Rana Pratap Singh v. Govt. of NCT of Delhi & Anr.

Delhi HC15 May 2026LPA/370/2026

Case brief

AI extract

What is this about?

Prisoner (Tihar Jail) awarded revised minimum wages under Minimum Wages Act, 1948 framework via Commissioner (Labour) order dated 20.04.2023, effective 01.04.2023, with arrears extending to all prisoners in Scheduled Employment; LPA allowed, Single Judge's committee-representation route set aside; comparable relief previously granted in W.P.(C) 8299/2023 (04.12.2023). Key terms: prison labour, minimum wages, Scheduled Employment, arrears, GNCTD, intra-Court appeal.

What did the court decide?

Impugned Single Judge order dated 17.04.2026 set aside; Respondents (GNCTD) directed to implement the Commissioner (Labour) order dated 20.04.2023 with effect from 01.04.2023; minimum-wage payments to commence within two weeks and arrears to be paid within six weeks to the Appellant and all other prisoners employed in Scheduled Employment. ¶¶29

Rana Pratap Singh Vs Govt. of NCT of Delhi & Anr. — Delhi HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

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Issue for consideration

Whether the learned Single Judge's disposal of W.P.(C) 2656/2025 by merely permitting a written representation before the Registrar General (to be considered by a committee) was relevant or adequate for adjudicating the Appellant's prayer for revised prison-labour wages. +1 more

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Court's answer

The direction for representation to be decided by a committee of this Court does not appear relevant for adjudication of the prayer made in the Writ Petition.

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Ratio / Principle

The Commissioner (Labour) order dated 20.04.2023 owes its origin to the Minimum Wages Act, 1948, must be applied and followed for payment of wages to all categories of workmen employed in Scheduled Employment, and wages offered to a convict lodged in Tihar Jail employed in any Scheduled Employment cannot be an exception.

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Key takeaways

In view of the earlier disposal in W.P.(C) 8299/2023 (payment of revised minimum wages from the date of increase/implementation in GNCTD and not from 14.11.2023), there is no reason why the minimum wages demanded by the Appellant in terms of the Commissioner (Labour) order dated 20.04.2023 cannot be provided to him.ratio¶¶28
The Appeal is allowed and the Impugned Order dated 17.04.2026 passed by the learned Single Judge is set aside.ratio¶¶29
The Respondents are directed to implement the order dated 20.04.2023 issued by the office of the Commissioner (Labour), GNCTD with effect from the date the minimum wages were increased and implemented in GNCTD, i.e., with effect from 01.04.2023.

Detailed headnote1 paragraphs

Letters Patent Appeal (LPA 370/2026) by a prisoner against a learned Single Judge's order dated 17.04.2026 disposing of W.P.(C) 2656/2025 by merely permitting a written representation before the Registrar General, to be considered by a committee. The Division Bench (Devendra Kumar Upadhyaya, CJ, orally, and Tejas Karia, J) held that the Commissioner (Labour) order dated 20.04.2023 revising minimum wages, owing its origin to the Minimum Wages Act, 1948, applies to all categories of workmen in Scheduled Employment and cannot exclude a convict lodged in Tihar Jail so employed; the committee-route direction was held irrelevant to adjudication of the writ prayer. Reliance was placed on the earlier order dated 04.12.2023 in W.P.(C) 8299/2023 directing payment of revised minimum wages from the date of increase/implementation in GNCTD rather than a later cut-off. Appeal allowed; impugned order set aside; Respondents directed to implement the 20.04.2023 order with effect from 01.04.2023, payments to commence within two weeks, and arrears to be paid within six weeks to the Appellant and all other prisoners employed in Scheduled Employment.

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$~56

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* IN THE HIGH COURT OF DELHI AT NEW DELHI

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% Date of Decision: 15.05.2026

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+ LPA 370/2026

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RANA PRATAP SINGH .....Appellant Through: Mr. Jai Wadhwa & Mr. Ronak Karanpuria, Advocates.

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versus

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GOVT. OF NCT OF DELHI & ANR. .....Respondents Through: Mr. Sameer VashishtStanding Counsel along with Mr. Raghvendra UpadhyayPanel Counsel, Ms. Purnima Jain & Ms. Shivpa Taneja, Advocates for Respondent Nos.1 & 2.

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CORAM: HON'BLE THE CHIEF JUSTICE HON'BLE MR. JUSTICE TEJAS KARIA

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DEVENDRA KUMAR UPADHYAYA, CJ ( ORAL )

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CM APPL. 32911/2026 (Exemption)

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Exemption is allowed, subject to all just exceptions.

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The Application stands disposed of.

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LPA 370/2026

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Heard the learned Counsel for the Parties.

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LPA 370/2026

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Page 1 of 4

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Signature Not Verified Signed By:NEELAM SHARMA Signing Da te:1 6.05.2026 15:42:15

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This intra-Court Appeal seeks an exception to an order dated 17.04.2026 (“ Impugned Order ”) passed by the learned Single Judge whereby W.P.(C) 2656/2025 has been disposed of permitting the Appellant to file a written representation along with a copy of the Writ Petition and all other necessary documents before the Registrar General of this Court.

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It was further stipulated that if any such representation is made by the Appellant, the same shall be placed before the concerned committee for consideration.

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The prayer made in the Writ Petition was for implementing the revised wages for prison labour in terms of order dated 20.04.2023 by the Office of the Commissioner (Labour) with effect from 01.04.2023 along with payment of consequential arrears. The order dated 20.04.2023 passed by the Commissioner (Labour) has revised the rates of minimum wages to be paid to unskilled, semi-skilled and skilled categories of workmen in all Scheduled Employment.

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The order dated 20.04.2023, thus, owes its origin to the Minimum Wages Act, 1948 and has to be applied and followed for the purpose of payment of wages to all categories of workmen employed in the Schedule Employment and, therefore, any such wages being offered to a convict lodged in Tihar Jail employed in any Scheduled Employment cannot be an exception.

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In our opinion, direction for representation to be decided by the committee of this Court does not appear to be relevant for the purposes of adjudicating the prayer made by the Appellant while instituting the Writ Petition.

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LPA 370/2026

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Page 2 of 4

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Signature Not Verified Signed By:NEELAM SHARMA Signing Da te:1 6.05.2026 15:42:15

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We may also refer to an order dated 04.12.2023 passed in W.P.(C) 8299/2023 which has been disposed of with a direction to the Respondents therein to pay the revised minimum wages to the Petitioners of the said Writ Petition with effect from the date when the minimum wages have been increased and implemented in the GNCTD and not from 14.11.2023. Paragraph No. 7 of the said order dated 04.12.2023 is extracted herein below:

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“7. Resultantly, the writ petition is allowed with a direction to the Respondents to pay the revised minimum wages to the Petitioner with effect from the date when the minimum wages have been increased and implemented in the GNCTD and not from 14.11.2023 as mentioned in the status report.”

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In view of the aforesaid, we do not see any reason as to why the minimum wages being demanded by the Appellant in terms of the order of Commissioner (Labour), dated 20.04.2023 cannot be provided to him.

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Accordingly, the Appeal is allowed and the Impugned Order passed by the learned Single Judge dated 17.04.2026 is hereby set aside. A direction is issued to the Respondents to implement the order dated 20.04.2023 issued by the office of the Commissioner (Labour), GNCTD with effect from the date the minimum wages have been increased and implemented in GNCTD i.e. with effect from 01.04.2023.

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There shall be no order as to costs.

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We direct that the payment of minimum wages in terms of order dated 20.04.2023 passed by the Commissioner (Labour) shall commence within a period of two weeks from today and arrears of the same shall also be paid not only to the Appellant but also to all other prisoners employed in Scheduled

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LPA 370/2026

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Page 3 of 4

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Signature Not Verified

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Signed By:NEELAM SHARMA Signing Da te:1 6.05.2026 15:42:15

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Employment, within a period six weeks. This Order shall be communicated forthwith by Mr. Sameer Vashisht, learned Standing Counsel representing GNCTD through all concerned.

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DEVENDRA KUMAR UPADHYAYA, CJ

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TEJAS KARIA, J

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MAY 15, 2026 / ‘A’

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LPA 370/2026

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Page 4 of 4

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Signature Not Verified