State must reconsider Gurujis’ honorarium adequacy in light of Articles 23 and 43.

The petitioners relied on the Madhya Pradesh High Court’s order dated 14 October 2026 in Laxman Singh Dhakar and Others v. State of Madhya Pradesh and Others, submitting that it had decided the same controversy.

The State did not distinguish the present case from Laxman Singh Dhakar.

In that matter, the Court directed the State to reconsider the adequacy of the honorarium paid to the petitioners, including whether expert assessment was needed, in light of the principles reflected in Articles 23 and 43 of the Constitution.

That decision held that a claim of “equal pay for equal work” under Articles 14 and 39(d) requires proof of substantial identity between the posts and their relevant duties and conditions; the petitioners there had not established such parity.

Relying on People’s Union for Democratic Rights v. Union of India, (1982) 3 SCC 235, the decision recognised that nominal remuneration may, in appropriate circumstances, implicate the constitutional protection against forced labour under Article 23.

It also invoked Article 43’s directive concerning a living wage and decent conditions of work, while treating minimum-wage rates as a benchmark for assessing adequacy—not as an entitlement under the Minimum Wages Act.

The cited authorities included Monirujjaman Mullick, Steel Authority of India Ltd. v. Dibyendu Bhattacharya, and Randhir Singh v. Union of India on pay parity, and Kesavananda Bharati on the constitutional role of Directive Principles.

The Court noted that the State had not shown any material distinction between this case and Laxman Singh Dhakar.

It therefore applied that decision mutatis mutandis, including its conclusion that the petitioners had not established an entitlement to equal pay or minimum wages, but that the adequacy of their honorarium should be reconsidered in light of the principles discussed there.

Accordingly, the State’s direction to reconsider the adequacy of honorarium, and to complete that exercise within three months, applied to these petitioners as well.