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Invisible and unprotected: India’s new labour codes fail domestic, home-based workers

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On a blistering afternoon in June, when the temperature had crossed 40 degrees Celsius, 48-year-old Manju (name changed on request) was at home in the dense Mewla Maharajpur locality. She wanted a few minutes of rest before heading out to work as a domestic worker. But the ceiling fan in the room, recirculating hot air, was not helping her cool down. Dreading the blazing sun, Manju reminded herself that it was only a 20-minute-walk to her employer’s home, and that she had been doing this for decades.

A few minutes into the walk, she knew something was terribly wrong.

“I began to feel overwhelming thirst, followed by a parched throat and nausea. I sat on the side of the road and managed to get drinking water from someone nearby,” she said. Manju’s symptoms indicate that she may have experienced heat exhaustion that arises due to the body's response to an excessive loss of water and salt, usually through profuse sweating. Yet, she did not return home. “I felt guilty about not showing up for work,” said Manju.

India’s four new labour codes, which replaced 29 Union government labour laws, have a blindspot when it comes to protecting workers from the impacts of climate change, as we reported in the first part of our series. The other four parts of this series investigated how women in the manufacturing sector, street vendors, small-site construction workers and gig workers, fall through the labour code protections, leaving them vulnerable to impacts of climate change.

Extreme climate has particular impacts on women workers, who juggle work with caregiving responsibilities at home, as we reported in the first part of our series. Safe working conditions, provisions such as paid sick leave, health insurance, maternity benefits, income support during climate disasters, access to cooling infrastructure, and bargaining power, can help shield women workers from climate risks.

Ellina Samantroy Jena, a Fellow at the V.V. Giri National Labour Institute, an autonomous body of the Ministry of Labour and Employment, explained that domestic and home-based work are low-paying. Domestic work involves performing various tasks, such as cleaning or sweeping, and home-based workers are involved in a variety of occupations, including metal work, zari (embroidery) work, carpentry, bangle making, papad making.

The Code on Social Security, 2020, which extends social security to all employees and workers in the organised, unorganised or any other sector, classifies domestic and home-based workers as wage workers, meaning those employed for remuneration in the unorganised sector, directly by an employer or through a contractor.

But domestic and home-based workers’ “vulnerability lies in that they are not employed in establishments (units where 10 or more workers are employed), where legal conditions can be extended,” Jena said. Homes, she added, are not recognised as workplaces for domestic and home-based workers in the labour code. This makes the labour codes, and its welfare provisions, inadequate for most such workers.

Unregulated working conditions

The Occupational Safety, Health and Working Conditions Code or OSH Code, 2020, is applicable to persons employed in an establishment.

While the Code mandates that employers of a factory provide a suitable atmosphere, enough air circulation, and protect workers from excessive heat, cold and extreme weather, Subhadra Pandey, Coordinator at SEWA Delhi, a non-profit working with informal sector women workers, asks who will regulate working conditions of domestic or home-based workers. “Who is the primary employer? This question is not answered in the Codes.”

One of the main industries that employ home-based workers is the beedi industry. Anna Gowri, 64, president of the Beedi workers union in Tirunulveli and Thoothukudi districts, explained that every alternate day, contractors come to her village in Melapattam in Tirunulveli, to distribute raw materials such as tendu leaves, nool (thread) and tobacco. The target is to complete rolling 1,000 beedis in two days. Home-based workers work all seven days a week, from 9 am to 4 pm, she said.

Summers are particularly stressful. “We cannot use a fan while working. To roll the leaves, they need to be wet. The fan can dry them out,” said Gowri, adding that women work under trees outdoors if it becomes too hot inside. A 2024 study published in the Indian Journal of Occupational and Environmental Medicine, that surveyed 153 participants in Karnataka, including 85 beedi rollers, found that one-third work in rooms with inadequate ventilation.

In extreme heat, 84% of home-based workers reduced their working hours, and 88% reported reduced productivity, all of which contributed to low earnings, found a survey, published in June 2026, by Women in Informal Employment: Globalizing and Organizing (WIEGO), a global network that researches on informal employment. Nearly 85% missed at least one day of work a month because of heat-related illness affecting themselves or a family member, the study found.

In addition, home-based and domestic workers often labour for longer than eight hours, making them more prone to exhaustion in times of heat. A 2022 study of 524 domestic workers published in the Indian Journal of Labour Economics estimated the average working hours for........

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