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Monday, August 18, 2025

Empowering the Gig Worker- Comparative Insights and Pathways for Reform.

Godala Alexandria Minakshi Devi,

3rd Year, LLB, University of Leeds, UK

Abstract


This research examines the legal status of gig workers in India, a rapidly growing workforce segment. Despite the significant contribution of the gig economy, existing labour lawsfail to address the unique challenges and vulnerabilities these workers face. While the Social Security Code 2020 offers some benefits, its implementation remains weak. Although some states have introduced legislation to benefit gig workers, there needs to be an effort all over India, and implementation needs to be effective. Drawing parallels with the UK, where the landmark Uber v Aslam case emphasised the reality of work over contractual terms, this research advocates a shift in focus in India. Key recommendations for reform include clear legal definitions, minimum wage guarantees, collective bargaining rights, and more vigorous enforcement mechanisms. By implementing these reforms, India can ensure that the benefits of the gig economy are shared equitably and that gig workers have the necessary protections to thrive in this dynamic and increasingly important sector.


Introduction


The gig economy supports flexible and on-demand work opportunities and has changed the global economy. The gig economy uses advancements in technology and digital platforms, and it connects workers with consumers for tasks and services, often supported by apps and websites. This model has reshaped traditional employment structures, offering benefits like autonomy and flexibility while posing challenges to job security, working hours and minimum wage.

Historically, labour laws in India have focused on formal employment relationships, which leaves gig workers outside their protective framework. Traditional laws, such as the Minimum Wages Act of 1948 and the Industrial Disputes Act of 1947, do not apply to gig workers, and they do not have critical protections such as minimum wages, social security, and safeguards against unfair termination.

Gig Workers in India can be broadly classified as platform workers who perform tasks through digital apps like food delivery or ride-sharing apps and non–platform workers who operate independently, such as freelancers or construction workers. While gig work offers flexibility and income opportunities, it exposes workers to vulnerabilities such as inconsistent earnings, lack of benefits, and absence of formal grievance redressal mechanisms.

Recognising these challenges, the Indian government introduced the Code on Social Security, 2020, which formally defines gig and platform workers. The Code proposes measures such as life and disability insurance, accident coverage, and a social security fund financed partly by platform aggregators. However, implementing these measures remains limited, and gig workers lack awareness and face difficulty accessing benefits. Moreover, the current framework does not address fundamental labour rights, including minimum wage guarantees and collective bargaining.

State-level initiatives, such as the Rajasthan Platform-Based Gig Workers (Registration and Welfare) Act, 2023, and the proposed Karnataka Platform-Based Gig Workers (Social Security and Welfare) Bill, 2024, represent significant steps toward improving the welfare of gig workers.These legislations aim to establish welfare boards, enforce registration mechanisms, and create social security funds for gig workers. Despite these efforts, challenges persist in providing comprehensive protection and ensuring effective enforcement.

Globally, experiences of countries like the United Kingdom offer valuable insights into addressing gig worker vulnerabilities. The landmark Uber v Aslam Judgement emphasised recognising the realities of employment relationships over contractual terms, granting workers essential rights like minimum wages and regulated working hours. Such approaches highlight the need for clear legal definitions and robust enforcement mechanisms to protect gig workers without compromising the flexibility inherent in gig work.

In conclusion, the gig economy holds immense potential to drive economic growth and provide employment opportunities. However, its success depends on balancing flexibility and worker protection. By learning from international best practices and strengthening domestic frameworks, India can ensure that its gig workers receive equitable treatment and integrate them into a sustainable labour system.


The current legal status of gig workers in India

The gig economy is a new phenomenon emerging from technological advancements and the digital economy.[1] According to Radhakrishnan and Singha Roy, the gig economy is ‘the collection of markets that match providers to consumers on a gig (or job) basis in support of on-demand commerce.'[2]India has 15 million gig workers, making up 40% of the global gig workers; it is the fifth largest gig economy.[3]A recent study by NITI Aayog (National Institution for Transforming India) found that the number of gig economy workers will rise to 23.5 million by 2029-30.[4]

 Historically, labour laws in many countries, including India, were designed around the traditional employee-employer relationship, leaving those in atypical work arrangements outside the scope.[5] The Minimum Wages Act of 1948 tried to ensure that workers in specific industries receive minimum wages for their labour to prevent exploitation and maintain living standards. [6] This Act aimed to ensure fair compensation for workers in specific industries by giving the state governments the authority to set and revise wage rates according to the present circumstances. It also established the regulation for working hours, overtime, and other labour conditions.[7] 

Similarly, the Industrial Disputes Act 1947 focuses on resolving industrial disputes and promotes industrial peace through conciliation, arbitration, and adjudication. It applies to formal industries, including manufacturing, trade, business, and services establishments with a clear employer-employee relationship.[8]The Act provides key worker protections, such as prohibitions on unfair labour practices, rights related to layoffs, retrenchments, and terminations, and mandatory notice and compensation for retrenched employees. It also mandates the formation of works committees in establishments with one hundred or more workers to address grievances and regulates the legality of strikes.[9]

Gig Workers in India cannot benefit from the progressive provisions in The Minimum Wages Act 1948 and The Industrial Disputes Act 1947, as they do not fall under the traditional employee category.[10] The platforms classify them as independent contractors rather than traditional employees.[11]According to the 2022 report by an international research project called Fair Work India, gig workers' rights have no statutory affirmation.  Accordingly, Gig workers are not traditional workers.[12]
Due to the non-traditional nature of gig work, even the Code on Wages 2019 does not explicitly address gig workers within its provisions.[13] The Code primarily focuses on the employee-employer relationship, setting standards for minimum wages, equal remuneration, and employee payment timelines.
The Code on Social Security 2020 defines gig workers as individuals who perform work or participate in work arrangements and earn from such work outside the traditional employee-employer relationship.[14]The Ministry of Labour and Employment suggests the Code on Social Security, 2020, introduces several provisions to extend social security benefits to gig and platform workers in India.[15] These include life and disability cover, which mandates the formulation of schemes to provide life insurance and disability benefits to gig workers, ensuring financial support in case of death or disability arising out of work, accident insurance, which requires gig workers to be covered under accident insurance schemes, offering compensation for injuries sustained during their work, health and maternity benefits, old age protection and a social security fund to finance their welfare schemes, aggregators are required to contribute 1- 2% of their annual turnover, subject to a limit of 5 % of the amount paid or payable to gig workers to this fund.[16] Finally, gig workers can register to receive benefits under various government welfare schemes. [17]
It is apparent that The Code on Social Security 2020, for the first time, brought gig workers into the category of employment rights. It provides for framing suitable social security schemes like life and disability coverage, accident insurance, and health and old age protection. Although this Code allows employees to have benefits like gratuity, employee compensation, insurance, provident fund, and maternity benefits, the Code only demands that central and state governments formulate suitable social security schemes for gig workers.[18]

The Social Security Code 2020 acknowledges the situation of gig workers and provides them with some benefits. However, they lack the essential rights all workers in all fields of employment should have. Of the Labour codes in India, only the Code related to social security is relevant to gig workers; as a result, Gig workers cannot get protections offered by other codes like the National minimum wage, occupational safety, and overtime pay.[19]Moreover, gig workers cannot access specialised redressal mechanisms under the Industrial Disputes Act 1947.[20] Also, they are not entitled to collective bargaining due to their non-conventional work.  Even though the Social Security Code 2020 might not be that extensive, it is commendable that India has taken a step forward in legally protecting gig workers. An extensive mechanism to protect gig workers' legal rights is vital.

Additionally, the rapid expansion of the gig economy in India has led to the creation of laws by the states of Rajasthan and Karnataka to protect the rights and welfare of gig workers. This article delves into the specifics of the Rajasthan platform-based Gig Workers (Registration and Welfare) Act, 2023 and the proposed Karnataka Platform-Based Gig Workers (Social Security and Welfare) Bill 2024, analysing their provisions, specific impact,and the challenges they might encounter.

The Rajasthan Platform-Based Gig Workers (Registration and Welfare) Act,2023, was enacted on July 24, 2023. The Rajasthan legislation has pioneered India in providing Social Security and welfare benefits to gig workers at an extensive level. The key provisions of this Act include:

Establishment of a Welfare Board: The Act mandates the creation of the Rajasthan Platform-Based Gig Workers Welfare Board, Headquartered in Jaipur. This Board comprises representatives from aggregators, gig workers, and various government departments, ensuring a tripartite approach to governance. Its primary responsibilities 1.      include registering gig workers and aggregators, overseeing the implementation of social security schemes, and ensuring compliance with the Act’s provisions.[21]

2.      Registration Mechanism: Aggregators must submit a database of all their platform-based gig workers to the Board within sixty days of the Act's enforcement; this facilitates the automatic registration of gig workers, each receiving a unique identification number. Such a system aims to bring gig workers under labour regulation, enabling them to access social security benefits and other entitlements.[22]

3.      Social Security and welfare fund: The Act introduces a welfare fee, ranging from 1% to 2% of the value of each transaction involving gig workers, which charges the aggregators. This fee contributes to the Rajasthan Platform-Based Gig Workers Social Security and Welfare Fund, which finances various social security schemes, including health insurance, accident coverage and other welfare measures.[23]

4.      Grievance redressal mechanism: Registered gig workers under this mechanism can file a complaint with the appropriate authority, as this Act requires;[24]this ensures that gig workers can cope with work-related issues and get fair treatment.

5.      Penalties for Non-compliance: The Act stipulates stringent penalties for aggregators and primary employers who violate its provisions, with fines reaching up to fifty lakhs for aggregators; this deters non-compliance and ensures adherence to the Act’s mandate. [25]

Following Rajasthan, Karnataka also proposed the Karnataka Platform-based Gig Workers (Social Security and Welfare) Bill, 2024, which aims to safeguard the rights of the platform-based gig workers but imposes obligations on aggregators concerning social security, occupational health, and safety.[26]It establishes a comprehensive definition of gig workers, encompassing individuals engaged in various sectors such as ride-sharing, food and grocery delivery, logistics, e-marketplaces, professional services, healthcare, travel and hospitality and content and media services. [27]The Bill proposes creating the Karnataka platform-based gig workers welfare board, which will register gig workers and aggregators, implement social security schemes, and ensure compliance with the Bill's provisions. [28] It mandates that contracts between gig workers and aggregators be fair and written in simple Kannada, English, or any language listed in the constitution of India. Mandating the contracts to be simple and written in a local or understandable language will empower gig workers because ‘armies of lawyers' draft employment contracts. These contracts are often used to misrepresent the realities of the working relationship and cleverly exclude someone from attaining worker status for the employer's benefit. [29]In other words, as McClelland, a researcher focusing on gig workers in the UK, suggests, individuals who hire gig workers often possess greater bargaining power than those hired.[30] The Bill introduces safeguards against arbitrary termination, requiring aggregators to provide a valid 14-day notice period before dismissing a gig worker, addressing concerns over job security; this is an excellent provision because employers often fire gig workers due to the algorithmic calculations of customer reviews, and it is not always possible for the worker to keep up with the reviews.[31]Additionally, it proposes establishing a dispute resolution mechanism, which would provide gig workers with a formal way to resolve conflicts related to employment terms, working conditions, and work-related issues. [32]
The Rajasthan Platform-Based Gig Workers (Registration and Welfare) Act, 2023, and the Karnataka Platform-Based Gig Workers (Social Security and Welfare) Bill, 2024, are significant in protecting gig workers. Nevertheless, they do not explicitly propose establishing minimum wage standards or regulating working hours for gig workers. Both laws propose a grievance redressal mechanism system; however, the Rajasthan Act lacks detailed procedures, making it difficult for workers to seek remedies, and the Karnataka Bill introduces a two-level grievance redressal system, but this might not be effective if it is not accessible to workers. Therefore, governments need to promote awareness of these acts.Neither legislation explicitly grants gig workers the right to collective bargaining, an important right to empower workers to voice their concerns.

In conclusion, the Rajasthan Act, and the Karnataka Bill mark considerable progress in addressing the challenges faced by gig workers in India. However, these laws need precise definitions, better implementation strategies, and awareness campaigns to inform workers about their rights to be truly effective. Additionally, grievance redressal mechanisms must be accessible and efficient to ensure timely dispute resolution.


The situation of gig workers in The United Kingdom

This research examines the landmark case of Uber v Aslam, a UK judgement withsignificant benefits for determining the employment status of people in the gig economy.[33] The Supreme Court prioritised the reality of Uber's relationship with the drivers over the written contract, employing a purposive approach to determining worker status. This approach considers factors like control and subordination to which the workers are subject. One must appreciate The Supreme Court's efforts in examining reality, as written contracts often misrepresent it.

Moreover, The Supreme Court has shifted from the traditional mutuality of obligations, prioritising an ongoing exchange between the employer and the putative worker, to giving importance to the minimum irreducible to work. In other words, they considered the drivers working while logged into the app. This liberal stance towards mutuality will not cause employers to misrepresent the employment status using mutuality clauses.

Nevertheless, Uber BV v Aslam's impact on determining employment status has certain limitations. Employers may still find loopholes that misrepresent employment status; for instance, Deliveroo created a sham contract using substitution clauses, and the court had to accept this contract as there was a rare but occasional use of substitutes. It is evident that given the courts' limitations in enforcing employment rights, legislative change can protect the employment rights of vulnerable people working in atypical environments by providing for stabilising contracts and imposing fines for misrepresenting employment status. Moreover, a single unified test to determine employment status would also eliminate any confusion regarding determining it and would deter employers from misrepresenting employment status.

The purposive method has assisted Uber drivers to fall within s.230(3)(b) of the Employment Rights Act 1996 or the Limb (b) worker category, which offers some critical employment rights like National minimum wage and the right to restrict their working hours.[34] Uber drafted contractual agreements that depicted it as only a technology platform that acts as an agent for drivers,[35]which was far from the truth, as Uber significantly controlled the drivers to the extent that the platform decided their fares for the rides; they were required to maintain a specific rating and accept rides constantly.  Otherwise, the app logs them off for about ten minutes.[36] Hence, the Supreme Court was required to examine the drivers' control, subordination, and level of integration into Uber. [37] The court developed this approach in Autoclenz, where it also ruled to set aside contractual documents if they differ from the actual agreement.[38]

Nevertheless, Scholars argue that the court cannot question the fairness of the exchange between the parties, as they have the freedom to contract freely without coercion.[39] Moreover, it is also contended that disregarding the contractual terms might create confusion regarding the situation's reality. The Parol evidence rule evidences this by suggesting the inadmissibility of any extrinsic evidence not present in the contractual documents.[40] Underhill LJ in the Court of Appeal also affirmed the importance of contractual agreements between the parties by suggesting that Uber’s connection with the parties is not the only one that the Law protects.[41]Sir Patrick Elias's similar point supports his argument, which asserted that courts cannot discard any express terms agreed to in the contract. [42]

Although concerned academics and judges disagree with using the purposive approach and discuss its negative impacts, "armies of lawyers" draft employment contracts, these contracts are often used to misrepresent the realities of the working relationship and cleverly exclude someone from attaining worker status for the employer's benefit. [43] In other words, as McClelland suggests, the hiring persons often have a higher bargaining power than the ones getting hired. 19Nevertheless, the courts do not always undermine contractual agreements when they are not necessary or when the contractual documents represent the reality of the situation. For instance, the court was less willing to intervene when both parties to the contract willingly applied the self-employed label in Massey v Crown Life Insurance.[44] Furthermore, the court in Ready Mixed Concrete v Minister of Pensions decided that the person concerned was not an employee as he was allowed to exercise significant control over his work.[45]Thus, as noted by Adams-Prassl, Uber's judgement focuses on the marginalised people designated as self–employed independent contractors due to unfair contractual terms.[46]

The Supreme Court's ruling reaffirms and expands on the approach used in Autoclenz, emphasising that the focus in establishing worker status is on the genuine connection between the putative worker and the putative employer. The critical issue is whether the appropriate legislation protects the relationship. It is firmly established in this case that contractual documents do not serve as a starting point which benefits people in the gig economy.

The court’s decision in Uber v Aslam to shift from the traditional view of mutuality of obligation will also positively impact the determination of the employment status of the people in the gig economy.[47]  According to Atkinson J and Dhorajiwala H, people working in the gig economy or zero-contract workers are less likely to be classified as workers due to a lack of mutuality of obligations.[48]

The traditional view of mutuality of obligations is ‘a contractual consideration in a single engagement or an ongoing obligation to offer and accept work’.[49] In O'Kelly v Trusthouse, the court endorsed this view by deciding that casual waiters are not employees because they are not obligated to accept work, and employers are not obligated to offer work.[50]McGaughey argues that by applying this view of mutuality to zero-hour contract workers, they will always be designated as self-employed, as the employers can draft contracts to deny the existence of any mutuality between the parties. [51]

 

According to Moore, there is also a hidden intention behind the employer's intention to deny mutuality and claim that workers can refuse to accept work. When workers refuse to work, employers can deny them future employment, making them commit to the employer,[52]this indicates that even if employers deny the existence of mutual obligations, the putative workers would still be obligated to work, and they would seldom use the right to refuse work as they would be denied work in the future.  Moreover, it is a clever way for employers to evade workers' employment rights; this was the precise situation in Uber-when the workers did not accept the rides for a certain period, Uber denied them work, and if the court did not deny the traditional mutuality test in Uber, the drivers would be denied worker status as Uber argued that the workers did not have an ongoing obligation to offer and accept work and this lack of obligation does not logically create a contractual obligation to work for uber.[53]However, the Supreme Court in Uber vehemently contended that the drivers are working when logged into the app, and their ability to turn down specific requests does not mean that they are not workers, as there is a minimum irreducible to work. One could consider this.[54]

The Supreme Court in Uber further quoted Elias J in James v Redcats (Brands) Ltd, where it could draw a comparison between Uber drivers and other casual workers who have no obligations between their engagements, but this does not disqualify them from having employment status.[55]In other words, absence or gaps in work should not affect a worker's status during the working period.  The Supreme Court's decision to view the mutuality of obligations in this manner, to consider the minimumirreducible importance, and to imply this to be a consideration will help Uber drivers and have a broader impact on the gig economy. Employers would not be able to misrepresent employment contracts using mutuality of obligations.

Although the Supreme Court in Uber v Aslam has taken a liberal stance towards mutuality clauses, the same has not occurred in cases where parties have used substitution clauses.[56] In some instances, like Pimlico Plumbers, the Supreme Court upheld employment rights even when there was a right to use a substitute. [57]  Furthermore, the courts have held that the right to use a substitute is consistent with worker status when the worker is unable to perform.[58]

However, personal performance remains an important factor in considering someone to be a worker.[59]  Although Uber v Aslam has used a purposive approach, which is quite liberal, to determine the worker status while considering factors like control and subordination the workers are being subject to, the Act of affirming personal performance, in this case, will provide an unduly fertile ground for these gig economy services to find loopholes and create sham contracts through the right to use substitutes.

This is the precise situation in Independent Workers Union of Great Britain (Appellant) v Central Arbitration Committee and another case, in which the court determined that the Deliveroo cyclists do not have worker status because they have an unfettered right to use substitutes.[60] Pitt comments that the right to use substitute was an unnecessary requirement that Deliveroo decided to use because the rider can log off from the app when he chooses not to work,[61]which depicts that Deliveroo has created the right to use a substitute to evade employment rights and not confer worker status upon the riders.  Ford argues that gig economy platforms like Deliveroo imposes hard and uninterrupted work upon the riders and substitutes sometimes become inevitable.[62] The court still held them not to be workers. However, personal performance was a dominant feature of their work, demonstrating that although substantial, the court's endeavours in Uber v Aslam do not drastically change the situation of people working in the gig economy, as employers can find loopholes to make the people working look self-employed.

Adams-Prassl has argued that the employment tribunal has become the only source of enforcing employment rights. He also emphasises the significant costs and delays involved in individual litigation. [63] The extent to which platforms like Uber will comply with these judgements is very uncertain, which could leave workers vulnerable.[64] Atkinson agrees with this and claims that the UK’s approach towards protecting gig economy workers is weak as it lacks substantial legislative reforms. [65]

 In contrast, the Spanish case of Glovo led to swift legislative change, and Authorities fined Glovo for misrepresenting the delivery workers as self-employed.[66] Atkinson also suggests stabilising contracts, such as allowing casual workers to request a more stable contract after weeks of service.[67] Another strategy could be to impose fines for fraud, such as misrepresenting employment status and attempting to profit from it.[68]

As part of its Good Work plan (2018), the UK government also discussed that legislation does not clarify what constitutes an employment contract and the employment tribunal’s efforts to create multiple tests to understand employment status.[69] Hence, another element of the UK's approach to labour law cases is the absence of a unified test to determine individuals' employment status.  Multiple outdated tests, like the test of mutuality, personal performance, and control, are argued to lead to confusion, make it challenging to determine employment status, and create a leeway for gig economy platforms to find loopholes to evade employment rights.[70] Thus, having a single unified test might considerably solve confusion regarding determining employment status.

These strategies and the decision's impact in Uber v Aslam will deter employers from misrepresenting and creating sham contracts. Nevertheless, individual litigation and the courts as the only source of enforcing employment rights will not have a significant impact, as employers might find loopholes.[71]

What India can learn from the United Kingdom?

India can draw lessons from the UK’s Uber v Aslam ruling, which emphasised the actual working relationship over written contractual terms. The UK Supreme Court's purposive approach to determining worker status ensures employers cannot use cleverly drafted contracts to misrepresent employment status. Indian courts must consider that although Employers classify these gig workers as independent contractors, they often function under severe employer control and restrictions.

Secondly, the UK's distinction between employees, self-employed individuals, and Limb (b) workers provides a clear framework reflecting the modern world's complexities. By creating an intermediate worker category, gig workers could access essential rights like minimum wages and social security without requiring full employment status.

Thirdly, the UK ensures that gig workers classified under Limb (b) are entitled to a national minimum wage and restrictions on excessive working hours. India lacks equivalent protections, leaving gig workers vulnerable to exploitation and poor compensation. Learning from the UK’s approach, India could establish statutory minimum wage guarantees for gig workers and regulate their working hours.

Fourth, the UK’s national insurance system and employment tribunals provide a structured framework for enforcing gig workers' rights. India's legislative efforts, such as the Social Security Code 2020, suffer from weak enforcement and a lack of worker awareness. India can adopt streamlined grievance redressal mechanisms and accessible judicial processes to ensure compliance with its laws.

What the UK can learn from India?

Firstly, India’s recent efforts to improve the position of gig workers through legislative provisions are commendable; they reflect a commitment to addressing the unique challenges of gig work. The UK could benefit from these legislative measuresrather than rely heavily on judicial interpretation.

Secondly, India’s Law mandates that aggregators contribute a percentage of their turnover to social security funds for gig workers. This model ensures a continuous funding mechanism for worker welfare schemes. The UK could implement a similar aggregator contribution system to supplement its national insurance framework.

India’s recognition of the need to tailor policies to meet the specific needs of certain states is commendable. The UK could invest in a similar legislative framework to meet the requirements of various parts of the country.

Lastly and most importantly, the Karnataka bill proposes safeguards against the arbitrary dismissal of gig workers. As discussed previously, Employers dismiss gig workers chiefly based on bad customer reviews and algorithmic analysis. This is a critical area where the UK could improve and safeguard gig workers against arbitrary dismissal.

Reforms that would change the situation of gig workers in India.

First, gig workers must be classified clearly within labour laws to ensure that gig workers should receive appropriate rights and protections. The Social Security Code recognises gig workers but does not clearly define their status or offer adequate protection.[72]As discussed previously, the UK clearly defines gig workers as Limb (b) workers and guarantees them a national minimum wage. India should follow this model and set a minimum wage for gig workers to compensate them fairly. In addition, Platforms need to provide clear information on payment structures, including deductions and incentives, to promote transparency and trust. Paigam and Janpahal, non–profit organisations, also suggest guaranteeing a baseline income for gig workers. They also advise regular evaluation and adjustment to align with inflation and the cost of living. As suggested by Coyle, A British economist, gig workers do not choose to be self-employed and work in the gig economy because they profit from it but because they have no other choice. The suggestions of Paigam and Janpahalcorrelate with Coyle's statement and can significantly improve their situation. [73]

As mentioned, gig workers do not have the right to unionisation and collective bargaining. As a result, it is difficult for them to express their needs, making it difficult for even the government to understand what legislation they need to introduce to improve the situation of gig workers. Therefore, gig workers should be allowed to form or join unions to collectively negotiate better terms and conditions. Organisations like the Indian Federation of APP-based Transport Workers are crucial in advocating for gig workers' rights. Another suggestion could be to encourage gig workers and representatives of platforms to be a part of the committee and understand concerns.

Conclusion

It is a fact that the gig economy has emerged as a formidable force in the global labour market, offering many opportunities and flexibilities. In India, this would lead to the potential growth of the labour force, which would offer many job opportunities. However, as the gig economy is a non-traditional work sector, the workers face many problems like job security; regulating working hours and minimum wage remain a concern as few legal protections solve their problems.

India’s existing labour laws, such as the Minimum Wages Act of 1948 and the Industrial Disputes Act of 1947, were designed for traditional employment models and failed to address the needs of gig workers. While introducing the Code on Social Security 2020 represents a crucial step toward recognising gig workers, its implementation remains limited. Different measures introduced by this Code, like disability and life insurance, accident coverage, and a social security fund, are commendable. However, it does not address critical rights such as minimum wage guarantees, regulating working hours, and collective bargaining. Furthermore, the reliance on self-registration and the lack of awareness among gig workers exacerbate their exclusion from their benefits.

State–level initiatives, including the Rajasthan Platform-Based Gig Workers (Registration and Welfare) Act, 2023, and the proposed Karnataka Platform-Based Gig Workers (Social Security and Welfare) Bill, 2024, mark progressive steps in bridging these gaps. These legislations establish welfare boards, introduce grievance redressal mechanisms, and mandate contributions from aggregators to social security funds. However, their limited scope and lack of focus on foundational labour rights leave gig workers vulnerable to exploitation and bad working conditions.

Globally, countries like the United Kingdom have taken significant strides in addressing gig worker issues. The landmark Uber v Aslam has addressed this issue by recognising the realities of employment and its diversity. The government of India and state governments must understand that progress will lie in clearly defining employment categories, minimum wage guarantees, and the right to collective bargaining. The most important lesson from the United Kingdom is to understand that these workers must have a separate category. The UK describes these workers as Limb (b) and provides certain benefits like minimum wage.

India’s path moving forward should be to create a comprehensive legal framework tailored to the unique needs of workers in India. The Indian government needs to introduce laws that address the basic needs of gig workers, like a minimum wage guarantee, regulating working hours, no penalty for refusing to do a specific task, social security provisions and the right to collective bargaining. All the states of India must introduce laws to ensure all gig workers have access to these rights. In addition, the central and state governments also need to ensure that gig workers are aware of these laws and can benefit from them. The government needs to use a robust administrative mechanism.

Lastly, by balancing flexibility with robust protections, India can ensure that gig workers are included within the formal labour system and empowered to thrive.


[1]Gig Economy Workers’ Livelihood: A Qualitative Study of Ride-Hailing Platforms in Bangalore City, India<https://gipe.ac.in/gig-economy-workers-livelihood-a-qualitative-study-of-ride-hailing-platforms-in-bangalore-city-india/#:~:text=With%20over%2050%20per%20cent,hailing%20platforms%20is%20indeed%20strenuous.> accessed 30 December 2024.

[2] ibid

[3]Rahul Kumar and Shreya Sharma, 'Understanding Gig Work in India: Challenges and Prospects' (2024) SSRN <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4558703> accessed 30 December 2024.

[4]NITI Aayog, 'India's Booming Gig and Platform Economy: Policy Brief' (27 June 2022) <https://www.niti.gov.in/sites/default/files/2023-06/Policy_Brief_India%27s_Booming_Gig_and_Platform_Economy_27062022.pdf> accessed 30 December 2024

[5]Centre for Labour Laws, 'The Unsettled Status of Gig Workers in India: Towards a Comprehensive Legal Framework' (NLIU) <https://cll.nliu.ac.in/the-unsettled-status-of-gig-workers-in-india-towards-a-comprehensive-legal-framework/>accessed 25 December 2024.

[6]Minimum Wages Act 1948.

[7]Ibid

[8]Industrial Disputes Act, 1947

[9] Ibid

[10]Rahul Kumar and Shreya Sharma, 'Understanding Gig Work in India: Challenges and Prospects' (2024) SSRN <https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4558703 >accessed 30 December 2024

[11] Ibid 

[13] Code on Wages, 2019

[14]Ibid

[15]Social Security Code, 2020.

[16]Ibid 

[17]Social Security Code, 2020.

[18]Ulka Bhattacharyya and Soumya Jha, 'Understanding Social Security for Gig Workers' (2022) NLIU Law Review<https://nliulawreview.nliu.ac.in/wp-content/uploads/2022/02/3.-Understanding-Social-Security-for-Gig-Workers.pdf> accessed 1 January 2025

[19]ibid

[20]Ulka Bhattacharyya and Soumya Jha, 'Understanding Social Security for Gig Workers' (2022) NLIU Law Review<https://nliulawreview.nliu.ac.in/wp-content/uploads/2022/02/3.-Understanding-Social-Security-for-Gig-Workers.pdf>accessed 1 January 2025

[21]The Rajasthan Platform-based Gig Workers (Registration and Welfare) Act, 2023<https://prsindia.org/files/bills_acts/acts_states/rajasthan/2023/Act29of2023Rajasthan.pdf?utm_> accessed December 2025.

[22] ibid

[23]  Ashok Sanyal, 'The Gig Is Up: Pros and Cons of the Karnataka Gig Workers Bill' Mondaq (2024) <https://www.mondaq.com/india/employee-rights-labour-relations/1510600/the-gig-is-up-pros-and-cons-of-the-karnataka-gig-workers-bill?utm_> accessed December 2025.

[24] ibid

[25]Indus Law, 'Gig Workers: Legal Analysis' (2024) <https://induslaw.com/publications/pdf/alerts-2024/gig-workers-article.pdf?utm_> accessed December 2025.

[26]IndusLaw, 'Gig Workers: Legal Analysis' (2024) <https://induslaw.com/publications/pdf/alerts-2024/gig-workers-article.pdf?utm>accessed December 2025.

[27]ibid

[28]Vajiram and Ravi, 'What Does the Karnataka Bill Promise Gig Workers: Explained?' (2024) <https://vajiramandravi.com/upsc-daily-current-affairs/mains-articles/what-does-the-karnataka-bill-promise-gig-workers-explained/?> accessed December 2025.

[29]ibid

[30]Vajiram and Ravi, 'What Does the Karnataka Bill Promise Gig Workers: Explained?' (2024) <https://vajiramandravi.com/upsc-daily-current-affairs/mains-articles/what-does-the-karnataka-bill-promise-gig-workers-explained/?utm_> accessed December 2025.

[31]ibid

[32]Vajiram and Ravi, 'What Does the Karnataka Bill Promise Gig Workers: Explained?' (2024) <https://vajiramandravi.com/upsc-daily-current-affairs/mains-articles/what-does-the-karnataka-bill-promise-gig-workers-explained/?utm_> accessed December 2025.

[33][2021] UKSC 5, [2021] R.T.R. 29.

[34] s.230(3)(b) of the Employment Rights Act 1996

[35] ibid

[36]Uber BV v Aslam [2021] UKSC 5, [2021] R.T.R. 29.

[37] Ibid

[38]Autoclenz Limited v Belcher and others [2011] UKSC 41

[39] Julie McClelland, ’A Purposive Approach to Employment Protection or a Missed Opportunity?‘ (2012) 75(3) The Modern Law Review <https://www.jstor.org/stable/41682860> accessed 27 April 2024.

[40]Fabian McNeilly, ’Sham Self-Employment Contracts: Taking a Liberty?’ 2 (15) Manchester Law Review <https://hummedia.manchester.ac.uk/schools/law/main/research> accessed 28 April 2024

[40]Uber BV v Aslam [2018] EWCA civ 2748

[41]Uber BV v Aslam [2018] EWCA Civ 2748

[42] Patrick Elias, “Changes and Challenges to the Contract of Employment†” (2018) 38 (4) Oxford Journal of Legal Studies <https://doi.org/10.1093/ojls/gqy022> accessed 29 April 2024

[43]Consistent Group Ltd v Kalwak [2007] UKEAT 0535, [2007] IRLR 560

[44] [1978] 1 WLR 676

[45][1968] 1 All ER 433

[46] Diane Coyle, Jeremias Adams-Prassl and Abigail Adams-Prassl, “Uber and Beyond: Policy Implications for the UK” [2021] SSRN Electronic Journal < https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3823829> Accessed 27 April 2024 

[47][2021] UKSC 5, [2021] R.T.R. 29.

[48]Atkinson and Dhorajiwala (n 3)

[49]Cotswold Developments Construction Ltd v Williams [2006] IRLR 181

[50][1984] Q.B. 90 [1984] Q.B. 90[984] Q.B. 90[1984] Q.B. 90

[51] Ewan McGaughey, “Uber, the Taylor Review, Mutuality and the Duty Not to Misrepresent Employment Status” (2018) 48(2) Industrial Law Journal <https://doi.org/10.1093/indlaw/dwy014> accessed April 30 2024

[52] Marc T. Moore, ’Flexible Work: A Law and Economics Perspective’ (2006) University of Cambridge Faculty of Law Research Paper No. 12/2018 <University of Cambridge Faculty of Law Research Paper No. 12/2018>accessed 20 April 2024

[53]Uber BV v Aslam [2021] UKSC 5, [2021] R.T.R. 29

[54] ibid

[55] [2007] IRLR 296

[56] Michael Ford,' Pimlico Plumbers: Cutting the Gordian Knot of Substitution Clauses?' (UK Labour Law, 19 July 2018) <https://uklabourlawblog.com/2018/07/20/pimlico-plumbers-cutting-the-gordian-knot-of-substitution-clauses-michael-ford-qc/> accessed 20 April 2024

 [57][2017] ICR 657

[57]Ready Mixed Concrete (Southeast) Ltd v Minister of Pensions and National Insurance [1968] 2QB497

[59] Gwyneth Pitt, ' The Simple Things You See Are All Complicated' (UK Labour Law, 2024) <https://uklabourlawblog.com/2024/01/15/the-simple-things-you-see-are-all-complicated-thoughts-on-deliveroo-by-gwyneth-pitt/> accessed 20 April 2024 

[60] Ford (n 27)

[61] Coyle, Adams-Prassl and Adams-Prassl (n 16)

[62] ibid

[63] Joe Atkinson,’ Zero-hours contracts and English employment law: Developments and possibilities’ (2023) European Labour Law Journal 13(3)

 [64]<https://journals.sagepub.com/doi/epub/10.1177/20319525221104165> accessed 1 May 2024

[65]Tiago Vieira ’Platform couriers' self-exploitation: The case study of Glovo’ New Technology, Work and Employment (2023) 38(3) European University Institute< 

[66] https://onlinelibrary.wiley.com/doi/epdf/10.1111/ntwe.12272>

[67] Atkinson (n 36)

[68] Ewan McGaughey, “Uber, the Taylor Review, Mutuality and the Duty Not to Misrepresent Employment Status” (2018) 48(2) Industrial Law Journal <https://doi.org/10.1093/indlaw/dwy014> accessed April 30 2024

[69] Good Work Plan, (2018), Department for Business and Trade.

[70] Hugh Collins, ‘A Missed Opportunity of a Unified test for Employment Status’ (UK Labour Law, 31 July 2018) <https://uklabourlawblog.com/2018/07/31/a-missed-opportunity-of-a-unified-test-for-employment-status-hugh-collins/> accessed 25 April 2024

[71] Ibid 

[72]Centre for Labour Laws, 'The Unsettled Status of Gig Workers in India: Towards a Comprehensive Legal Framework' (NLIU, 2024) https://cll.nliu.ac.in/the-unsettled-status-of-gig-workers-in-india-towards-a-comprehensive-legal-framework/?utm_ accessed 1 January 2025.

[73]Ibid 


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