously dangerous and harmful to children; and
  2. Interferes with their schooling by;
  3. Depriving them of the prospect to attend school;
  4. Obliging them to depart school prematurely; or
  5. Requiring them to aim to combine school human activity with too long and important work.
In its most extreme forms, child labor involves child's being confined, separated from their families, exposed to serious hazards and sicknesses and/or left to support themselves on the streets of huge cities usually at an awfully early age. whether or not or not or not specific sorts of work are usually remarked as child labor depends on the child's age, the kind and hours of labor performed, the conditions at a lower place that it's performed and thus the objectives pursued by individual countries. The answer varies from country to country, still as among sectors at intervals countries.

The Issue of Child Labor in Asian Country
The child labor could also be a sophisticated and a polemic downside. The lifestyles and continuance of child labor could also be a challenge to the human society. Its miles honestly a curse and stigma upon the society; shame for the theater of cluster, a malady which can together spoil the economic backbone of a rustic. The practice of infant would be degree impediment inside the way of human development within the majority the 0.33 world countries beside Asian country.

The matter of child labor is one in every of essential human rights issues and a rather affection one. The matter of nestling labor in underdeveloped and developing international locations is pretty acute and a typical and it's miles a worldwide development that exists within the majority of the nations of the globe, but there is distinction solely in degree.[1] One inside the past, child labor has been a district of the structure inside that all members contributed their labor to produce for the subsistence and survival.[2]

In rural farming, the paintings of the child become formal a district of labor, that become needed for the duplicate of the machine and price of labor taken as an area of infant's socialization for copy of the labor power. The event of child labor could also be an indication of the disorder associate de greed associate degree outcome of consumptive gizmo, running on the national and international stages.

Constitutional Provisions
The makers of Constitution were visionary to provide, that child's need to receive distributive justice in free Asian country. The rights against exploitation were mentioned inside the draft planned by Dr. B.R. Ambedkar, K.M. Munshi and K.T. Shah. While Dr. Ambedkar's draft just on condition that subjecting somebody to forced labor or involuntary bondage would be degree offense, K.M. Munshi's draft Article counseled for abolition of all sorts of slavery, child labor, traffic in blood line and obligatory labor.[3]

Constitution of India contains provisions in Part III and Part IV of the Constitution. Several Articles protect rights of the children in various ways.

Article 23
Prohibits traffic in human being and other similar forms of forced labor.
Article 24
No child under the age of 14 years shall be employed to work in any factory or mine or engaged in any other hazardous employment
Article 39
Article 39(e) and (f) requires the State and secure that the tender age of children are not abused and to ensure that they are not forced by economic necessity to enter avocations unsuited in their age or strength.
Article 45
Free and compulsory education for all children until they complete the age of 14 years.
Article 51 A (k)
Fundamental duty of the parent or Guardian to provide opportunities for education to the child or ward between the age of 6 and 14 years.
Article 21-A
The Right to Education as fundamental right and it mandates that, the state shall provide free and compulsory education to all children of age of six to fourteen years in such manner as the state may, by law, determine.

These constitutional provisions have played fundamental role in the development of law relating to child.

Legislation and Policies relating to child Labor in Republic of India
Legislation to regulate and regulate child labor in Republic of India has existed for many decades. the most concern of those legislation's was prescribing minimum regulation for employment of youngsters and regulation of operating hours for children; and making certain the health and safety of the child labourers by prohibiting the use of youngsters in venturesome work. There square measure variety of child labor legislation's prohibiting the use of youngsters below fourteen years and fifteen years in sure specific employments like factories, mines, shipping, transport etc.

 However, contrary to our international commitment and every one proclamations within the country's Constitution, and despite all the legislative measures, child labor may be a harsh reality. Thanks to lack of political can and in absence of realistic measures to tackle the matter the share of child labor within the total working class of the country unbroken on increasing over the years.

Large numbers of legislation were enacted since 1881 that provides the legal protection to the operating child's. The children (Pledging of Labor) Act, 1933 followed by the use of youngsters Act, 1938 was the primary statutory enactment handling child labor that was repealed by the child Labor Act, 1986. The Child Labor (Prohibition and Regulation) Act 1986 is an outcome of varied recommendations created by a series of Commissions. This legislation was enacted to reform the legal live, because the policy of each Prohibition of child labor in venturesome trade and regulation in different kinds of industries.

The important laws relating to child labor are listed below
  1. The Children (Pledging of Labor) Act,1933
  2. The Employment of Children Act,1938
  3. The Minimum Wages Act,1948
  4. The Plantation of Labor Act,1951
  5. Factories Act, 1948
  6. The Mines Act,1952
  7. The Merchant Shipping Act,1958
  8. The Motor Transport Workers Act,1961
  9. Beedi and Cigar Workers (Conditions of Employment) Act,1966
  10. Contract Labor (Regulations and Abolition) Act,1970
  11. Shops and Commercial Establishment Act,1948
  12. Radiation Protection Rules,1971
  13. The Child Labor (Prohibition and Regulation) Act,1986
The main legislation for the prohibition of child labor is the Child Labor (Prohibition and Regulation) Act, 1986 which will be analyzed in detail and the role of judiciary will also be discussed in the light of said Act.

The Child Labor (Prohibition and Regulation) Act, 1986
Various legislation's were enacted since 1881 for more and more extending legal protection to the operating child's. The children (Pledging of Labor) Act, 1933 followed by the use of Employment Children Act, 1938 was the primary statutory enactment handling child labor, was repealed by the Child Labor (Prohibition and Regulation) Act 1986.

It absolutely was associate outcome of varied recommendations created by a series of Commissions like Gurupad swamy Committee on Labor 1976 and Sanat Mehta Committee 1984. These commissions were habitual to reform the legal live, because the policy of each Prohibition and Regulation. Finally a protracted expected.

The statement of objects and reason within the Act say that there are varied legislation's that fully command employment of child's below fourteen years and fifteen years in sure specific employments. However, there's no special procedure set down in any law for deciding within which employments, occupations or processes the use of child's to be illegal. There's additionally no law to control the operating conditions of child's in most of the employments wherever they're not prohibited from operating and are operating underneath consumptive conditions.

The Act objectives to:
  • Ban the use of child's, i.e. those that haven't completed their fourteenth year in specific occupations and processes
  • Lay down a procedure to come to a decision modifications to the schedule of illegal occupations or processes;
  • Regulate the conditions of labor of child's engaged in varieties of employment within which they're permissible to work;
  • Prescribe increased penalties for employment of child's in violation of the provisions of this Act and different Acts that forbid the use of children; and
  • Establish uniformity within the definition of child in laws regarding them.

The introduction of the Bill generated an energetic discussion within the Indian Parliament within which members cutting across party affiliation debated and provided rare insights into this old social issue. In course of the controversy the members particularly took exception to the following:

The condition in Section three says, provided that nothing during this section shall apply to any workshop whereby any method is carried on by the occupier with the help of his family or to any faculty established by or receiving help or recognition from Government.

The members had additionally expressed apprehensions and reservations relating to the following:
  1. Past expertise shows that labor laws are never enforced. the child Labor (Prohibition and Regulation) Act had additionally became yet one more exercise in futility;
  2. Unsafe work doesn't become safe just as a result of it's performed at home;
  3. Any theme of exemption provided in a very law is certain to be misinterpreted and misused;
  4. The intention of state shouldn't be to regularize child labor just as a result of it exists; and
  5. A one sided and half-hearted approach of forbiddance child labor in few institutions and control it in few others while not adopting a holistic or integrated approach, while not resolution the matter of poorness and economic deprivation, while not implementing the Minimum Wages Act, while not resolution the matter of universal entrance and retention of all child's of school-going age within the formal establishment can serve very little purpose.
The apprehension and reservations expressed by the members were real and still be valid to the present day.

The main options of the current Act are as follows:
  1. It prohibits employment of child's in most employments as careful within the Schedule as Processes and Occupations. Most of them are unsafe in nature however the term unsafe has not been defined;
  2. It intends to control employment of child's altogether institutions except those prohibited ones;
  3. It provides for a baby Labor Technical consultative Committee to advise the Central Government in matters of additional prohibition, regulation etc.
  4. Restrictive provisions created fixing the quantity of hours, amount of labor, prohibition of overtime, double employment, provision of weekly holidays etc.;
  5. Demand of the leader to grant notice to Inspectors, maintenance of register, show of notice; provision for health and safety also are partially III;
  6. It provides for minimum penalty of imprisonment for three months and most one year and minimum fine of Rs. 10,000 and most fine of Rs. 20,000. most the violations of the restrictive and obligatory provisions are declared as offense underneath the Act; and
  7. Any one will file a criticism however solely a Metropolitan functionary will take cognizance of any offense.

Significant Provisions of the child Labor (Prohibition and Regulation) Act, 1986
The Act is split into IV parts and carries twenty six sections with one agenda consisting of Part-A for Occupations and part-B for processes. The preamble to the Act, states that its miles ―An Act to limit the use of child's in positive employments and to regulate the conditions of labor of the children in sure totally different employment.

The Act prohibits the use of anyone United Nations agency has not completed his fourteenth year[4] aged in occupations and procedure set forth partially A[5] and component-B[6] vi of the program of the Act. The prohibition below part II, section three is not absolute because it will not observe to any workshop whereby any manner is carried on by suggests that of the occupier with the helpful resource of his family or to any faculty established by method of, or receiving help or recognition from government.

Critical Analysis of Child Labor (Prohibition and Regulation) Act, 1986
Any law isn't while not defect and also the same with this Act. the children Labor Act was passed with the Article of achieving 2 contradicting goals i.e. prohibition and regulation of children labor that isn't in conformity with Article twenty four of Constitution and also the Act is in favour of regulation instead of conclusion of Child Labor.

Another major disadvantage is that the absence of any measures for rehabilitation of the child. The stipulation annexed to section three is abused by using children in respect of families and work expertise non heritable by children's. This stipulation helps leaders to create as members of the family of the youngsters operating in their premises and so continued to use the children; this is often however the employer escapes from prosecution. Thus burden of proof is to be fastened on the occupier to prove that the children may be a member of his or her family.

In addition to the current the age of the children has been otherwise outlined in numerous laws. There's no a criterion or scientific parameters for outlining the age of the children so laws results in confusion and uncertainty. The definition of children's given beneath Child Labor (Prohibition and Regulation) Act, 1986 is in contradiction with international organization Convention on the Rights of the child, 1989 and Juvenile Justice (Care and Protection of Children) change Act, 2006. Article 24 of the Constitution indirectly permits the child labor as a result of Article 24 reads;

No child below the age of fourteen years shall be used to figure in any plant or mine or engaged in the other unsafe employment.

By reading on top of Article twenty four it's ascertained that Constitution of India doesn't produce associate degree absolute bar to the use of children below the age of fourteen years. Their employment is prohibited solely in plant or mine or in the other unsafe employment. Children below the age of fourteen years shall be used to figure all told institutions apart from plant or mine or unsafe employment.

Numerous laws and policies regarding child labor and child rights seem to figure in isolation. There's no nexus between one another. The correct to education failed to have direct bearing upon the children labor law. Policy views regarding children's and childhood square measure confused. The correct of child to Free and required Education Act, 2009 supposed to supply free and required education all the youngsters of the age 6-14 years. However beneath Child Labor (Prohibition and Regulation) Act, 1986 egg laying down that children's below fourteen years will add non-hazardous occupations and processes may be a mockery in providing justice to the youngsters.

The president of National Commission for cover child of Rights aforementioned The child labor policy itself is imperfect and existing child labor law was violating the basic right to education. So there's a necessity to amend the Act to create it in consonance with the correct to Education (Kavita Chowdhary 2009). The definition of children labor has to embrace children's operating within the farm-lands. The laws and policies currently ought to indicate to the international standards ordered down within the U.N. Convention on the Rights of the children.

Court Cases
  1. Andhra High Court- P. Ramachander Rao Vs State of Andhra Pradesh on 18 March, 2006, THE HON'BLE Dr. JUSTICE G. YETHIRAJULU Criminal Petition No.793 of 2004
  2. Hemendra Bhai Vs State of Chhattisgarh on 6 January, 2003, Equivalent citations: 2003 (97) FLR 402, (2003) IILLJ 645 CG Bench: K Kuranga C.J
  3. Madhya Pradesh High Court- Bhagwandas and Anr. Vs State Of M.P. and Anr. On 9 July, 1998, Equivalent citations: (2000) IIILLJ 661 MP Bench: S Srivastava
  4. Madhya Pradesh High Court- Bhaiyalal Shukla and Ors. Vs State Of M.P. And Ors. On 12 March, 1999 Equivalent citations: (2000) ILLJ 640 MP Bench: C Prasad
  5. Madhya Pradesh High Court-Raj Homes Pvt. Limited Vs State Of M.P. and Anr. on 4 December, 2002, Equivalent citations: (2003) IIILLJ 626 MP Bench: A Mishra
  6. Allahabad High Court-Basudeo Lal Srivastava (D).... Vs Punjab National Bank on 18 March, 2004, Equivalent citations: 2004 (2) AWC 1871 Bench: T Agarwala
  7. Allahabad High Court-Mahesh Kumar Garg and Ors. Vs State Of U.P. And Ors. On 11 April, 2000, Equivalent citations: (2000) 2 UPLBEC 1426 Bench: P Kant
  8. Allahabad High Court-Matrumal Sharma and Anr. Vs the Chief Inspector of Shops And ... on 25 March, 1952, Equivalent citations: AIR 1952 all 773Bench: Misra, Beg

In spite of several legislative measures by enactment of statutory provisions to diminish employment of kids in hazardous employment and people injurious to health, the exploitation of youngsters through different profit makers for their non-public profits persisted unabated in utter disregard of constitutional injunction and statutory prohibition. From the evaluation of the relevant statutory provisions of the Indian laws regarding child labor, it has emerge as abundantly clear that the statutes range as to the age restriction of an infant hired or authorized to work in diverse occupations. There may be no law solving minimum age for employment of youngsters in agriculture.

The Factories Act, 1948, fixes minimal age of 14 while the worldwide Labor enterprise conference prescribes minimum age for any employment to be 15. Inside the case of plantations, the age of employment has be non- business employment the minimal age varies from 12 to 14 years.

Consequently, Indian legal guidelines relating to baby labor are poor from the global standards as laid down through the global Labor employer however even then they can be considered first-class in view of the everyday financial situations of the country. There are plethora of statutes[7] to save the misuse of children in dangerous employment and to shield the general rights of the children. But sociological studies have discovered either the useless nature of these legal guidelines or their blatant violations.

Mockingly overall laxity prevails the enforcement of the provisions with no longer a great deal proof of conviction. The entire Abolition of child labour and proper regulation thereof in accordance with the statutory provisions need to be the cherished and prime objective of a civilized society. It is also pertinent to country that the Judiciary played a sizable role in protection of child labors. Many course breaking judgments of the perfect court docket have performed a fantastic deal by increasing the human rights doctrine.

The obligation for imparting this training is that of the organization. Judiciary in India played a very substantial position in upholding child welfare rights. It has taken the lead to save the child from exploitation and enhance their situations. Judicial mandate definitely demonstrates that proper to education is important for the proper flowering of children and their character.

Hence the judiciary has always made concrete efforts to safeguard them towards the exploitative inclinations of their employers, by means of regularizing their working hours, fixing their wages, laying down guidelines approximately their health and medical facilities.

The judiciary has even directed the states that it's miles their responsibility to create an environment where the kid people can have opportunities to grow and expand in a wholesome manner with complete dignity in consensus of the mandate of our charter. Hence, it's implied that hypothesis disproved that the existing legislation's are not sufficient to prevent child labor. It's the judiciary that plays an important role in shaping the lives of children.

It may be accepted that trying to enforce law through labor inspectors is not likely to yield results because law itself has loopholes that can easily take advantage of. Very recent effort of the Central Government to enhance penalty through further amendment of the law is likely to yield the same result. Adopting the principle of compulsory elementary education for the children of age group 6 to 14 along with compulsory vocational training cum education for children of age group 14 to 18 who are participating in working market may be the way out to solve child labor problem permanently.

To eradicate the problem of child labor permanently notion of penalty oriented law or enhanced penalty to be supplemented by the incorporation of the principle of compulsory education, both formal as well as vocational as a compulsory duty on the part of the employer. It should be introduced into legal system. Emphasis should be given upon village areas. The panchayati raj system could be made responsive to put primary education on their agenda for development ensuring universal literacy program as measure to eradicate child labor.

Non-governmental organizations can play a bigger role in identifying and monitoring units where child labor is used and at the same time acting as pressure group stressing the importance of education. With increasing globalization and integration with the world economy, India should gear towards adoption of modern technology with skilled labor forces to compete with global market players.

A child cannot enter into a contract of employment until he/she attains 18 years of age whereas a child may be engaged in work after he/she attains the age of 14 years. On the other hand, the right to receive compulsory elementary education is restricted to the age group 6 to 14 which means after 14 years a child may stop education and enter into a work/ economic activity in need, thereby, the employment of the children from 14 to 21 as a labor is legal and permitted subject to certain legal guidelines.

This is the most controversial area of law, which affects the fate of millions of children in India. Therefore, law needs to be amended and uniform age criteria i.e. 18 years to be prescribed for work permit in order to abolish the child labor keeping pace with the age of majority as per Indian Majority Act.

The stereotypical thinking that poverty is the only root cause of child labor is not supportable always. The social attitude should be changed and strong political will is the need of the hour to address the issue.

  1. Sen, R.K. & Dasgupta, A., 2003. Problems of Child Labour in India, Deep and Deep
  2. Publications.
  3. Bajpai, A., 2018. Child Rights in India: Law, Policy, and Practice, Oxford University Press.
  4. Bajpai, A., 2006. Right Against Economic Exploitation Child Labour. In Child Rights in India. Pp. 148 206.
  5. Basu, K., Child Labour and International Labour Standards. In The Retreat of Democracy and
  6. Other Itinerant Essays on Globalization, Economics, and India. pp. 21 30.
  7. The Children Act, 1960, Juvenile Justice Act, 1986, the Child Labour (Prohibition and Regulation) Act. 1986 etc.
Web link:
  1. [Accessed April 1, 2021]
  2. [Accessed April 5, 2021]
  3. [Accessed April 7, 2021]
  4. [Accessed April 7, 2021]
  1. Small Hands Hard Labour in Surat Textile[1] Industry, 17, December, 2013
  2. Nirmal .Mitra, ―The Slave Children of Mandsour Sunday 8, 14th December, 1980
  3. The framing of Indian Constitution  A study, Vol.V
  4. Child Labour Act, 1986; Sec. 3, ― No child shall be employed or permitted to work in any of the occupations set forth in part A of the Schedule or in any workshop wherein, any of the processes set forth in part B of the schedule is carried on.
  5. There are 15 occupations set forth in part-A of the schedule under section 3. Further employment of child as servants or workers and employment of children in Dhabas, ( roadside Eateries), restaurants, hotels, Motels, Tea -Shops, Resorts, Spas or other recreational centres are notified on 10th July, 2006
  6. There are 57 processes set forth in part-B of the Schedule
  7. The Children Act, 1960, Juvenile Justice Act, 1986, the Child Labour (Prohibition and Regulation) Act. 1986 etc.

    Award Winning Article Is Written By: Mr.Deepak Subhashappa Sangekar
    Awarded certificate of Excellence
    Authentication No: SP35671227421-03-0921

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