Monday, 23 March 2020

Using Social Security Laws for Working Indian Poor in the Times of a Pandemic


The COVID-19 pandemic not only constitutes a monumental public health crisis for the world but also presents a severe threat to the global economy. Mitigating measures like social distancing are likely to result in a decline in consumer demand, a slowdown in investment and disruption in production and supply chains. Cumulatively, these may result in an economic shock not seen since the aftermath of the Great Depression in the 1930s. Indeed, the International Labour Organization (ILO) has predicted that as many as 24 million workers could be rendered unemployed by the economic impact of the pandemic.  Such massive unemployment is also likely to be accompanied by significant income losses for workers, especially in the unorganised sector.

With more than 90% of its workforce engaged in unorganised work and lacking adequate social security, paid leaves, and wage security, the impact of COVID-19 in India is going to be particularly devastating. Anecdotal accounts suggest that initial attempts at social distancing through closing down of educational institutions, government offices and advisories on work from homes have resulted in a dramatic reduction of availability of work for unorganised workers. Not surprisingly, many among the blue-collared working-class view social distancing without welfare measures as discriminatory. Paradoxically, the lack of any form of income support compels workers to venture out in search of work and thereby also thwarts the purpose of social distancing. Thus, welfare measures and social security for workers affected by the economic impact of COVID-19 is an urgent imperative.
A few state governments, including Kerala, and Uttar Pradesh have already announced financial packages that include measures on pensions and payments to workers. Yet, they remain in the minority so far, and the Central Government has also failed to announce any concrete initiative towards social security for workers. The need for social security for workers due to the COVID-19 pandemic, however, also calls for an interrogation of the adequacy of the existing labour laws in extending social protection to workers whose livelihood is affected.

India's social security regime comprises of a multitude of fragmented schemes set-up through more than fifteen central legislation and state legislations. Some of these, like the Employees' State Insurance Act 1948 are of general application whereas a few like the Building and Other Construction Workers Cess Act, 1996  are sector-specific. Apart from these, the Industrial Disputes Act 1947, which deals with industrial relations, also contains specific provisions on income-security.

Social Security Provisions in the Industrial Disputes Act

Indeed, the Industrial Disputes Act 1947 may be of particular relevance given the protracted shutdown of workplaces. Section 25-C and Section 25-M provide that a workman in an industrial establishment being laid-off shall be paid by the employer a compensation of fifty per cent of his basic wages and dearness allowance for all the days (except weekly holidays) during which he has been so laid off. Pertinently, unlike its common parlance meaning, the term lay-off in the Industrial Disputes Act does not connote termination of employment. Instead, lay-off has been defined by Section 2 (kkk) as a temporary inability by an employer to give work "on account of shortage of coal, power or raw materials or the accumulation of stocks or the break-down of machinery or natural calamity or for any other connected reason". The Supreme Court of India had held in Management of Kairbetta Estate v. Rajamanickam [(1960) 3 SCR 371] that the phrase "any other reason" would mean a reason over which the employer has no control. Thus even though there is no mention of a pandemic in the definition, the inability of an employer to temporarily give work due to a pandemic-induced shutdown would arguably constitute a lay-off. If that is so, the provisions on lay-off compensation can provide a modicum of income protection for industrial workmen. The Industrial Disputes Act may also be relevant for workers who lose their jobs due to the impending economic slowdown. Section 25-F of the Industrial Disputes Act provides for compensation amounting to fifteen days of average pay for every year of continuous service for workers who are retrenched. 

Yet, there are severe limitations to these protective provisions. They apply only to industrial workmen who have had continuous service for 240 days. As a result, a vast swarth of workers employed on a temporary basis or short-term contracts may not be entitled to the compensation, especially since many industries consciously engage workers for terms of less than 240 days. More significantly, the provision on lay-off compensation applies only to workmen employed in factory, mines and plantations that hire at least a fifty or a hundred employees (depending on the applicable provision). In a country where more than ninety per cent of the establishments in this country hire less than six employees, a numerical threshold of fifty excludes most workmen from the protective cover of layoff-compensation. The other hurdle that application of Section 25-C and Section 25-F would run into is the limited capacity of the employer to pay the statutory compensation in the face of a severe economic downturn. Therefore, a sustained governmental intervention may indeed be necessary. 

Employees' State Insurance Act 1948

The most significant social security regime in the country is employment-based social insurance legislation, the Employees' State Insurance Act 1948. The Act provides for Medical Benefit, Sickness Benefit, Disablement Benefit, Dependents' Benefit, Maternity Benefit and a host of other benefits like confinement expenses and funeral expenses. The Act currently extends to more than thirteen crore beneficiaries and therefore has the potential of reaching out to a vast pool of workers and their families.

The provision of free medical treatment through the Medical Benefit can ensure treatment for those suffering from COVID-19. Sickness Benefit available under the Act also guarantees cash compensation to eligible insured workers during certified sickness for a maximum of 91 days in a year. These benefits can provide much-needed income support to those directly afflicted by COVID-19.

Further, benefits directed at unemployment security introduced under the Act can provide some form of income support for those impacted by the loss of livelihood due to social distancing.  Rajiv Gandhi Shramik Kalyan Yojana provides unemployment allowance and vocational training up to a maximum term of two years to those insured for more than three years and rendered unemployed to due to retrenchment or closure of their establishment. A more recently introduced scheme, the Atal Beemit Vyakti Kalyan Yojana provides of cash compensation up to 90 days after three months of unemployment.

It is also pertinent to note that the existing schemes do not exhaust the power of the Employees' State Insurance Corporation (ESIC) to introduce new welfare measures for insured employees. Section 19 of the ESI Act states that "the Corporation may, in addition to the scheme of benefits specified in this Act, promote measures for the improvement of the health and welfare of insured persons and for the rehabilitation and re-employment of insured persons." It is imperative in the context of the catastrophic economic impact of this pandemic that the Central Government and the ESIC use its statutory powers under Section 19 to expand the scope of existing protection for welfares. Interestingly, the Parliamentary Standing Committee on Labour and Employment had chastised the ESIC for spending a meagre sum on the welfare of the insured employees. The Committee had noted that the ESIC had a standing corpus of more than Rs. 73,000 crores and termed the transfer of massive sums into the so-called corpus fund instead of providing facilities to workers' immoral and illegal.' In view of this, it can be surmised that the ESIC has the resources to sustain a welfare scheme that can meet the pressing need of workers affected by the pandemic. Given that it is the workers who have significantly contributed to the accumulation in the ESIC's corpus, financing of unemployment security and related welfare schemes to meet the imminent crisis is both a legal and a moral imperative.

The Building and Other Construction Workers Act, 1996
The Building and Other Construction Workers (Regulation of Employment and Conditions of Service) Act, 1996 (BOCWA) creates a statutory framework for safety, health and welfare measures for the building and other construction workers. For this purpose, a Welfare Fund under the aegis of the State Welfare Boards, has been created under Section 24 of the Act and this Fund is financed through a cess levied at the rate of 1% of the cost of construction by the State Governments under the Building and Other Construction Workers' Welfare Cess Act, 1996. While Section 22 of the BOCWA lists specific measures like accident insurance, old-age pension, loans for housing, group insurance, educational loans, maternity benefit and medical reimbursements, it also enables the government to make provisions and improvement of other welfare measures and facilities. Thus, there is ample scope for the state governments and the state welfare boards to introduce welfare schemes for construction workers to cope with the imminent loss of livelihood and income.

Interestingly, the Central Government had noted that the states and union territories had collected more than Rs 45,473.1 crore and spent a mere Rs. 17,591.592 crore – less than half the amount collected - up to September 2018 under the BOCWA. Even the Supreme Court in National Campaign Committee for Central Legislation on Construction Labour v Union of India had expressed its shock at the underutilisation of the funds collected under the Act. The fact of underutilisation of the BOCWA funds had been highlighted by the Parliamentary Standing Committee on Labour and Employment as well. As such, these unutilised funds could be used by devising schemes for construction workers.

Unorganised Workers' Social Security Act, 2008
The Unorganised Workers' Social Security Act, 2008 (UWSSA) was enacted specifically to meet the social security needs of unorganised workers. Even though it has been a particularly poorly implemented legislation, the UWSSA provides a framework for the introduction of schemes for all categories of unorganised workers. Section 2 (m) defines an "unorganised worker" to include not just wage workers un unorganised sector but also home-based workers, self-employed workers and workers in the organised sector who are not covered by any of the labour laws listed in the schedule to the Act. Significantly, the UWSSA does not provide for a closed list of welfare schemes but empowers the Central Government as well as the State Governments to formulate suitable welfare schemes from time to time. Given its wide amplitude, the UWSSA does provide an available framework for extending social security to the unorganised workers who constitute more than 90% of the workforce in India and are likely to be the worst affected by the economic slowdown caused by COVID-19.

Conclusion
This glance at various labour laws on social security suggests that there are options available within existing social security legislation and schemes for providing a modicum of income support for workers likely to suffer from loss of income or employment due to the COVID-19 pandemic. While many of the schemes and statutes are indeed limited and piecemeal in their scope, there is ample scope for expanding and utilising them to guarantee social security for the affected workers. Further, available information on non-utilisation of funds collected under the ESI Act and the BOCWA suggest that there may be resources available for financing welfare measures for the working poor. In view of the fact that there are more than thirteen crores beneficiaries registered with the ESIC, schemes under the ESI Act can indeed reach out to a significant number of workers and their families. Similarly, Central and State governments must utilise the statutory framework and the mandate under the BOCWA and the UWSSA  to devise new schemes. Challenges remain formidable. The constrained institutional capacity of the state also would be further shackled due to the general lockdowns. The extent of registration in many of these legislations have traditionally remained poor. Therefore, creative designs have to be formulated for implementation of schemes, especially for self-employed and other unorganised workers. Most importantly, such measures have to supported by the expansion and universalisation of existing welfare schemes like the Public Distribution System and the Old Age Pension schemes.

Nonetheless, if social security has to have any meaning as a fundamental right as part of the right to life, state institutions must tap into these existing legislative frameworks and schemes to protect the workers in face of the grave crisis confronting the country. In words of the British journalist Martin Wolf, "[I]n war, governments spend freely. Now, too, they must mobilise their resources to prevent a disaster."

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