Condemned by Caste, Failed by Law: The Rights of Manual Scavengers and the Chasm Between Constitutional Promise and Ground Reality in India

Condemned by Caste, Failed by Law: The Rights of Manual Scavengers and the Chasm Between Constitutional Promise and Ground Reality in India

 

Abstract

Manual scavenging—the manual removal of human excreta from dry latrines, sewers, septic tanks, and railway tracks—endures as one of the most constitutionally irreconcilable realities of contemporary India. Despite the unambiguous abolitionist mandate of Articles 14, 17, 21, and 23 of the Constitution of India, and the enactment of two successive legislative frameworks—the Employment of Manual Scavengers and Construction of Dry Latrines (Prohibition) Act, 1993, and the Prohibition of Employment as Manual Scavengers and their Rehabilitation Act, 2013—the practice persists at a scale that official data systematically underreports. This article undertakes a critical, analytically driven examination of the structural chasm between India’s legal promise and the lived degradation of an estimated hundreds of thousands of individuals, the overwhelming majority of whom belong to historically untouchable scheduled caste communities. The article argues that successive legal interventions have treated manual scavenging as a labour welfare problem susceptible to prohibition and rehabilitation schemes, when the operative variable is caste—a social ideology of hierarchical human valuation that no statute has yet confronted directly. Through constitutional analysis, comparative legislative critique, examination of landmark Supreme Court jurisprudence, case studies from Delhi, Agra, Madhya Pradesh, and Chennai, and a critical appraisal of government schemes including SRMS and the Swachh Bharat Mission, the article demonstrates that legal reform divorced from anti-caste restructuring will continue to produce performative governance rather than substantive justice. It concludes with targeted recommendations for an independent enforcement authority, reparative rehabilitation, and the integration of anti-caste praxis into the legal framework itself.

Keywords: Manual scavenging, caste, untouchability, Article 21, dignity, Prohibition Act 2013, Safai Karamchari Andolan, rehabilitation, Dalit rights, structural inequality

 

1. Introduction

In July 2023, three sanitation workers descended into a sewage pit beneath a residential colony in Delhi. None emerged alive. Their deaths, attributed to asphyxiation caused by toxic hydrogen sulphide and methane gases, barely registered in the national news cycle—yet they were not aberrations. According to the National Commission for Safai Karamcharis, more than nine hundred individuals died in sewers and septic tanks across India between 2014 and 2023.[1]

Behind every statistic is a name, a caste, and a community systematically denied the protection of a law that has existed, in various forms, for over three decades. That India continues to produce such deaths despite explicit constitutional prohibitions and two dedicated legislative frameworks reveals not a failure of law alone, but a failure of the moral imagination that law is supposed to embody. Civil society organisations, most prominently the Safai Karmachari Andolan led by Bezwada Wilson, have documented this persistence over decades, cataloguing deaths, demanding accountability, and petitioning courts—often to be met with bureaucratic evasion dressed as compliance.[2]

Manual scavenging—the manual removal of human excreta from dry latrines, sewers, and railway tracks—is among the most viscerally degrading forms of labour extant anywhere in the contemporary world. The Prohibition of Employment as Manual Scavengers and their Rehabilitation Act, 2013 (‘the 2013 Act’) defines a manual scavenger as a person employed to manually clean, carry, dispose of, or otherwise handle human excreta in an insanitary latrine, open drain, pit, railway track, or similar location.[3]

This article interrogates the structural gap between India’s constitutional promise of dignity and equality and the ground reality of manual scavenging. It argues that the failure is not merely administrative but epistemic: Indian law treats manual scavenging as an employment problem susceptible to prohibition and welfare schemes, when it is fundamentally a caste problem requiring the dismantling of a social order that produces and reproduces the condition. Unless this reorientation occurs, legislative amendments and government programmes will continue to function as instruments of symbolic governance rather than transformative justice.

1. Conceptual and Historical Context

The legal definition of manual scavenging defies straightforward application in practice. Field surveys conducted by the Safai Karmachari Andolan consistently reveal a vast invisible workforce—individuals engaged in the manual cleaning of sewers, drains, and septic tanks under contractual or daily-wage arrangements that evade the definitional threshold, thereby escaping both legal protection and statistical capture. The definitional boundary becomes a boundary of invisibility: those who fall outside it are simultaneously the most exposed to harm and the least reachable by the law’s protective machinery.

The historical roots of this practice are coterminous with the caste hierarchy itself. Varna and jati-based occupational assignment consigned certain communities—the Balmikis, Helas, Doms, and Mehtar castes across different regions—to the hereditary task of waste removal. As Dr. B.R. Ambedkar argued with unsparing clarity, caste is not merely a division of labour but a division of labourers, in which human beings are assigned to degrading work not by capacity or choice but by birth.[4]

Colonial municipal structures deepened this association by institutionalising caste-based sanitation labour through civic bodies, creating a bureaucratic architecture that naturalised exclusion. Thorat and Umakant have documented how colonial municipalities in northern and western India formalised hereditary jati-based labour contracts that survived independence and were absorbed wholesale into state and municipal employment rolls.[5]

What sustains manual scavenging into the twenty-first century is not inertia but active structural reproduction. Absence of alternative livelihoods, illiteracy, caste-based social pressure, debt bondage, and the unavailability of mechanised sanitation equipment in rural and peri-urban areas collectively ensure that members of scavenging communities remain trapped. The problem is not that individuals are unwilling to exit the practice; it is that the economic, social, and physical conditions that would make exit possible are systematically absent—a point to which the analysis of government schemes will return.

III. Constitutional Framework

India’s Constitution furnishes a robust normative architecture against manual scavenging, even without naming the practice explicitly. Article 14 guarantees equality before the law and equal protection of laws—a guarantee rendered hollow when the state, through its municipal bodies and railway corporations, continues to employ manual scavengers and insulates itself from prosecution through contractual intermediaries.[6]

Article 17 abolishes untouchability in any form, making its enforcement a matter not of state discretion but of constitutional obligation. The word ‘any form’ has been construed by the Supreme Court to encompass economic and occupational disabilities grounded in notions of ritual impurity, not merely the traditional social exclusion of untouchables from temples and wells.[7]

Article 23 proscribes traffic in human beings, begar, and other forms of forced labour. The Supreme Court in Peoples Union for Democratic Rights v. Union of India held that Article 23’s prohibition extends to any situation of compelled labour arising from economic vulnerability, not merely physical coercion. Manual scavengers who perform this work under conditions of hereditary obligation, social coercion, and economic destitution are therefore victims of forced labour in the constitutional sense, irrespective of any formal employment contract.[8]

Article 21’s guarantee of the right to life, as expansively interpreted since Maneka Gandhi v. Union of India and its progeny, encompasses the right to live with dignity. The right to dignity is not a philosophical flourish; it is a justiciable constitutional entitlement that the state is obliged to protect, promote, and not violate.[9] Manual scavenging is not merely illegal under statute—it is unconstitutional in its very essence, and every death in a manhole is a violation of the right to life that the Supreme Court has expressly and repeatedly confirmed.[10]

1. Legislative Framework: A Critical Comparison of the 1993 and 2013 Acts

The Employment of Manual Scavengers and Construction of Dry Latrines (Prohibition) Act, 1993 was India’s first legislative attempt to abolish the practice. It prohibited the construction of dry latrines and the employment of manual scavengers, with penal consequences for violations. However, the Act suffered from fatal structural deficiencies: it was adoptable rather than directly applicable to states, resulting in large swathes of the country—including Uttar Pradesh and Rajasthan, where the practice was most entrenched—remaining entirely uncovered. Enforcement was entrusted to local authorities who were themselves often the employers of manual scavengers. No mechanism for survivor identification or rehabilitation was created.[11]

The 2013 Act represented a legislative advance in several respects. It extended the prohibition nationally, covered sewers and septic tanks explicitly, imposed obligations on municipalities to provide protective equipment and mechanised cleaning machinery, created a survey mechanism for identifying manual scavengers, and established an entitlement-based rehabilitation framework. It also amended the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act to include discrimination linked to manual scavenging.[12]

Yet the 2013 Act carries significant limitations. The definitional scope remains contested, with municipal bodies exploiting ambiguities to exclude sewer-cleaning workers from coverage. Rehabilitation provisions are discretionary in practice despite being mandatory in text, because implementation rests entirely with state governments that lack both resources and political incentive to comply. The Act provides no private right of action for survivors to directly sue employers or the state. The distinction between the 1993 and 2013 frameworks is, ultimately, the distinction between a prohibition unsupported by enforcement and a prohibition unsupported by accountability—different in degree, not in kind.

1. The Rights Dimension: Dignity, Equality, and Reparation

Manual scavengers possess rights that are simultaneously constitutional, statutory, and human—yet each category remains systematically denied. The right to dignity is violated at the moment of entry into a sewer without protective equipment, when a person is required to handle excreta with bare hands, and when death in a manhole is classified as an accident rather than as the foreseeable consequence of state negligence. Dignity is not a concession of the state; it is a pre-political entitlement that the state is constitutionally mandated to safeguard.

The right to equality demands that communities historically burdened by caste-based occupational assignment receive not merely formal legal equivalence but substantive remediation. As the Supreme Court acknowledged in State of Kerala v. N.M. Thomas, achieving real equality may require treating unequals unequally—a principle that demands preferential and immediate rehabilitation, priority in housing, fee-free higher education, and reservation in occupations representing genuine social mobility.[13]

The right to be free from exploitation, grounded in Article 23, encompasses protection against forced and bonded labour. Many manual scavengers work without formal contracts, receive wages below the statutory minimum, and face the threat of social ostracism if they attempt to exit the occupation. The right to rehabilitation created by the 2013 Act is not charitable but corrective: it acknowledges that the state, through decades of institutional inaction and active employment of scavenging labour, bears a constitutional duty of repair that extends well beyond a single cash transfer.

1. The Judicial Role: Promise, Persistence, and Paradox

The Supreme Court of India has repeatedly intervened to fill the enforcement vacuum left by the executive and legislature. In Safai Karamchari Andolan v. Union of India, culminating in over two decades of litigation, the Court directed state governments to identify manual scavengers, provide rehabilitation benefits, and ensure compensation of ten lakh rupees to the families of each person who died in a sewer. The judgment was notable for its moral clarity: it held that manual scavenging was a blot on the constitutional scheme and that every sewer death was a violation of Article 21.[14]

In subsequent contempt proceedings, the Court expressed frustration at the persistent non-compliance of state governments, which submitted data of dubious reliability while tens of thousands of identified manual scavengers remained without rehabilitation. The Court directed the National Commission for Safai Karamcharis to conduct independent verification and ordered chief secretaries to appear and explain non-compliance. Yet judicial directions without autonomous enforcement mechanisms ultimately depend on executive good faith—a commodity conspicuously absent in this domain.

The courts have thus occupied a paradoxical position: asserting rights with admirable force while possessing inherently limited capacity to ensure their practical realisation. Judicial activism has been indispensable in keeping the issue alive and establishing the constitutional accountability of the state, but it cannot substitute for the administrative infrastructure, community empowerment, and political commitment that structural transformation requires. The gap between judicial pronouncement and ground reality in manual scavenging cases is perhaps the starkest illustration in Indian jurisprudence of the limits of rights adjudication in the absence of institutional reform.

VII. Law Versus Ground Reality: The Architecture of Failure

As of 2023, the government’s own Socio-Economic and Caste Census data identified approximately 58,000 manual scavengers nationally, while independent organisations and academic researchers place the actual figure in the hundreds of thousands. This chasm between official and real figures is not accidental—it is a product of survey design, definitional narrowness, and the structural incentive of local authorities to minimise counts so as to minimise rehabilitation obligations.[15]

The failure of implementation operates at multiple levels simultaneously. At the institutional level, District Magistrates and municipal commissioners legally responsible for identification surveys treat the obligation as bureaucratic formality rather than a rights-enforcement mandate. At the social level, caste identity means that manual scavengers lack the political representation necessary to demand accountability. The definitional and administrative gaps identified in the 2022 NCSK Status Report confirm that the 2013 Act’s enforcement architecture has been captured by the same municipal bodies it was designed to regulate.[16]

The structural dimension of failure is perhaps the most significant. Manual scavenging persists because it is economically convenient—it is cheaper to deploy a human being than to invest in mechanised sanitation infrastructure. Municipal budgets, particularly in smaller towns and rural areas, prioritise visible infrastructure over sanitation dignity. The contractor system creates layers of legal insulation between the state employer and the actual worker. And caste hierarchy naturalises the arrangement so that neither employer nor, tragically, many members of scavenging communities initially perceive the practice as something the law has either the power or the obligation to change. This cognitive normalisation of degradation is the most durable obstacle to legal reform and the one that no legislative drafting technique alone can dissolve.

VIII. Ground-Level Case Studies

In 2019, Ramkhelawan, a daily-wage worker from a Valmiki community in Agra, was contracted by a private firm holding a subcontract from the municipal body to clean a sewage pit at a commercial complex. He entered the pit without any protective equipment—no harness, no gas detector, no monitoring rope. He died within minutes from hydrogen sulphide poisoning. His family received no compensation under the 2013 Act for over two years, as local officials insisted the death fell outside the Act’s purview because his immediate employer was a private contractor. This jurisdictional evasion is systemic: the contractor structure insulates the state from liability precisely when the state is the ultimate beneficiary of the hazardous labour.

In rural Madhya Pradesh, a 2021 survey by the Human Rights Law Network found that women in Balmiki communities continued to manually clean dry latrines in villages where local panchayats had certified compliance with the 2013 Act. The survey had been completed without visiting the affected hamlets. Women interviewed reported being paid in kind—grain, cloth, occasionally small cash sums—placing them outside even the informal wage-monitoring framework. Their names appeared on no list of identified manual scavengers. They were, in every administrative sense, non-persons before a law that was supposedly enacted for their protection.[17]

In Chennai, at least twelve workers died in storm-water drains and sewers within corporation limits between 2018 and 2022, as per reports by the Greater Chennai Corporation and Tamil Nadu State Human Rights Commission. Each death generated a press statement, a committee, and, in most cases, complete impunity for supervisors and contractors. The Chennai cases dismantle a persistent assumption: that urban modernity and technological capability automatically produce sanitation justice. When the victims are caste-marginalised and politically voiceless, technological readiness and political will remain entirely distinct variables.[18]

1. Government Schemes: Architecture Without Accountability

The Self-Employment Scheme for Rehabilitation of Manual Scavengers (SRMS), administered by the National Safai Karamcharis Finance and Development Corporation, provides credit-linked subsidies for self-employment to identified manual scavengers and their dependants. While the scheme has the correct orientation, its implementation suffers from chronic underutilisation. The NSFDC Annual Report for 2022–23 reveals disbursement figures consistently falling well below targets—a direct consequence of the same identification failures that plague the 2013 Act. A scheme built on the foundation of flawed identification cannot achieve its objectives regardless of its financial architecture.[19]

The Swachh Bharat Mission, launched in 2014, aimed at open-defecation-free status through individual household latrine construction, theoretically eliminating the dry latrines that necessitate manual scavenging. However, studies by the Research Institute for Compassionate Economics found that toilet construction consistently outpaced actual usage, and that newly built latrines in many areas were accessed by upper-caste households while Dalit households continued the practices the Mission was designed to end. The Mission’s performance metrics—toilet construction counts—are structurally blind to the caste dimensions of sanitation access.[20]

Both schemes share a foundational limitation: they address symptoms rather than causes. Rehabilitation schemes assume that the former manual scavenger, once trained in an alternative skill, can access a market that will receive them as an equal participant—an assumption that catastrophically underestimates caste-based discrimination in the open economy. Swachh Bharat assumes that eliminating dry latrines will eliminate manual scavenging, ignoring the vast sewer-cleaning workforce that surveys have failed to capture. Government policy, across both schemes, exhibits a systematic evasion of caste as the operative variable, and that evasion is the single greatest obstacle to effective intervention.

1. Critical Analysis: Structural Inequality, Tokenism, and the Legal-Social Gap

The fundamental analytical error in India’s legal and policy response to manual scavenging is the treatment of caste as a background condition rather than as the proximate cause. This framing allows legislators, administrators, and courts to address manual scavenging as a labour welfare issue—a matter of occupational safety, wages, and skill development—without confronting the caste ideology that assigns certain human beings to certain degradations by birth. Legal prohibition, however precisely drafted, cannot dissolve social ideology by decree. Gopal Guru’s concept of ‘Dalit invisibility’ in state data is not merely a statistical problem; it is evidence of the state’s epistemological refusal to see the Dalit subject as a full rights-bearing citizen.[21]

The phenomenon of tokenism demands particular scrutiny. High-profile events—ministers photographed sweeping streets, Swachh Bharat rallies, awards for sanitation workers on national days—create a performative discourse of sanitation dignity that is carefully detached from any redistribution of power or accountability. This tokenism is not benign. When compensatory gestures substitute for systemic change, they actively retard the latter by generating an appearance of responsiveness that deflects genuine accountability. The United Nations Special Rapporteur on Contemporary Forms of Slavery observed, with reference to India, that symbolic state recognition of sanitation workers’ contributions has not translated into enforceable rights or systemic protection.[22]

The legal-social gap is ultimately a gap in the meaning of rights. In formal legal doctrine, a right is a claim enforceable against the state through judicial mechanisms. For a manual scavenger in rural Rajasthan, the distance between that doctrinal right and her lived reality encompasses illiteracy, geographical inaccessibility of courts, language barriers, police hostility, and the daily terror of social ostracism if she challenges her employer and community simultaneously. Rights that cannot be exercised by those they are designed to protect are, at best, aspirational norms and, at worst, instruments of false legitimation for a system that perpetuates oppression while declaring it abolished.

1. Recommendations for Structural Reform

First, India requires an independent National Authority for Elimination of Manual Scavenging, constituted under an autonomous statutory framework, with powers to conduct surveys independently of state governments, prosecute violations, award direct compensation, and submit binding compliance reports to Parliament. The current dependence on state governments to implement a law that requires them to indict their own municipal bodies and contractors is an irreducible conflict of interest that judicial monitoring alone cannot resolve.

Second, the definitional scope of the 2013 Act must be amended by Parliament to cover unambiguously all persons who manually clean sewers, septic tanks, drains, and railway tracks, irrespective of the existence of a formal employment contract or the technological classification of any equipment nominally provided. Every death in a confined sanitation space must trigger mandatory criminal prosecution of the responsible municipal officer, not merely an FIR against a contractor.

Third, rehabilitation must be reconceptualised as reparation. The current one-time payment is structurally inadequate and morally incongruous with the decades of forced degradation it purports to address. A reparation framework should provide monthly economic support for a defined transition period, housing entitlement, fee-free education through the graduate level for all family members, and priority public employment in non-sanitation roles. Finally, anti-caste curriculum integration in schools and mandatory sensitisation training for all civil servants and municipal employees must be treated not as peripheral to the legal framework but as constitutive of it—because law enforced by minds that have never examined their own caste assumptions will always be law selectively applied.

XII. Conclusion

The rights of manual scavengers in India exist in a state of cruel paradox: declared with constitutional eloquence, legislated with apparent comprehensiveness, adjudicated with judicial vigour, and violated with administrative impunity. The problem is not that Indian law lacks the ambition to abolish manual scavenging. The problem is that the political economy of caste renders enforcement structurally inconvenient for those who hold enforcement power. Law, in this domain, has functioned more as moral theatre than as transformative instrument.

A genuinely transformative response must reject the binary of prohibition and rehabilitation in favour of a deeper reckoning with the caste infrastructure that makes manual scavenging possible, profitable, and perversely stable. It must empower survivors as rights-claimants rather than beneficiaries, create accountability mechanisms answerable to affected communities rather than to state governments, and treat each sewer death not as a regulatory violation but as a constitutional emergency demanding immediate institutional response.

India cannot claim to be a constitutional republic while its most foundational constitutional promise—the right of every human being to live with dignity—remains a daily casualty for those condemned by birth to clean what the rest of the nation discards. The distance between the Constitution’s promise and the sewer worker’s reality is not a policy gap. It is the precise measure of the moral work this nation has refused, for seven decades, to do.

References

1. Constitution of India, 1950, arts 14, 17, 21, 23.
2. Employment of Manual Scavengers and Construction of Dry Latrines (Prohibition) Act, 1993 (Act 46 of 1993).
3. Prohibition of Employment as Manual Scavengers and their Rehabilitation Act, 2013 (Act 25 of 2013).
4. Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (Act 33 of 1989), as amended by Act 1 of 2016.
5. Safai Karamchari Andolan v Union of India (2014) 11 SCC 224.
6. Peoples Union for Democratic Rights v Union of India AIR 1982 SC 1473.
7. Maneka Gandhi v Union of India AIR 1978 SC 597.
8. Francis Coralie Mullin v Union Territory of Delhi AIR 1981 SC 746.
9. State of Kerala v N M Thomas AIR 1976 SC 490.
10. Ambedkar BR, Annihilation of Caste (1936; Verso Books annotated edn, 2014).
11. Thorat S and Umakant (eds), Caste, Race and Discrimination: Discourses in International Context (Rawat Publications, 2004).
12. Guru G, ‘The Language of Dalit-Bahujan Political Discourse’ in Shah G (ed), Dalit Identity and Politics (Sage, 2001).
13. Wilson B, ‘The Liberation Struggle of Manual Scavengers’ (2014) 49(17) Economic and Political Weekly 13.
14. National Commission for Safai Karamcharis, Annual Report 2022–23 (Ministry of Social Justice and Empowerment, Government of India, 2023).
15. National Commission for Safai Karamcharis, Status Report on Implementation of the Prohibition of Employment as Manual Scavengers and their Rehabilitation Act, 2013 (2022).
16. National Safai Karamcharis Finance and Development Corporation, Annual Report 2022–23 (Ministry of Social Justice and Empowerment, 2023).
17. Greater Chennai Corporation, Annual Public Health Report 2022 (2022).
18. Human Rights Law Network, Unseen and Unheard: Manual Scavenging in Madhya Pradesh (HRLN, 2021).
19. Research Institute for Compassionate Economics, No Relief: Revisiting Sanitation Coverage in India (r.i.c.e., 2019).
20. Law Commission of India, Report No 247: Wrongful Death and Injury to Persons in Custody (2014).
21. United Nations Human Rights Council, Report of the Special Rapporteur on Contemporary Forms of Slavery, UN Doc A/HRC/24/43 (2013).
22. Socio Economic and Caste Census 2011 (Ministry of Rural Development, Government of India, 2016).

[1]National Commission for Safai Karamcharis (NCSK), Annual Report 2022–23 (Ministry of Social Justice and Empowerment, Government of India, 2023) 14–17.

[2]Bezwada Wilson, ‘The Liberation Struggle of Manual Scavengers’ (2014) 49(17) Economic and Political Weekly 13, 14.

[3]The Prohibition of Employment as Manual Scavengers and their Rehabilitation Act 2013 (Act 25 of 2013), s 2(g).

[4]Safai Karamchari Andolan v Union of India (2014) 11 SCC 224, para 23.

[5]B.R. Ambedkar, Annihilation of Caste (1936; Verso Books annotated edn, 2014) 231.

[6]Sukhadeo Thorat and Umakant (eds), Caste, Race and Discrimination: Discourses in International Context (Rawat Publications, 2004) 88–91.

[7]Constitution of India 1950, art 14.

[8]Constitution of India 1950, art 17. The Untouchability (Offences) Act 1955, later renamed the Protection of Civil Rights Act 1955, operationalises this provision.

[9]Peoples Union for Democratic Rights v Union of India AIR 1982 SC 1473, para 15 (Bhagwati J).

[10]Maneka Gandhi v Union of India AIR 1978 SC 597; Francis Coralie Mullin v Union Territory of Delhi AIR 1981 SC 746 (expanding art 21 to encompass dignity).

[11]Safai Karamchari Andolan (n 4) para 56.

[12]Employment of Manual Scavengers and Construction of Dry Latrines (Prohibition) Act 1993 (Act 46 of 1993), ss 3–5.

[13]2013 Act (n 3) ss 5, 13, 22–24; Schedule I (rehabilitation package including one-time cash assistance of ₹40,000, residential plot, and skill training loan up to ₹15 lakh).

[14]State of Kerala v N M Thomas AIR 1976 SC 490, para 134 (Krishna Iyer J) (articulating substantive equality requiring differential treatment of unequals).

[15]2013 Act (n 3) s 4; see also National Commission for Safai Karamcharis, Status Report on Implementation of the 2013 Act (2022) 9 (noting definitional gaps exploited by municipal bodies).

[16]Socio Economic and Caste Census 2011 (Ministry of Rural Development, 2016); NCSK (n 1) 22 (placing official figure at 58,098 while acknowledging significant undercounting).

[17]Human Rights Law Network, Unseen and Unheard: Manual Scavenging in Madhya Pradesh (2021) 34–41.

[18]Greater Chennai Corporation, Annual Public Health Report 2022 (2022) 78; Tamil Nadu State Human Rights Commission, Case No 2786/2019 (order dated 14 March 2022).

[19]National Safai Karamcharis Finance and Development Corporation, Annual Report 2022–23 (Ministry of Social Justice and Empowerment, 2023) 31–35.

[20]Research Institute for Compassionate Economics, No Relief: Revisiting Sanitation Coverage in India (r.i.c.e., 2019) 12–19.

[21]Gopal Guru, ‘The Language of Dalit-Bahujan Political Discourse’ in Ghanshyam Shah (ed), Dalit Identity and Politics (Sage, 2001) 97, 104 (coining the concept of ‘Dalit invisibility’ in state data).

[22]United Nations Human Rights Council, Report of the Special Rapporteur on Contemporary Forms of Slavery, UN Doc A/HRC/24/43 (2013) paras 44–49 (India-specific observations).