On 6 November 1996, a three-judge bench held that once the appropriate Government issues a Section 10 notification under the Contract Labour Act prohibiting contract labour in a process, the displaced workers stand automatically absorbed into the principal employer's establishment. The doctrine lived for five years before a Constitution Bench overruled it in SAIL.
On 16 December 1983, a three-judge bench held that Article 21 derives its life-breath from the Directive Principles and laid the foundation for continuing-mandamus supervision of bonded-labour rehabilitation.
On 18 September 1982, a two-judge bench held that payment below minimum wage is 'forced labour' under Article 23, opening Article 32 to construction workers at the Delhi Asian Games sites.