People's Union for Democratic Rights v. Union of India
(1982) 3 SCC 235- In this judgment, the honourable Supreme Court defined forced labour, while discussing the scope of Article 23 of the Constitution of India, stated: The word force must therefore be construed to include not only physical or legal force but also force arising from the compulsion of economic circumstances which leaves no choice of alternatives to a person in want and compels him to provide labour or service even though the remuneration received for it is less than the minimum wage.