The curse of child labour: How dingy placement agencies exploit children in Delhi

Child labour: Delhi has been contending with a rise of placement agencies exploiting the labour of children since time immemorial; however, more often than not, the exploitation transcends into much more varied forms of harassment.

On October 27, the Delhi High Court ruled that the minor survivor, referred to as ‘X’, was subjected to a cavalcade of abuse by their former employer, Deepak Jain. The minor had been led to the meeting with Jain by the petitioner, Renu Tora, a self-proclaimed social activist and convenor of an NGO.

According to the FIR, the minor alleged that Renu Tora and a co-accused, Firoz, took her to meet her former employer, Jain. There, Jain handed over the victim’s wages to Firoz and Tora. The survivor stated that the money, which represented her earnings, was never given to her and was instead retained by the petitioner and her accomplice, Firoz, alias Mohammed Jumrat. Furthermore, the minor alleged that they informed her she would only receive the money if she made a false statement against Deepak Jain.

Tora had contended that she had been falsely implicated. She argued that the essential ingredients of Section 79 of the Juvenile Justice Act (JJ Act) were not satisfied, as she had never employed the victim. Her role, she claimed, was limited to assisting the victim in recovering payment from her former employer. Earlier, a trial court had concluded that Tora, along with Firoz, had withheld the earnings of the victim child and used them for their own purposes, thereby justifying the charge under Section 79.

The High Court upheld the Trial Court’s decision and dismissed the revision petition. It interpreted Section 79 of the JJ Act as comprising three distinct limbs, connected by the word “or”: ostensibly engaging a child and keeping him or her in bondage for employment; withholding his or her earnings; or using such earnings for one’s own purposes. The court emphasised that the existence of any one of these circumstances is sufficient to attract the provision.

Applying this interpretation, the Delhi HC found that the victim’s statement under Section 164 of the Cr.P.C., taken at face value, clearly indicated that the petitioner, in connivance with Firoz, had withheld the legitimate earnings of the child. This supported a prima facie case under the second and third limbs of Section 79. Accordingly, the Court identified no infirmity or illegality in the Trial Court’s order framing the charge. The petition was dismissed, with the clarification that the judgement expressed no opinion on the merits of the case.

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Child labour remains a disturbing reality in the national capital, with multiple incidents surfacing regularly.

In 2024, authorities in Delhi rescued 1,170 children in nearly 100 cases of child labour and trafficking. This marked a slight decline from 1,257 children rescued in 126 cases in 2023. These minors, often found working in hazardous conditions for minimal pay, endured long hours of exploitative labour — underlining the continuing crisis of child exploitation in India’s capital.

Tackling trafficking with surveillance and task forcesEfforts to curb child trafficking have intensified. Delhi Police’s Crime Branch has expanded surveillance and deployed Anti-Human Trafficking Units (AHTUs) across the city. “We are working relentlessly to curb trafficking incidents in Delhi,” said a senior police official. He explained that strategic placement of AHTUs and better coordination have made it easier to target trafficking and labour networks effectively.

Despite the decline in reported cases, non-governmental organisations (NGOs) warn that underreporting and changing trafficking tactics continue to hinder long-term progress.

One new challenge has emerged in the form of rogue placement agencies exploiting legal loopholes. These agencies often place minors in homes or businesses, where they work as domestic help or labourers in unsafe conditions for paltry wages.

According to Delhi Police, while intra-city child trafficking is relatively rare, the Capital’s position as a transit hub — due to its proximity to Gurugram and Noida — makes it a key node for trafficking networks. Many children are brought from rural areas or neighbouring states and pushed into labour-intensive work.

Changing tactics and growing challenges

Naved Anjum of Prayas Juvenile Aid Centre pointed to the shifting tactics of traffickers. “While reported child labour cases have decreased, perpetrators are exploiting loopholes. Placement agencies play a significant role, often luring impoverished families with payments or posing as relatives to gain custody of children,” he said.

Anjum added that trafficking cases are sometimes misclassified as kidnappings, leading to an apparent dip in figures. “The nature of exploitation has shifted,” he noted. “Unlike in the past, some children are sent by their families or come voluntarily, only to be trapped in exploitative conditions through deceptive agencies.”

The Child Labour (Prohibition and Regulation) Act, 1986, prohibits the employment of children under 14 and restricts those aged 14 to 18 from engaging in hazardous work. Yet, enforcement remains patchy, hampered by systemic gaps and the secretive operations of trafficking rings.

A recent report by Just Rights for Children (JRC) paints a grim picture of this nationwide crisis, revealing that child labour continues under extreme and hazardous conditions.

Titled Building the Case for Zero: How Prosecution Acts as a Tipping Point to End Child Labour, the report details that 2,588 children were rescued from such conditions in Delhi alone between April 2024 and March 2025. The report places the Capital among the top five regions in India for child labour rescues, highlighting its continued vulnerability despite legal protections.

Rakesh Kumar of Bachpan Bachao Andolan explained, “Our work involves identifying factories and workplaces exploiting children. We conduct reconnaissance, inform the police, and assist in raids to apprehend perpetrators.”

Ravi Kant, founder of Shakti Vahini, stated that approximately 29,224 children were rescued in Delhi between April 2023 and March 2024.

Role of placement agencies in domestic exploitation

A senior Delhi Police official clarified that raids based on tip-offs are conducted only within the capital. “Most of these children are brought by relatives or placement agencies that contact their parents directly. These families are often impoverished and see the ‘big city’ as a chance for their children to earn. We can only investigate or act in other states like Gurugram or Noida if an FIR is registered in Delhi,” the official said.

Jeebanjyoti Mohanty, joint director of Prayas JAC, explained that rescue operations often take months of preparation. “We begin by surveying factories to understand how children are employed. Once we confirm the details, we coordinate with the police to carry out raids,” she said.

Mohanty underscored the role of placement agencies, particularly in placing children as domestic help. “We’ve documented multiple cases where children working in households were physically abused. These agencies send representatives to remote villages in Jharkhand, Odisha, Uttar Pradesh, and Bihar, offering parents money for their children. Because these families are extremely poor, they rarely object. Once in Delhi, the children are forced into factories or homes, often suffering horrific treatment,” she explained.

According to Mohanty, these children typically earn between Rs 100 and Rs 150 a day, amounting to a maximum of Rs 4,500 a month. The physical toll is severe. “Minor errors can result in beatings, leading to unimaginable injuries, especially for children employed in households,” added a representative from Shakti Vahini.

Activists report that many of these placement agencies are based in Shakurpur and Karol Bagh, while others operate out of Gurugram and Noida. In one such case in Noida, five people were charged, including the child’s mother, uncle, aunt, and employers.

Judicial orders and institutional inertia

On January 10, the Delhi High Court, led by Acting Chief Justice Vibhu Bakhru and Justice Tushar Rao Gedela, ordered the state government to submit a detailed status report, certified by then Chief Secretary Dharmendra Kumar. The report was to include district-wise details of task force meetings, rescue operation plans, and rehabilitation steps for rescued children.

The court emphasised the need for accountability at the district level. It also asked Delhi Police for a status update on a 2023 FIR related to the assault and molestation of volunteers during a child labour rescue.

This intervention stemmed from a petition by Bachpan Bachao Andolan, filed after a 2019 fire at a factory in Anaj Mandi killed more than 40 people, including minors. The incident reignited public demands for stricter action against trafficking and child labour.

Advocate Prabhsahay Kaur, representing the NGO, pointed out that Rule 17C of the Child and Adolescent Labour Rules mandates monthly district task force meetings. “Many districts failed to conduct these meetings or rescue operations in 2024. Action typically takes place only after court orders,” she said.

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Commission for child rights remains non-functional

After a long two-year wait, the Delhi Commission for Protection of Child Rights (DCPCR) has found itself with a head, albeit officiating. Rashmi Singh, an IAS officer, was posited at the position just three days before the deadline on October 27; however, the commission remains weak, with little work done to strengthen its base foundations.