Purposive interpretation of contract labour law extends to construction work and upholds welfare and licensing safeguards.

A purposive reading of the contract labour welfare statute treats construction undertaken for an establishment's benefit as "work of the establishment," so the Act extends to contractors engaged for that work. The Court further accepted that welfare requirements, licensing conditions, fees, security deposit, forfeiture, inspection powers, and the power to remove difficulties are rationally connected to the statute's object of preventing exploitation and securing humane conditions, and therefore do not offend Article 19(1)(g) or amount to excessive delegation. The challenged provisions were upheld as constitutionally valid, and the challenge to the Act and Rules failed.

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Issues: (i) Whether contractors engaged in construction work for an establishment fall within the definition of contractor and whether the work is work of the establishment so as to attract the Act; (ii) Whether the provisions of the Act and the Rules, including welfare requirements, licensing fees, security deposit, forfeiture, and removal of difficulties power, are unconstitutional or amount to excessive delegation.

Issue (i): Whether contractors engaged in construction work for an establishment fall within the definition of contractor and whether the work is work of the establishment so as to attract the Act.

Analysis: The definitions of contractor, establishment, principal employer, workman, and contract labour were read together to determine the scope of the expression "work of an establishment". The construction undertaken for the benefit of the establishment was treated as work connected with the establishment, not merely work done at the physical place where the core business is carried on. The scheme of the Act, especially section 10, showed that the legislative focus is on regulation and progressive abolition of contract labour in relation to the work site of the establishment, and the expression "other work in any establishment" was construed in context. The Court held that limiting the Act only to work identical with the principal employer's core commercial activity would defeat the statutory object.

Conclusion: The petitioners were contractors within the meaning of the Act, and the construction work was work of the establishment, so the Act applied.

Issue (ii): Whether the provisions of the Act and the Rules, including welfare requirements, licensing fees, security deposit, forfeiture, and removal of difficulties power, are unconstitutional or amount to excessive delegation.

Analysis: The Act was treated as a social welfare measure aimed at preventing exploitation of contract labour and securing humane working conditions. The requirements relating to canteens, rest rooms, drinking water, latrines, urinals, washing facilities, licensing, and conditions of service were held to bear a rational nexus with the statutory object and not to impose unreasonable restrictions under Article 19(1)(g). The prescribed fees were held to be regulatory and not a tax. The security deposit and forfeiture mechanism under section 14 and the relevant Rules were upheld as a valid administrative penalty linked to due performance of licensing conditions, with appeal provided against adverse orders. Section 34 was held not to confer excessive delegation because it only enabled the Government to make necessary provisions consistent with the Act for removing implementation difficulties. The power of inspection under section 28 was not treated as unconstitutional.

Conclusion: The challenged provisions of the Act and the Rules were upheld as constitutionally valid.

Final Conclusion: The challenge to the Act and the Rules failed in full, and the petitions were dismissed.

Ratio Decidendi: A purposive construction of a labour welfare statute permits the expression "work of an establishment" to include construction work undertaken for the establishment's benefit, and welfare, licensing, and security provisions that are rationally connected to that object do not violate the constitutional guarantees invoked.

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