In Bandhua Mukti Morcha v. Union of India (1984), the Supreme Court recognized that bonded labour violates right to life and personal liberty under Article ______, and directed rehabilitation, release of bonded labourers as part of State's positive obligation.

Answer: 21

Bandhua Mukti Morcha (1984) bonded labour and Article 21: (a) Context: Petition regarding bonded labour in stone quarries of Haryana; issue of State's obligation to release, rehabilitate bonded labourers, (b) Supreme Court holding: (i) Bonded labour violates right to life and personal liberty under Article 21 (dignity, autonomy), (ii) State has positive obligation to identify, release, rehabilitate bonded labourers, (iii) Used PIL mechanism: Relaxed locus standi to enable public-spirited organizations to file for marginalized groups unable to approach courts, (c) Applications: (i) Bonded Labour System (Abolition) Act, 1976: Court directed effective implementation, rehabilitation schemes, (ii) Judicial monitoring: Courts periodically review implementation, direct compensation, rehabilitation for released labourers, (iii) Awareness: Legal literacy programs empower bonded labourers to claim rights, access justice, (d) Subsequent developments: (i) Rehabilitation schemes: State/Central governments implement rehabilitation packages (land, housing, skill training) for released labourers, (ii) Monitoring mechanisms: District-level committees monitor identification, release, rehabilitation of bonded labourers, (e) Rationale: (i) Dignity: Bonded labour violates human dignity, autonomy; Article 21 requires State to protect vulnerable groups, (ii) Positive obligation: State must take affirmative steps to realize rights, not just refrain from violation, (iii) Social justice: Releasing bonded labourers advances substantive equality, social transformation, (f) Illustrates transformative constitutionalism: Article 21 interpreted to impose positive obligations on State for marginalized groups; PIL enables judicial enforcement of socio-economic rights through State action.