Supreme Court Closes 2015 MGNREGA PIL, Leaves Door Open to Challenge New VB-G RAM G Act

The Supreme Court disposed of a decade-old PIL concerning delayed wage compensation and minimum wages under MGNREGA, but permitted the petitioners to bring a fresh challenge concerning the Viksit Bharat–Guarantee for Rozgar and Ajeevika Mission (Gramin) Act, 2025. The Court also witnessed an important exchange on whether minimum wages and the right to work can be enforced as fundamental rights.

The Supreme Court has disposed of a 2015 Public Interest Litigation (PIL) concerning delayed wage compensation and minimum wages under the Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA), while leaving the door open for a fresh legal challenge concerning India's new rural employment law.

A Bench comprising Chief Justice of India Surya Kant, Justice Joymalya Bagchi and Justice V. Mohana observed that the issues raised in the old petition stood covered by the Supreme Court's earlier decision in Swaraj Abhiyan.

However, after hearing Advocate Prashant Bhushan, appearing for the petitioners, the Court granted liberty to approach it through a fresh petition concerning provisions of the Viksit Bharat–Guarantee for Rozgar and Ajeevika Mission (Gramin) Act, 2025, or VB-G RAM G Act.

The new legislation has replaced the MGNREGA framework, making the decade-old PIL largely concerned with a statutory regime that is no longer in force.

The proceedings nevertheless triggered a significant constitutional discussion over minimum wages, dignified livelihood, the right to work and the limits of judicial intervention in welfare policy.

What was the MGNREGA PIL about?

The petition, Aruna Roy and Others v. Union of India, was filed in 2015.

It raised two principal issues concerning workers employed under MGNREGA:

1. payment of compensation when wages were delayed; and

2. payment according to state-prescribed minimum wages rather than a lower wage prescribed under the rural employment framework.

During the hearing, however, the Bench noted that the legal framework governing rural employment had fundamentally changed.

The VB-G RAM G Act, 2025 has replaced MGNREGA and establishes a new statutory rural-employment framework.

Supreme Court: MGNREGA no longer governs the field

At the outset, Justice V. Mohana pointed to the changed statutory position and noted that the old MGNREGA framework had been replaced.

That raised an immediate difficulty: could the Court use a PIL filed in 2015 under the old legislation to examine questions arising under an entirely new Act?

Bhushan argued that an important issue nevertheless survived — whether workers must receive the minimum wages notified by state governments.

He referred to the earlier judicial treatment of minimum wages and argued that paying workers below the applicable minimum could raise concerns relating to forced labour.

According to his submissions, the new legislation itself made the minimum-wage issue relevant and therefore warranted judicial examination.

Is right to work a Fundamental Right? Justice Bagchi raises larger constitutional question

The hearing then moved beyond the technical question of whether the old PIL had become infructuous.

Justice Joymalya Bagchi raised a broader constitutional issue concerning the nature of the right to work.

He observed that the right to work is not expressly recognised as a Fundamental Right under Part III of the Constitution, and described it instead in the context of the aspirations embodied in the Directive Principles of State Policy under Part IV.

The observation raises an important distinction in Indian constitutional law.

Fundamental Rights are judicially enforceable, while Directive Principles guide the State in governance and policymaking but are not ordinarily enforceable in the same manner.

Justice Bagchi questioned whether courts could effectively compel the State to maintain or implement a particular welfare programme once the matter entered the domain of social and economic policy.

The exchange therefore raised a larger question:

Can courts compel the government to provide a particular level of employment or welfare support?

The Bench did not finally decide that constitutional question in the proceedings.

Prashant Bhushan invokes Article 21 and dignified life

Bhushan responded by relying on the Supreme Court's expansive interpretation of Article 21 of the Constitution, which protects life and personal liberty.

He argued that Article 21 encompasses the right to live with dignity.

According to the submission, where the State itself provides employment, a dignified livelihood requires workers to receive at least the legally applicable minimum wage.

This brought two strands of constitutional law into focus:

Part IV: the State's social and economic obligations, including employment-related aspirations;

and

Article 21: the judicially developed protection of life with human dignity.

The Court, however, did not determine that larger issue because the Bench considered that questions arising from the new legislation should be brought through an appropriate fresh proceeding.

Supreme Court allows fresh challenge to VB-G RAM G Act

Ultimately, the Bench disposed of the old petition while giving the petitioners liberty to file a fresh petition concerning provisions of the VB-G RAM G Act, 2025, if required.

CJI Surya Kant made clear that the validity or interpretation of the new legislation could not appropriately be examined in the old MGNREGA proceedings.

The significance of the order therefore lies partly in what the Court did not decide.

It did not finally settle the minimum-wage controversy under the new Act.

Nor did it rule on a constitutional challenge to the VB-G RAM G framework.

Instead, it indicated that those issues would require a properly instituted proceeding directed specifically against the new statutory regime.

CJI Surya Kant praises MGNREGA's role in rural India

During the hearing, CJI Surya Kant also reflected on the social impact of MGNREGA.

The Chief Justice described the programme positively as an important welfare intervention for rural communities, particularly people who lacked reliable sources of livelihood.

He distinguished the programme from a simple transfer or “freebie”, observing that its basic model involved people working in return for income.

The CJI's remarks highlighted the underlying philosophy of employment-guarantee programmes: livelihood support through paid work rather than unconditional financial assistance.

At the same time, the Chief Justice expressed reservations about deciding the broader controversy through the existing PIL when no directly aggrieved workers were before the Court.

If an appropriate petition challenging the new framework were brought before the Court, he indicated that the issues could then be examined.

What is the VB-G RAM G Act, 2025?

The Viksit Bharat–Guarantee for Rozgar and Ajeevika Mission (Gramin) Act, 2025 represents a major restructuring of India's statutory rural-employment framework.

It replaced the Mahatma Gandhi National Rural Employment Guarantee Act, 2005.

Among its major features is an increase in the statutory employment guarantee from 100 days under MGNREGA to 125 days of wage employment in a financial year for eligible rural households whose adult members volunteer to perform unskilled manual work.

The new framework also places greater emphasis on rural infrastructure, livelihood assets, water security, convergence of development programmes and technology-based monitoring.

The shift is therefore more than a change of name: it represents a substantial redesign of the statutory architecture governing rural employment.

MGNREGA vs VB-G RAM G: What changed?

Issue	MGNREGA	VB-G RAM G
Statutory framework	MGNREGA, 2005	VB-G RAM G Act, 2025
Guaranteed employment	At least 100 days	At least 125 days
Target	Rural households seeking unskilled manual work	Rural households whose adult members volunteer for unskilled manual work
Approach	Employment guarantee and rural asset creation	Employment guarantee integrated with wider rural-development planning
Current status	Repealed	Current statutory framework

The new Act received presidential assent in December 2025 and was subsequently brought into operation across rural India from July 1, 2026, when MGNREGA stood repealed.

What happens to minimum wages under the new rural jobs law?

This is now one of the most important questions emerging from the Supreme Court proceedings.

The petitioners argued that workers performing employment guaranteed by the State should receive the applicable minimum wage and linked that proposition with constitutional protections against exploitation and the right to a dignified life.

The Bench did not finally decide that question.

Instead, by permitting a fresh petition concerning the new legislation, the Supreme Court has left open the possibility that the wage provisions of the VB-G RAM G Act may face separate judicial scrutiny.

Any such challenge would require the Court to consider the precise language of the new legislation alongside existing constitutional jurisprudence.

Why Swaraj Abhiyan matters

The Bench observed that issues arising from the old MGNREGA petition were covered by the Supreme Court's judgment in Swaraj Abhiyan.

That litigation dealt extensively with the implementation of MGNREGA and the State's responsibilities toward workers under the statutory employment-guarantee framework.

The present proceedings are different because India has since moved to a new statute.

Consequently, precedents developed under MGNREGA may remain relevant to broader constitutional and labour-law questions, but the provisions of the new Act will have to be interpreted according to their own statutory language.

Why this Supreme Court hearing matters

Although the Court disposed of the PIL without deciding the merits of a challenge to the new law, the hearing exposed several questions that could become important in future litigation.

1. Is payment below a state's minimum wage constitutionally permissible?

This could involve the interaction between minimum-wage protections, Article 21 and constitutional safeguards against forced labour.

2. Can the right to work become judicially enforceable?

The Constitution places employment-related social objectives within the Directive Principles, while Article 21 jurisprudence has progressively expanded the meaning of a dignified life.

How far those principles can be used to compel specific welfare expenditure remains a difficult constitutional question.

3. How much can courts intervene in welfare policy?

Social-welfare programmes involve choices about public expenditure, eligibility, wage rates and Centre-State financial responsibilities.

Courts generally have to balance enforcement of constitutional rights against the executive and legislature's policymaking domain.

4. Can the new VB-G RAM G provisions be challenged?

Yes. The Supreme Court expressly left the petitioners free to institute an appropriate fresh proceeding concerning provisions of the new Act.

That means the constitutional and statutory questions raised during the hearing remain potentially open for future adjudication.

The bigger constitutional question: Welfare policy vs enforceable rights

The exchange between Justice Bagchi and Bhushan illustrates a recurring tension in Indian constitutional law.

On one side is the principle that decisions concerning welfare programmes, employment guarantees and public expenditure primarily belong to the elected branches of government.

On the other is the Supreme Court's extensive jurisprudence interpreting Article 21 to protect a life of dignity and recognising constitutional safeguards against exploitative labour.

The difficult question is where one ends and the other begins.

If employment is provided through a statutory welfare programme, can workers insist upon a particular minimum wage as a constitutional entitlement?

And if the State changes the structure or financing of that programme, how far can a constitutional court intervene?

The Supreme Court did not answer those questions in Aruna Roy.

But by permitting a fresh challenge under the new legislation, it has left the door open for them to return.

The Supreme Court has closed the decade-old MGNREGA PIL filed in 2015, finding that its issues were already covered by earlier precedent and that the statutory landscape has since changed.

But the Court has not closed the debate over minimum wages and rural employment rights.

The petitioners have been permitted to approach the Supreme Court afresh concerning the VB-G RAM G Act, 2025.

That means questions surrounding minimum wages, dignified livelihood, the right to work and the constitutional limits of welfare-policy intervention could eventually return before the Court in a new case.

For now, the old MGNREGA litigation has ended.

The constitutional debate surrounding India's new rural employment regime may only be beginning.

Case at a Glance

Case: Aruna Roy & Ors. v. Union of India

Case No.: W.P.(C) No. 768/2015

Court: Supreme Court of India

Bench: CJI Surya Kant, Justice Joymalya Bagchi and Justice V. MohanaIssue: Delayed wage compensation and minimum wages under MGNREGA

Outcome: PIL disposed of; liberty granted to bring an appropriate fresh proceeding concerning the new VB-G RAM G Act

UPSC Relevance

GS Paper II: Fundamental Rights, Directive Principles, judiciary and welfare schemes

GS Paper III: Employment, inclusive growth and rural development

Key constitutional provisions: Article 21, Directive Principles and constitutional protection against forced labour

Current Affairs: MGNREGA replacement, VB-G RAM G Act, rural employment guarantee and minimum wages