I. Abstract
The purpose of labor laws was to regulate the environment in industries and other labor related workplaces; especially pertaining to the condition of the workmen. Today, the most prominent form of emerging entity is the e-commerce. However, there have been various instances which brought to light the condition of the workmen in these e-commerce entities. Though the working platform in e-commerce is online, it is not so with regards to the workmen. They work on the non-virtual platform. Then why are the e-commerce entities not abiding by the labor laws. We have seen the example of Rajasthan, which explicitly brought e-commerce under the labor laws. Thus, this article analyses what an industry is and what are the essentials to constitute an industry. It then analyzes whether the e-commerce setup would form the ‘e-industry’. A definition of ‘e-industry’ is attempted for the first time. To emphasize upon the importance of this issue, the article discusses various problems and violation of rights that arise due to the present, unsettled position including human rights and health-care issues. Finally, the article gives certain recommendations in light of the practical examples where workmen from the e-commerce entities have suffered, to attempt uniformity and make the labor laws applicable to them as well.
II. Introduction
If there is one thing India is talking about right now, then that is e-commerce. It has emerged as the new boon to India’s economy, among other things. But every coin has two faces. Where India may pat itself on its success in the e-commerce platform, there are issues pertaining to the workplace haunting it. Various instances of non-adherence to labor laws have come to light. There has been a debate as to whether the present, existing labor laws will apply to the e-commerce structure that is on a boom. There has been no case-law precedent as of now which lays down as to whether the e-commerce structure rightly qualifies as an industry and they are taking advantage of this unsettled position. Due to this position, these entities are not strictly adhering to the labor law mandates laid down by the legislature and the judiciary. Though there seems to be no big hurdle in bringing e-commerce under the ambit of an ‘industry’ as required by the concerned Act; laying down a well-reasoned and well-founded clarification will put an end to the hay-ware practice that is going on right now. If e-commerce is established as an e-industry, the present negligent practice can be put an end to.
III. Introduction to Industrial Laws
One thing that has the power to make and break a society is the industry. Since the beginning, we have seen the might of the industries. Talk of the industrial revolution and the world has never looked back since. With the rise of the industries and the ever-growth-hungry industrialists came the problems associated with the labors who were treated no better than mere machines. The cure to the problem obviously came in the form of labor laws. In India for instance, the industrial laws have a deep rooted history of labor movements seeking reform in their condition and the then state of affairs.
The various labor laws came as a big relief dealing with all possible areas. The biggest problem then was their implementation as some definitions and provisions were way too ambiguous and wide. The courts have worked over this problem from time to time to bring some kind of uniformity if not a litmus test. Various definitions have been amended though not implemented. A uniform Labor Law is on the table though it has not yet seen the daylight. The labor laws are a product of the labor reforms. Thus, where they seek to harmonize the relationship pf the labors an the employers, they also seek to promote the working condition of the labors specifically.
IV. Understanding E-Commerce
Electronic commerce or e-commerce refers to a wide range of online business activities for products and services.[1] It also pertains to “any form of business transaction in which the parties interact electronically rather than by physical exchanges or direct physical contact.[2] A more comprehensive definition is: E-commerce is the use of electronic communications and digital information processing technology in business transactions to create, transform, and redefine relationships for value creation between or among organizations, and between organizations and individuals.[3] So far, from these definitions, it is pertinent that in e-commerce, the mode of communication and transaction between the organization and organization and organization and individual is online. On a closer scrutiny it becomes pertinent that it does not refer to the mode of communication between the employer and employee. As a vast network of people and information,[4] the Internet is an enabler for e-commerce as it allows businesses to showcase and sell their products and services online and gives potential customers, prospects, and business partners access to information about these businesses and their products and services that would lead to purchase.[5] Thus, the internet has no role to play whatsoever, as long are the employer employee is concerned. Therefore, the mode of communication between the employer and employee is still like any other industry. All in all, from the perspective of the employees, e-commerce is like any other industry since the relation between employer and employee is not via the online platform, but in the traditional way. However, one example for consideration can be the scenario where the employees are hired online, though for a shorter period. The work is assigned online which is to be submitted online.
V. Defining An Industry
The definition of 'industry' prior to the amendment was little ambiguous had a lot of scope for construction. It was given in two parts in the statute. In its first part it means any business, trade, undertaking, manufacture or calling of employers is an industry. It determined industry in reference to the occupation of employers falling in the categories mentioned. The second part viewed the matter from the angle of employees and gave an extended connotation. It stated that any calling, service, employment, handicraft or industrial occupation or avocation of workmen is included in the concept of industry. However the second part alone could not define an 'industry'.[6]
On the contrary, the present definition of industry provided in Section 2(k)[7] of the Industrial Disputes Act, 1947 after the Industrial Disputer (Amendment) Act, 1982 is quite self-explanatory and provides various sectors and categories in itself. It also provides certain exceptions which may look like an industry but are not. However, the major problem and the confusing, unsettled position as to whether an activity will qualify an as industry or not still exists because this particular amendment has not been enforced as of now. Once this does, it will overrule a lot of judicial pronouncements. Once it gets enforced, there will be a lot of uniformity in the labor laws.
The definition of industry has developed in many stages and has been interpreted many times by the courts. However, for a long time there was no fixed definition and scope of industry,
The first stage was from 1953 to 1962. The ambit of industry was very wide in this period as is evident by the judicial pronouncements of the said time.
In Corporation of the city of Nagpur vs. Its employees[8], the court had to decide whether a corporation is an industry as under Section 2(j) of the Industrial Dispute Act, 1947. The Supreme Court in this case made some significant observations and held that corporation is an industry for the purposes of its nonregal functions but its regal functions of sovereign nature are the ‘primary’ and inalienable functions of the state, though delegated to the corporation, are necessarily excluded from the purview of the definition of industry. In D.N.Banerji v P.R. Mukherjee[9], the issue was whether Municipality is an industry. The court did not have to decide this under Section 2(j) exclusively and thus it was held that a municipal activity cannot be called a “business or trade” but it would fall within the scope of “undertaking” and thus it is an industry. The nonprofit undertakings of the municipality were included in the concept of an industry, even if there is no private enterprise.
In the period from 1963 to 1978, the definition was interpreted rather narrowly and all the entities put to question were held not to be an industry. In Madras Gymkhana Club Employees’ Union vs. Gymkhana Club[10], the Supreme Court held that non-profit making members are not employed in a trade or industry. Thus, in this time a club[11], solicitors firm[12], University[13], law department[14], forest department[15], census department of Government of India[16], District Literary Samiti[17], the Diocese of Church[18], temple[19], were held not to bean industry.
Soni Photostat Centre v. Basudev Gupta[20] held that “a single lawyer, a rural medical practitioner of urban doctor with a little assistant and/or menial servant may play a profession but may not be said to run an industry”. This is because there is no element of an organized labour in such employment. In Osmania University vs. Industrial Tribunal Hyderabad[21], it was held that the test for determining whether the dispute is between the capital and labour, is to see if they are engaged in cooperation or whether dispute is concerned directly or indirectly with the production or distribution of wealth.
However, there are some conflicting pronouncements as well. An example could be Chief Conservator of Forest v. Jagannath Maruti Kondare[22] where forest department of the State of Maharashtra was held to be an industry whereas in State of Gujarat v. Pratamsingh Narsingh Parmar[23], the forest department of State of Gujarat was held not to be an industry.
Then again the pronouncement in State of UP v. Jai Bir Singh[24], is in contrast to the one in Bangalore Water Supply v. A. Rajappa[25].
All in all it is evident that the courts have tried to evolve some sort of test to define an industry but they have succumbed to their own varied interpretation of the definition. Thus, there has been a lot of inconsistency in the decisions but now the position seems to have settled a little bit. A final position has also been reached in connection to various entities. However, the scope of interpretation will always be there.
A. Triple Test
The Golden Rule to test whether an entity/activity constitutes an industry or not was laid down in the case of Bangalore Water Supply v. A. Rajappa[26] known as the Triple Test, where a seven-judge bench was constituted especially to examine the definition of “industry” and lay down the law on the subject. The essentials as mentioned in this landmark judicial pronouncement have more or less been incorporated in the new definition of industry. The three elements of triple test are that the activity should be:
1. Systematic activity ,
2. Organized by co-operation between the employer and employee,
3. For the production and/or distribution of goods and services calculated to satisfy human wants and wishes.
The court also noted these points:
1. Absence of profit motive or gainful objective is irrelevant, be the venture in the public, joint private or other sector.
2. The true focus is functional and the decisive test is the nature of the activity with special emphasis on the employer-employee relations.
3. If the organization is a trade or business it does not cease to be one because of philanthropy animating the undertaking.
These observations, which are widely known as triple-test, are readily resorted to by the courts whenever there is a dispute over the industrial nature of the entity. This judgment exhaustively laid down the defining factors of an industry and clarified the otherwise unsettled position.
VI. Can E-Industry Be An Industry For The Purpose of Labor Laws
A. Triple Test
First of we have to examine the nature of the industry itself to see as to whether the e-commerce entity fits in the definition of an industry. To pursue this investigation, we resort to the triple test. The test provides the following:
i. Systematic Activity.
Under this head, the primary element of the activity has to be seen and tested. The activity should be systematic in the sense that it should not be an irregular or randomly carried activity. There should be some scheme to it. A certain ‘system’ should be the deciding factor. The courts have not said much about this element as it is a purely factual test and no straight jacket formula can be put to test it. Also, disputes do not generally arise in determining this element.
As far as an e-commerce entity is concerned, where they are rendering their services online, their scheme of taking the want/wishes into account, and further providing the solutions/services to the consumers spells out a systematic activity. Where proper online platform is set for the carrying out of the activity, there can be no doubt to the system attached to the functioning.
ii. Organized by co-operation between the employer and employee.
In the e-commerce structure, the initial communication between the entity and the consumers is through electronic means only. If we take the example of some entities like Flipkart, Amazon, ebay, etc; then it becomes imperative that though the services are online, they do not function on the online platform solely. The online platform is only for the initial interaction between the buyer and the seller. The series/products shown online are made available through the regular setup of an employment place. Thus, when a consumer orders some product through an e-commerce website, it gets processed by the technical and all other relevant departments and come to an end when the product is delivered by the delivery staff. It is impossible to imagine the functioning of these entities without their workforce. They are called e-commerce because their mode of communication with the outside world is online. But where such entities have a set office, howsoever small, then such office an easily be seen to run with the cooperation of the employer an employees. The employer does not deliver the product to the consumer on his own. They usually hire people for each processing step. Such people are employees for their concerned functions.
Thus an e-commerce entity which operates on the offline platform as well can very well be said to run with the co-operation between the employers and employees.
iii. For the production and/or distribution of goods and services calculated to satisfy human wants and wishes.
Most of the e-commerce entities that exist and that are coming up, have incepted to meet the consumer demands. If we take the example of the likes of Flipkart and ebay again, then we see that these exist on a purely commercial base. They provide the goods and also the service of delivering them at the doorstep of the consumer.
Thus they produce/provide the goods and services for the satisfaction of human wants and wishes. There seems no hindrance in putting most of the e-commerce entities as a structure that works for the satisfaction of human wants and wishes.
Not all e-commerce structures fall under this category, but those that do, should actively be brought under the ambit of an industry that have to abide by all the labor laws properly.
B. Workmen
i. Principal Nature of Duties and Functions
To ascertain if an employee is a “workman” under Section 2(s)[27] of the Industrial Disputes Act, is determined with reference to the principal nature of his duties and functions. It thus depends upon the facts and circumstances of each case and materials on record and there can be no objective test for this enquiry.[28]
Once the tests of employment for hire or reward for doing the specified type of work is satisfied, employee would fall within definition of “workman”.
ii. Supervisory and Managerial Duties
Where the employee possesses the power to assign duties and distribute work, such authority indicates his supervisory power.[29] However, there is a difference between a Supervisor and a Manager. Supervisor’s predominant function is to see that the work is done by the workers under him as per the norms laid down by the management: he has no power to take any disciplinary action[30].
iii. Full Time or Part Time
The definition of workmen doesn’t make any distinction between a fulltime or part time employee or a person employed on contract basis. It is upon the Labor or the Industrial court to determine the nature of work for which a person is employed.[31]
Thus, for a person to be a workman under the Industrial Disputes Act, he/she must be employed under any category mentioned in Section 2(s)[32]. The person must not discharge managerial or supervisory duties. It is not sufficient to establish that he/she is not covered by any of the four exceptions to the definitions.[33]
iv. Scenario relating to e-industry
Where it is established that e-commerce is an e-industry, the employees falling in the category of workmen can definitely seek resort to the provisions relating to an industrial dispute. For purposes of enquiry, if we take the case of a delivery boy employed in an online shopping portal, then he falls under the category of an operational labor whether for hire, or reward; full-time or part-time as there seems no evident objection against the same.
VII. Defining E-Industry
The entities for consideration here are the ones where the entity majorly provides services, etc online. The consumer-entity relationship is established on the virtual platform majorly. However, it is not necessary that the workman-employer relationship is virtual. It might be virtual or not. Where the establishment is running on a full commercial setup and earning profits thus, there is nothing to not call it an industry. If the e-commerce entity is qualifying as an industry, then there is nothing that stops it from being an ‘e-industry’ thus.
VIII. Why E-Industry Needs to be Defined
A. Flipkart Strike
Flipkart, the biggest e-commerce entity in India, and a known name recently faced a strike by its delivery boys. Flipkart is known for its services of the products in the Indian marketplace. It also provides lucrative benefits to its employees at the office. However, as a result of the strike, it came to public knowledge that Flipkart does not provide basic services like toilet and fixed working hours or days to the delivery boys. The demands in the strike were:[34]
1. Toilets in each delivery office
2. Duty hours to be fixed
3. Overtime allowances
4. Existing shipment allowance to be enhanced
5. Bike maintenance allowance to be granted
6. Food, laundry allowance to be made available
7. Foot delivery boys to be paid Rs. 5 for shipment and Rs. 10 for return shipment
8. Workers to be issued company ID card
9. Delivery boys to be exempted from work on public holidays
10. Workers to be paid Rs. 30 per day as shipment delivery expenses
11. Workers to be issued an ESIC card
12. Workers to be provided uniforms
13. Workers to be provided vouchers
14. Sunday holiday/compensatory off
Delivery boys would fall under the definition of workmen as provided in the Industrial Disputes Act. Due to non-clarity in the laws, the e-commerce entities are taking benefit of the situation and violating the laws to further their profits. Their competitive schemes like ‘speedy-delivery’, ‘one-day delivery’ are becoming a burden on the delivery boys alone. Had there been a proper structure, Flipkart would have been liable to file the draft of its Standing Order, in lines of the Model Standing Order[35], with the Conciliation Officer[36].
The Standing Order includes conditions relating to holidays, working-days, working hours, allowances, termination, appointment, etc. The employees are at the liberty to oppose the terms if they seem unjust and unfair. That is why it is necessary to explicitly include these entities under the ambit of labor laws.
Thus, it becomes imperative that because there is no precedence relating to e-commerce entities, they are doing a gross violation of the labor norms set in India. Flipkart is one entity that came into light; there must be many others doing the same. Therefore, it is necessary to explicitly include these entities under the ambit of labor laws.
B. Basic Rights
All the labor laws are a product of the prolonged human rights movements which has influenced the Social Justice feature of our constitution leading to industrial harmony.[37] [38]
Once e-industry will be defined as an industry for the purpose of labor laws, it will be subject to the basic statutes in this regard and the problems that the workers are facing right now will be solved to a greater extent. This will ensure the much needed e-industrial boom.
C. Health Issues
By subjecting e-industry to the labor laws, the brutal treatment to the workers will stop. A disease has come up which is mostly reported by the delivery boys of the e-commerce websites as a result of carrying excessive weight on their shoulders all day long subjecting their backbone to incurable disease.[39] This is but, one example of the trauma that they face only facilitated by the loophole in the law which was not cured by updating it with the changing times.
This and many more such issues will be resolved if the proposed act is done because after-all, prevention is better than cure. And we dare say it even when some amount of damage has already been done.
D. Minimum Wage
In order to ensure that the workers are not economically exploited, as our constitution guaranteed social justice, two legislations for regulating the payment of the employees have been formulated in India. The Minimum Wages Act, 1948 ensures that the workers are not paid less that what they need for a minimalistic survival and their economic desperateness is not exploited. Then again, the Payment of Wages Act, 1936 ensures that unjustified deductions are not done and that the workers get what they deserve.
However, when the e-industry is not subject to the Labor Laws, the employers are free to indulge in the economic exploitation of the employees. This again, will be cured once they are put under the mandates of law.
E. Relaxations
In this era of e-commerce boom; much like the industrial boom era, it has to be borne in mind that the human body is not a machine. Where the same problem was cured in the Industrialization phase by setting up labor laws, the revision will cure the same problems pertaining to the e-commerce scenario. By subjecting them to the Labor Laws explicitly, the employees will get humanly relaxations like clean working environment, weekend holiday, medical relaxations (if not the benefits), etc.
IX. Suggestions
Though upon an analysis, it becomes clear that there is nothing substantial in the way of bringing the e-industries under the ambit of Labor Laws, still these entities take advantage of the unsettled position and non-declaration by the law, and violate the labor norms. Therefore, in order to avoid this situation, there should be an express statement as to inclusion of e-industries under the ambit of Labor Laws.
One good example can be the state of Rajasthan which has amended the definition of industry to include e-commerce entities.[40] It is suggested that it is high time that the legislators follow the suit and groom the statute with the changing times before a grave damage is done.
X. Conclusion
Therefore, all in all, it is concluded that it is no doubt that the said entities could be brought under the ambit of an industry for the purpose of the labor laws and there is no hindrance to it as such. The same can be done by way of an amendment into the definition of ‘industry’ in the relevant Statutes. Therefore, in light of the events that have occurred, it is high time now that an explicit word be given on the status of the applicability of labor laws to e-commerce. Otherwise, the violation of rights of the delivery boys and other such workmen in the e-commerce industries will have no end. The example of amendment by Rajasthan could be a roadmap to be followed wherein the said entities were explicitly included under the labor laws.
[1] Anita Rosen, The E-commerce Question and Answer Book (USA: American Management Association, 2000)
[2] MK, Euro Info Correspondence Centre (Belgrade, Serbia), “E-commerce-Factor of Economic Growth;” available from http://www.eicc.co.yu/newspro/viewnews.cgi?newsstart3end5
[3] Emmanuel Lallana, Rudy Quimbo, Zorayda Ruth Andam, ePrimer: An Introduction to eCommerce (Philippines: DAI-AGILE, 2000)
[4] Industry Canada, Canada’s Business and Consumer Site; available at http://strategis.gc.ca
[5] Zorayda Ruth B. Andam, e-Commerce and e-Business ,The e-ASEAN Task Force and the UNDP Asia Pacific Development Information Programme (UNDP-APDIP), available at: http://www.kau.edu.sa/Files/830/Files/61164_Ecommerce%20and%20E%20Business.pdf
[6] Secretary, Madras Gymkhana Club v. Management Of The Gymkhana Club; 1968 AIR SC 554
[7] "industry" means any systematic activity carried on by co-operation between an employer and his workmen (whether such workmen are employed by such employer directly or by or through any agency, including a contractor) for the production, supply or distribution of goods or services with a view to satisfy human wants or wishes (not being wants or wishes which are merely spiritual or religious in nature), whether or not,--
(i) any capital has been invested for the purpose of carrying on such activity; or
(ii) such activity is carried on with a motive to make any gain or profit, and includes--
(a) any activity of the Dock Labor Board established under section 5A of the Dock Workers (Regulation of Employment) Act, 1948 (9 of 1948);
(b) any activity relating to the promotion of sales or business or both carried on by an establishment but does not include--
(1) any agricultural operation except where such agricultural operation is carried on in an integrated manner with any other activity (being any such activity as is referred to in the foregoing provisions of this clause) and such other activity is the predominant one.
Explanation.--For the purposes of this sub-clause, "agricultural operation" does not include any activity carried on in a plantation as defined in clause (f) of section 2 of the Plantations Labor Act, 1951 (69 of 1951); or
(2) hospitals or dispensaries; or
(3) educational, scientific, research or training institutions; or
(4) institutions owned or managed by organizations wholly or substantially engaged in any charitable, social or philanthropic service; or
(5) khadi or village industries; or
(6) any activity of the Government relatable to the sovereign functions of the Government including all the activities carried on by the departments of the Central Government dealing with defense research, atomic energy and space; or
(7) any domestic service; or
(8) any activity, being a profession practiced by an individual or body or individuals, if the number of persons employed by the individual or body of individuals in relation to such profession is less than ten; or
(9) any activity, being an activity carried on by a co-operative society or a club or any other like body of individuals, if the number of persons employed by the co-operative society, club or other like body of individuals in relation to such activity is less than ten;]
[8] 1960 AIR 675
[9] 1953 AIR 58
[10] 1968 AIR 554
[11] Madras Gymkhana Club Employees’ Union v. Gymkhana Club; 1968 AIR 554
[12] NNUC Employees v. IT; 1962 AIR 1080
[13] Osmania University v. Industrial Tribunal Hyderabad; [1960] 1 LLJ 593 [AP]
[14] State of Rajasthan v. Ganeshi lal; 2008 LLR 170
[15] State of Gujarat v. Pratam Singh Narsingh Parmar; (2001) 9 SCC 713
[16] Md. Raj Mohammad v. Industrial Tribunal –cum Labour court, Warangal; 2003 LLR 535. Also ref. to Himanshu Kumar Vidyarathi and others v. State of Bihar; (1997) 4 SCC 391.
[17] Project Director, District Literacy Samiti v. Ms. Mamta Srivastava and another; (2012) I LLJ 212.
[18] Diocese of Amritsar of Church of North India and others v. Buta Anayat Masih and others; 2010 LLR 407 (Punjab & Haryana HC).
[19] Indravadan N. Adhvaryu v. Laxmidevnaryan Dev Trust; 2011 LLR 261 (Guj. HC).
[20] 2004 (1) AWC 252
[21] [1960] 1 LLJ 593 [AP]
[22] 1996 AIR SC 2898
[23] (2001) 9 SCC 713
[24] (2005) 5 SCC 1
[25] 1978 AIR SC 548
[26] 1978 AIR SC 548
[27] " workman" means any person (including an apprentice) employed in any industry to do any manual, unskilled, skilled, technical, operational, clerical or supervisory work for hire or reward, whether the terms of employment be express or implied, and for the purposes of any proceeding under this Act in relation to an industrial dispute, includes any such person who has been dismissed, discharged or retrenched in connection with, or as a consequence of, that dispute, or whose dismissal, discharge or retrenchment has led to that dispute, but does not include any such person--
(i) who is subject to the Air Force Act, 1950 (45 of 1950 ), or the Army Act, 1950 (46 of 1950 ), or the Navy Act, 1957 (62 of 1957 ); or
(ii) who is employed in the police service or as an officer or other employee of a prison; or
(iii) who is employed mainly in a managerial or administrative capacity; or
(iv) who, being employed in a supervisory capacity, draws wages exceeding one thousand six hundred rupees per mensem or exercises, either by the nature of the duties attached to the office or by reason of the powers vested in him, functions mainly of a managerial nature.
[28] S. K. Maini v. M/s. Carona Sahu Company Ltd. & Ors.; 1994 2 CLR 359
[29] Supervisor: One who has authority over others: someone who superintends and directs others.
[30] G. M. Pillai v. A.P. Lakhmikaf Judge, III Labour Court; 1998 LLR 310
[31] New India Assurance Co Ltd. v. A Sankaralingam; (2008) 10 SCC 698
[32] Any person (including an apprentice) employed in any industry to do any manual, unskilled, technical, operational, clerical or supervisory work for hire or reward, whether the terms of employment be expressed or implied, and for the purpose of any proceeding under this Act in relation to an industrial dispute, includes any such person who has been dismissed, discharged or retrenched in connection with, or as a consequence of, that dispute, or whose dismissal, discharge or retrenchment has led to that dispute, but does not include any such person-
i. who is subject to the Air Force Act, 1950 (45 of 1950), or the Army Act, 1950 (46 of 1950), or the Navy Act, 1957 (62 of 1957); or
ii. who is employed in the police service or as an officer or other employee of a prison; or
iii. who is employed mainly in a managerial or administrative capacity; or
iv. who, being employed in a supervisory capacity, draws wages exceeding one thousand sic hundred rupees per mensem or exercises, either by nature of duties attached to the office or by reason of the powers vested in him, functions mainly of a managerial nature.
[33] Mukesh K. Tripathi v. LIC; (2004) 8 SCC 387
[34] Flipkart's Logistics Suffer Blow: 400 Delivery Boys Go On Strike Due To Lack Of Basic Amenities, inc42 Magazine. (2015) http://inc42.com/buzz/flipkart-delivery-boys-strike/
[35] The Schedule, Industrial Employment (Standing Orders) Act, 1946.
[36] Section 3, Industrial Employment (Standing Orders) Act, 1946.
[37] Report of the National Commission on Labour (1969) p.56
[38] Fourth Five-Year Plan- Draft Outline (1966) p. 386
[39] The backbone of Indian e-commerce boom faces serious breakdown, The Economic Times, (29 December 2015), http://tech.economictimes.indiatimes.com/news/internet/the-backbone-of-indian-e-commerce-boom-faces-serious-breakdown/50362860
[40] Labour Pains for e-commerce Players, Business Standard, http://www.business-standard.com/article/opinion/labour-pains-for-e-commerce-players-115081600604_1.html
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