This commentary critically examines the Supreme Court’s decision in ‘Workmen of Nilgiri Cooperative Marketing Society Ltd. v. State of Tamil Nadu’, which applied the control and integration tests mechanically and thereby denied contract workers in a cooperative society protection under labor law. In giving primacy to formal contractual relationships over economic dependency, the Court did not promote substantive justice to vulnerable workers. This decision continues to reinforce structural inequalities and erodes the protective goals of labor law, especially in India’s large informal sector. This paper argues that the decision is a sign of a glaring flaw in reasoning and begs the cause for a jurisprudential shift towards the recognition of de facto employment relationships. Based on principles embedded in the Indian Constitution and international labor standards, it appeals for the development of a more inclusive and pragmatic legal framework that guarantees the rights of economically dependent workers in all sectors.
