National Commission for Safai Karamchari
What is 'National Commission for Safai Karamchari'?
In India, the National Commission for Safai Karamcharis is the governmental organization responsible for protecting the welfare and rights of safai karamcharis, or sanitation workers who do cleaning tasks. The commission aims to improve the welfare and dignity of safai karamcharis by addressing concerns related to their socioeconomic status, health, and safety. It might also contribute to the elimination of manual scavenging and guarantee the effective implementation of regulations and guidelines for sanitation personnel.
NCSK functions under the Ministry of Social justice and Empowerment. It aimed to monitor the implementation of the act and the welfare of the safai karamcharis. NCSK's primary objective is to safeguard the rights and promote the welfare of safai karamcharis, including manual scavengers.
Manual Scavenging is defined as the removal of human excrement from public streets, cleaning septic tanks , gutters and sewers.
The NCSK has construed vigilance commissions and monitoring cells to ensure the smooth functioning of this system.
Vigilance Commission
The Vigilance Commission is an independent statutory body tasked with preventing corruption in government organizations. It investigates misconduct, ensures transparency, and promotes ethical practices, providing recommendations for corrective actions to uphold integrity in public services.
Monitoring Cell
The Monitoring Cell of the National Commission for Safai Karamcharis (NCSK) tracks the execution of government policies and schemes aimed at the welfare of sanitation workers, particularly manual scavengers, ensuring proper implementation and addressing grievances related to their rights and rehabilitation.
Official Definition of the term
Term as defined in legislation
National commission for safai karamchari Act, 1993
The National Commission for Safai Karamcharis (NCSK) was constituted on 12th August, 1994 as a statutory body by an Act of Parliament viz. ‘National Commission for Safai Karamcharis Act, 1993’, for a period of three years i.e. up to 31st March, 1997.
As per sub-section (4) of Section 1 of the Act, it ceased to exist after 31.3.1997. However, validity of the Act was extended up to March, 2002, and then up to February, 2004 vide Amendment Acts passed in 1997 and 2001 respectively. On 19 January, 2022, The Union Cabinet, chaired by the Prime Minister Narendra Modi, approved the extension of the tenure of the National Commission for Safai Karamcharis (NCSK) for three years beyond 31.3.2022 and the total implication of the extension for three years would be approximately Rs.43.68 crore.
Powers and Functions
As per the official NCSK online portal, In the discharge of its functions, the Commission has the powers to call for information with respect to any matter specified above from any Government or local or other authority. Further, the Commission has adopted the following procedure to accomplish its mandate:-
- The Commission seeks reports from concerned authorities on the representations received by it from the target group and makes suitable recommendations in order to resolve the grievance.
- Seeking information from State/UT Governments, Municipalities, PSU, etc. on implementation of the M.S. Act, 2013 and outcomes.
- The Commission visits the States/UTs and meet the State Govt. /Distt. Officialsto take up the matters related to their respective States/Districts.
- The Commission also visits those places which are inhabited by safai Karamcharis and meet their leaders, representatives, social organization and individuals to know their problems, and obtain suggestions on development /welfare.
Additionally, The Commission shall perform the following functions:-
- Recommend to the Central Government specific programmes of action towards elimination of inequalities in status, facilities and opportunities for Safai Karamcharis.
- Study and evaluate the implementation of the programmes and schemes relating to the social and economic rehabilitation of Safai Karamcharis; and scavengers, in particular.
- Programmes or schemes in respect of any group of Safai Karamcharis
- Decisions, guidelines or instructions, aimed at mitigating the hardships of Safai Karamcharis
- Measures for the social and economic upliftment of Safai Karamcharis
- The provisions of any law in its application to Safai Karamcharis; and take up such matters with the concerned authorities or with the Central or State Governments
- To study and monitor the working conditions, including those relating to health, safety and wages of Safai Karamcharis working under various kinds of employers including Government, Municipalities and Panchayats, and to make recommendations in this regard.
- Make reports to the Central or State Governments on any matter concerning Safai Karamcharis, taking into account any difficulties or disabilities being encountered by Safai Karamcharis
- Any other matter which may be referred to it by the Central Government.
With the enactment of “The Prohibition of Employment as Manual Scavengers and Their Rehabilitation Act, 2013”, the mandate and scope of the Commission has also been enlarged. As per Section 31(1) of the said Act, the Commission shall perform the following functions, namely:-
- To monitor the implementation of the Act.
- To enquire into complaints regarding contravention of the provisions of the Act, and to convey its findings to the concerned authorities with recommendations requiring further action.
- To advise the Central and the State Governments for effective implementation of the provisions of the Act.
- To take suo motu notice of matter relating to non-implementation of the Act
Section 8 of The national commission of Safai karamchari Act, 1993 talks about the functions and power of the commission such as :
(a) recommend to the Central Government specific programmes of action towards elimination of inequalities in status, facilities and opportunities for Safai Karamcharis under a time-bound action plan.
(b) study and evaluate the implementation of the programmes and schemes relating to the social and economic rehabilitation of Safai Karamcharis and make recommendations to the Central Government and State Governments for better coordination and implementation of such programmes and schemes;
(c) investigate specific grievances and take suo moto notice of matters relating to non implementation of— (i) programmes or schemes in respect of any group of Safai Karamcharis; (ii) decisions, guidelines or instructions, aimed at mitigating the hardship of Safai Karamcharis; (iii) measures for the social and economic upliftment of Safai Karamcharis; (iv) the provisions of any law in its application to Safai Karamcharis, and take up such matters with the concerned authorities or with the Central or State Governments;
(d) make periodical reports to the Central and State Governments on any matter concerning Safai Karamcharis, taking into account any difficulties or disabilities being encountered by Safai Karamcharis;
(e) any other matter which may be referred to by the Central Government. (2) In the discharge of its functions under sub-section (1), the Commission shall have power to call for information with respect to any matter specified in that subsection from any Government or local or other authority.
The staff and employees in the commission shall be deemed to be public servants within the meaning of section 21 of the Indian penal code (45 of 1860) which consists of the chairperson, vice chairperson and other members.
Term as defined in official government report
Annual Reports of the Ministry of Social Justice and Empowerment: This ministry manages the NCSK, and its yearly reports explain the activities and measures done to improve the lives of safai Karamchari and abolish manual scavenging.
Reports of the National Commission for Safai Karamcharis: The NCSK provides annual and special reports that offer valuable insights on the well-being and condition of safai karamcharis, along with the steps made to eradicate manual scavenging. The latest report released by the NCSK was 2021-22. Copy of Annual Report NCSK.pdf
Reports by the National Human Rights Commission( NHRC): In its yearly reports and special studies on human rights in India, the NHRC often addresses topics related to manual scavenging and the rights of safai karamcharis.
Legal Provisions
The National Commission for Safai Karamcharis finds legal legitimacy in
Manual Scavengers and Their Rehabilitation Act, 2013 : Section 32 (i) of the Manual Scavengers and Their Rehabilitation Act, 2013 states that “The State Government may, by notification, designate a State Commission for Safai Karamcharis or a State Commission for the Scheduled Castes or such other statutory or other authority, as it deems fit, to perform, within the State”
State Monitoring Committees on National Commision for Safai Karamcharis : The State continues to monitor the official development of the NCSK. These reports can be traced from January 2023 and continue to be updated on a monthly basis. The latest report, as published on 31st August 2024 states that those States/UTs that have not informed about the Constitution of a State Monitoring Committee include Arunachal Pradesh, Jammu and Kashmir, Manipur and Mizoram. District Vigilance Committee : The District Vigilance Committees, formed under the National Commission for Safai Karamcharis, monitor the implementation of laws and welfare schemes for sanitation workers. These committees aim to prevent exploitation, address grievances, and ensure proper rehabilitation of manual scavengers. They function at the district level, providing oversight and support to safeguard the rights of these marginalised workers.
Databases
This is the information provided by State/UT governments on Number of Sewer Deaths, full compensation paid & disposed off cases due to non-availability of legal heirs since 1993 to 31.03.2022
S. No. State/UT Total No. of Deaths Total No. of Cases Where Compensation Has Been Paid Disposed Off Cases Due to Non-Availability of Legal Heirs 1 Andhra Pradesh 22 20 0 2 Bihar 2 2 0 3 Chandigarh 3 3 0 4 Chhattisgarh 1 1 0 5 Delhi 97 71 0 6 Goa 6 0 0 7 Gujarat 153 95 12 8 Haryana 87 61 0 9 Karnataka 86 85 0 10 Kerala 13 13 0 11 Madhya Pradesh 16 16 0 12 Maharashtra 39 19 0 13 Odisha 2 2 0 14 Puducherry 9 8 0 15 Punjab 41 34 0 16 Rajasthan 38 26 1 17 Tamil Nadu 220 208 0 18 Telangana 17 14 0 19 Tripura 2 2 0 20 Uttar Pradesh 102 63 0 21 Uttarakhand 9 2 0 22 West Bengal 23 21 0 Total 988 766 13 Term as defined in Case Laws:
Safai Karamchari Andolan & ors. Versus Union Of India & Ors
In order to solve the problem of manual scavenging in India, this historic case was essential. The Supreme Court ordered the federal and state governments to act immediately to identify, heal, and give manual scavengers alternative jobs. The court ordered compensation for the injured families and stressed the importance of strictly enforcing the regulations that forbid manual scavenging.
Delhi Jal Board versus National Campaign for Dignity and Rights of Sewerage and Allied Workers
This case brought attention to how dangerous cleaning sewers can be and called for the implementation of safety regulations, worker rehabilitation programs, and remuneration for those who perform these tasks. The Supreme Court gave the government instructions to put careful cleanup strategies into place and make sure sanitation workers are safe.
Bezwada Wilson versus State of Karnataka
Bezwada is an Indian activist and one of the co convenor and founder of the Safai Karamchari Andolan. Although not a case in traditional terms, well-known human rights activist Bezwada Wilson has played a significant role in promoting the rights of sanitation workers and opposing manual scavenging. His initiatives have made a major difference in increasing public awareness, influencing regulatory reforms, and promoting the application of the legislation to end manual scavenging.
Chinnamma versus State of Karnataka & Ors.
In this instance, the Karnataka High Court ruled in favor of the family of a man named Chenchaiah, who drowned from suffocation while cleaning a drain. The victim's relatives sought entitlement to rehabilitation despite receiving a payment of Rs 2 lakhs.udge Ashok B. Hinchigeri stated that manual scavengers put their lives in danger to ensure the comfort of others, using precedents from the Delhi Jal Board and the Safai Karamchari Andolan case. He went on to say that the court is required by the constitution to familiarize itself with the concerns related to the situation of those who choose to live such a risky and dangerous life. He claimed that when courts can hear cases of tax evasion, horrible crimes like murder, rape, kidnapping, etc., or people coming forward to complain that their fundamental rights have been violated, then the court can certainly take some time out to hear the grievances of the vast majority of people.
Dr. Balram Singh versus Union Of India & Ors.
In this Case Supreme Court issued directions to the Union and State Government to ensure the complete eradication of the practice of complete manual scavenging. While pronouncing the judgment, Justice Bhat quoted the words of Dr. Ambedkar, “Ours is a battle not for wealth of power. It is a battle for freedom. It is a battle for reclamation of human personality.” The order of the bench further reads, “If you have to be truly equal in all respects, the commitment that Constitution makers gave to all sections of society by entrenching emancipatory provisions such as Articles 15(2), 17, 23, and 24, each of us must live up to its promise. Union and States are duty-bound to ensure that the practice of manual scavenging is completely eradicated. Each of us owes to this large segment of the population, who have remained unseen, unheard, and muted, in bondage and systematically trapped in inhuman conditions. The conferment of entitlements and placement of obligations upon the Union and States through the express prohibitions in the Constitution and provisions of the 2013 Act mean that they are obliged to implement the provisions in the letter and spirit.”
The Employment of Manual Scavengers and Construction of Dry Latrines ( Prohibition) Act, 1993
This Act prohibits the building or repair of dry latrines, as well as the use of manual scavengers. It requires the present dry latrines be demolished and that manual scavengers be rehabilitated by offering them financial support and alternative work options.
Prohibition of employment as manual scavengers and their rehabilitation Act, 2013
This comprehensive law, which replaces the 1993 Act, forbids manual scavenging in all of its appearances, including the risky cleaning of septic tanks and sewers. It provides a wide definition of manual scavenging and requires that those who engage in it be identified, surveyed, rehabilitated, and given access to alternate means of subsistence. Additionally, the Act specifies fines for noncompliance.
Protection of civil rights Act, 1955 ( Revised)
This is an Act which came into effect in 1977 prohibited untouchability and made it an offense that could be prosecuted but not settled. Integrated low-cost sanitation programs were permitted in order to convert dry latrines owned by disadvantaged urban households into flush latrines.
State Monitoring Committees
As per Section 26 of the Manual Scavengers (Rehabilitation) Act, 2013 -cedure in regard to the transaction of business at its meetings as may be prescribed.
And As per Section 27 of the Manual Scavengers (Rehabilitation) Act, 2013 -The functions of the State Monitoring Committee shall be—
(a) to monitor and advise the State Government and local authorities for effective implementation of this Act;(b) to coordinate the functions of all concerned agencies;
(c) to look into any other matter incidental thereto or connected therewith for implementation of this Act.District Vigilance Committee under MSAAs per Section 24 of the Manual Scavengers (Rehabilitation) Act, 2013 -
Every State Government shall, by notification, constitute a Vigilance Committee For each district and each Subdivision.(2) Each Vigilance Committee constituted for a district shall consist of the following members, namely:—
(a) the District Magistrate—Chairperson, ex officio;(b) all members of the State Legislature belonging to the Scheduled Casteselected from the district—members: Provided that if a district has no member of the State Legislature belonging to the Scheduled Castes, the State Government may nominate such number of other members of the State Legislature from the district, not exceeding two, as it may deem appropriate.
(c) the district Superintendent of Police— member, ex officio;(d) the Chief Executive Officer of,— (i) the Panchayat at the district level—member, ex officio; 11 (ii) the Municipality of the district headquarters—member, ex officio; (iii) any other Municipal Corporation constituted in the district—member, ex officio; (iv) Cantonment Board, if any, situated in the district—member,ex officio;
(e) one representative be nominated by the railway authority located in the district;(f) not more than four social workers belonging to organisation working for the prohibition of manual scavenging and rehabilitation of manual scavengers, or,representing the scavenger community, resident in the district, to be nominated by theDistrict Magistrate, two of whom shall be women;
(g) one person to represent the financial and credit institutions in the district, tobe nominated by the District Magistrate;(h) the district-level officer in-charge of the Scheduled Castes Welfare—Member-Secretary, ex officio;
(i) district-level officers of Departments and agencies who, in the opinion of the District Magistrate, subject to general orders, if any, of the State Government, have asignificant role to play in the implementation of this Act.(3) Each Vigilance Committee, constituted for a Sub-Division, shall consist of the following members, namely:—
(a) the Sub-Divisional Magistrate—Chairperson, ex officio;(b) the Chairpersons and the Chief Executive Officers of Panchayats at intermediate level of the Sub-Division, and where Panchayats at intermediate level, do not exist, Chairpersons from two Panchayats at Village level to be nominated by theSub-Divisional Magistrate—member, ex officio;
(c) the Sub-Divisional Officer of Police—member, ex officio;(d) Chief Executive Officer of— (i) the Municipality of the Sub-Divisional headquarters—member,ex officio; and (ii) Cantonment Board, if any, situated in the Sub-Division—member,ex officio;
(e) one representative to be nominated by the railway authority located in the Sub-Division—member, ex officio;(f) two social workers belonging to the organisation working for the prohibition of manual scavenging and rehabilitation of the manual scavengers, or representing the scavenger community resident in the Sub-Division, to be nominated by the DistrictMagistrate, one of whom shall be a woman;
(g) one person to represent the financial and credit institutions in theSub-Division, to be nominated by the Sub-Divisional Magistrate;(h) the Sub-Divisional level officer in-charge of Scheduled Castes welfare—Member-Secretary, ex officio;
(i) Sub-Divisional level officers of Department and agencies who in the opinion of the Sub-Divisional Magistrate, subject to any general orders of the State Government Or the District Magistrate, have a significant role to play in the implementation of thisAct—member, ex officio.(4) Each Vigilance Committee constituted at district and Sub-Divisional level shallmeet at least once in every three months.
(5) No proceeding of a Vigilance Committees shall be invalid merely by reason of anydefect in its constitution.Constitutional Provisions related to manual scavenging: Human dignity is an inalienable right which forms a part of the fundamental right to life (Article 21– Maneka Gandhi vs. Union of India) as per the Constitution of India. ‘Dignity’ has been construed to include equal treatment and protection of the law, and equal respect. It is a unanimously accepted right, validated by Articles 1, 22, and 23 of the Universal Declaration of Human Rights. The following is a list of provisions under the Indian Constitution which is supposed to cater to the rights of equality, respect, and dignity before the law.Constitutional Aspects with respect to NCSK
- Article 14: Deals about the equality before Law
- Article 15 : It states that there should be no discrimination on the basis of race, caste , gender, religion, Birth of a person. However, Manual scavengers usually face discrimination on their caste.
- Article 16 : In matters of public employment guarantees equal opportunity to all its citizens.
- Article 17 : It deals with the provision for the abolition of untouchability.
- Article 19(1)(g): Provides every citizens Right to practice any profession or to carry any occupation, Trade, or business.
- Article 21: Right To Life
- Moreover, Article 46 and 338 are other rights which safeguard the manual scavengers as SC or ST.
Types of National Commission for Safai Karamcharis
- The National Commission for Safai Karamcharis comprises one Chairperson (in the rank and status of the Union Minister of State), one Vice-Chairperson (in the rank and status of the Secretary to the Government of India) and five members, including a lady member (in the rank and status of the Secretary to the Government of India) and the Secretary (in the rank of Joint Secretary to the Govt. of India) along with other supporting staff.
- The National Commission for Safai Karamcharis (NCSK) was constituted on 12th August, 1994 as a statutory body by an Act of Parliament viz. ‘National Commission for Safai Karamcharis Act, 1993’, for a period of three years i.e. up to 31st March, 1997. As per sub-section (4) of Section 1 of the Act, it was to cease to exist after 31.3.1997. However, validity of the Act has been extended till 2025.
The mandate of the National Commission for Safai Karamcharis as laid down in the resolution dated 06.03.2013 read with resolution dated 02.03.2009, is as follows:
Recommend to the Central Government specific programmes of action towards elimination of inequalities in status, facilities and opportunities for Safai Karamcharis.
Study and evaluate the implementation of the programmes and schemes relating to the social and economic rehabilitation of Safai Karamcharis; and scavengers, in particular.
Investigate specific grievances and take suo-motu notice of matters relating to non-implementation of:
programmes or schemes in respect of any group of Safai Karamcharis
decisions, guidelines or instructions, aimed at mitigating the hardships of Safai Karamcharis
measures for the social and economic upliftment of Safai Karamcharis
the provisions of any law in its application to Safai Karamcharis; and take up such matters with the concerned authorities or with the Central or State Governments
To study and monitor the working conditions, including those relating to health, safety and wages of Safai Karamcharis working under various kinds of employers including Government, Municipalities and Panchayats, and to make recommendations in this regard.
Make reports to the Central or State Governments on any matter concerning Safai Karamcharis, taking into account any difficulties or disabilities being encountered by Safai Karamcharis
Any other matter which may be referred to it by the Central Government.
However, with the enactment of “The Prohibition of Employment as Manual Scavengers and Their Rehabilitation Act, 2013”, the mandate and scope of the Commission has also been enlarged. As per Section 31(1) of the said Act, the Commission shall perform the following functions, namely:
To monitor the implementation of the Act.
To enquire into complaints regarding contravention of the provisions of the Act, and to convey its findings to the concerned authorities with recommendations requiring further action.
To advise the Central and the State Governments for effective implementation of the provisions of the Act.
To take suo motu notice of matter relating to non-implementation of the Act.
In the discharge of its functions, the Commission have the powers to call for information with respect to any matter specified above from any Government or local or other authority.
The Commission also monitors the implementation of Supreme Court Judgement dated 20.10.2023 in Writ Petition(Civil) No.324 of 2020 in Dr. Balram Singh & ors Vs. Union of India. The Supreme Court, in the above Writ Petition has, inter-alia, directed as under:
To ensure that the compensation for sewer deaths is increased (given that the previous amount fixed, i.e., Rs 10 lakhs) was made applicable from 1993. The current equivalent of the amount is Rs. 30 lakhs. This shall be the amount to be paid, by the concerned agency, i.e., the Union, the Union Territory or the State as the case may be. In other words, compensation for sewer deaths shall be Rs 30 lakhs. In the event, dependents of any victim have not been paid such amount, the above amount shall be payable to them. Furthermore, this shall be the amount to be hereafter paid, as compensation.
In the case of sewer victims suffering disabilities, depending upon the severity of disabilities, compensation shall be disbursed. However, the minimum compensation shall not be less than 10 lakhs. If the disability is permanent and renders the victim economically helpless, the compensation shall not be less than 20 lakhs.
The National Commission for Safai Karamcharis comprises one Chairperson (in the rank and status of the Union Minister of State), one Vice-Chairperson (in the rank and status of the Secretary to the Government of India) and five members, including a lady member (in the rank and status of the Secretary to the Government of India) and the Secretary (in the rank of Joint Secretary to the Govt. of India) along with other supporting staff.
The mandate of the National Commission for Safai Karamcharis as laid down in the resolution dated 06.03.2013 read with resolution dated 02.03.2009, is as follows:
Recommend to the Central Government specific programmes of action towards elimination of inequalities in status, facilities and opportunities for Safai Karamcharis.
Study and evaluate the implementation of the programmes and schemes relating to the social and economic rehabilitation of Safai Karamcharis; and scavengers, in particular.
Investigate specific grievances and take suo-motu notice of matters relating to non-implementation of:
programmes or schemes in respect of any group of Safai Karamcharis
decisions, guidelines or instructions, aimed at mitigating the hardships of Safai Karamcharis
measures for the social and economic upliftment of Safai Karamcharis
the provisions of any law in its application to Safai Karamcharis; and take up such matters with the concerned authorities or with the Central or State Governments
To study and monitor the working conditions, including those relating to health, safety and wages of Safai Karamcharis working under various kinds of employers including Government, Municipalities and Panchayats, and to make recommendations in this regard.
Make reports to the Central or State Governments on any matter concerning Safai Karamcharis, taking into account any difficulties or disabilities being encountered by Safai Karamcharis
Any other matter which may be referred to it by the Central Government.
However, with the enactment of “The Prohibition of Employment as Manual Scavengers and Their Rehabilitation Act, 2013”, the mandate and scope of the Commission has also been enlarged. As per Section 31(1) of the said Act, the Commission shall perform the following functions, namely:
To monitor the implementation of the Act.
To enquire into complaints regarding contravention of the provisions of the Act, and to convey its findings to the concerned authorities with recommendations requiring further action.
To advise the Central and the State Governments for effective implementation of the provisions of the Act.
To take suo motu notice of matter relating to non-implementation of the Act. In the discharge of its functions, the Commission have the powers to call for information with respect to any matter specified above from any Government or local or other authority.
The Commission also monitors the implementation of Supreme Court Judgement dated 20.10.2023 in Writ Petition(Civil) No.324 of 2020 in Dr. Balram Singh & ors Vs. Union of India. The Supreme Court, in the above Writ Petition has, inter-alia, directed as under:
- To ensure that the compensation for sewer deaths is increased (given that the previous amount fixed, i.e., Rs 10 lakhs) was made applicable from 1993. The current equivalent of the amount is Rs. 30 lakhs. This shall be the amount to be paid, by the concerned agency, i.e., the Union, the Union Territory or the State as the case may be. In other words, compensation for sewer deaths shall be Rs 30 lakhs. In the event, dependents of any victim have not been paid such amount, the above amount shall be payable to them. Furthermore, this shall be the amount to be hereafter paid, as compensation.
- In the case of sewer victims suffering disabilities, depending upon the severity of disabilities, compensation shall be disbursed. However, the minimum compensation shall not be less than 10 lakhs. If the disability is permanent and renders the victim economically helpless, the compensation shall not be less than 20 lakhs.
The National Commission for Safai Karamcharis comprises one Chairperson (in the rank and status of the Union Minister of State), one Vice-Chairperson (in the rank and status of the Secretary to the Government of India) and five members, including a lady member (in the rank and status of the Secretary to the Government of India) and the Secretary (in the rank of Joint Secretary to the Govt. of India) along with other supporting staff.
International Experience
Universal Declaration of Human Rights ( UDHR)
- Article 1: States that all human beings are born free and equal in dignity and rights.
- Article 23: Everyone has the right to work, to free choice of employment, to just and favorable conditions of work and to protection against unemployment.
International Covenant on Economic, Social and Cultural Rights( ICESCR)
- Article 7: The States Parties to the present Covenant recognize the right of everyone to the enjoyment of just and favourable conditions of work.
