The Supreme Court sought responses from the Union Government, the NCPCR, and the NHRC on a PIL calling for a complete ban on employing children and adolescents in orchestras, dance troupes, massage parlours, and spas in India .
The Supreme Court sought replies from the Union Government, the child rights body NCPCR, and the NHRC in connection with a PIL demanding an absolute ban on the employment of children and adolescents in orchestras, dance troupes, massage parlours and spas.
A bench comprising Chief Justice Surya Kant and Justices Joymalya Bagchi and Vipul M Pancholi took note of submissions by senior advocate H S Phoolka, appearing for the child rights collective Just Rights for Children Alliance (JRCA), and issued notices to the Union Ministries of Labour and Law and Justice.
Phoolka told the court that minor girls aged 10 and 11 years were allegedly being employed in orchestras and dance bars.
He said,
“For spas and massage parlours, some states have made rules of 18 years as the minimum age,”
Calling the matter “serious”, the bench also issued notices to the National Commission for Protection of Child Rights (NCPCR) and the National Human Rights Commission (NHRC) on the PIL.
The plea sought a writ of mandamus or other suitable directions, stating,
“Issue a writ of mandamus or appropriate directions directing the Central Government… to exercise its powers under Section 4 of the Child and Adolescent Labour (Prohibition and Regulation) Act, 1986, to include the employment or performance of children below 18 years in orchestras, dance bars, dance troupes, nautanki performances, massage parlours, spas, and salons, or any similar establishments that depict children in obscene or exploitative manner in Part A of the Schedule to CALPRA, thereby categorically prohibiting such employment,”
The petition further alleged that these sectors have become clandestine fronts for organised trafficking, sexual exploitation, and forced labour of minor girls across the country.
JRCA, filed through Advocate Sonali Jain, highlighted an alleged enforcement vacuum under the Child and Adolescent Labour (Prohibition and Regulation) Act (CALPRA), 1986. Under the law, hazardous occupations where adolescent labour is strictly prohibited are listed under Part A of the CALPRA Schedule.
However, massage parlours and spas currently fall under Part B, where employment is regulated for adolescents aged 14–18 rather than completely banned. The petition added that the orchestra and dance troupe categories common in states such as Bihar and West Bengal are not listed at all.
The PIL argued that traffickers exploit these gaps in statutory coverage to present commercial sexual exploitation of children as lawful employment within entertainment and wellness industries. It cited figures from rescue operations conducted between March 2025 and May 2026, stating that 212 minors were rescued from orchestras and dance groups in Bihar and West Bengal.
It also said 12 minors were rescued from massage parlours and spas in Delhi and Rajasthan.
It further alleged that victims, some reportedly as young as 12, were lured from impoverished communities with false promises of glamour, dance training, or film roles. According to the plea, many were sold to operators for sums ranging from Rs 10,000 to Rs 50,000, forced into debt bondage, and compelled to perform in sexually provocative attire before intoxicated audiences.
The petitioner also relied on a 2023 report by the Bharatiya Institute of Research and Development (BIRD), stating that 44.04 percent of identified trafficking victims in India are minors and that spas are frequently used as fronts for disguised sexual exploitation.