A COMPARATIVE ANALYSIS OF THE LEGAL FRAMEWORKS FOR

ELIMINATING CHILD LABOUR BETWEEN SRI LANKA AND BANGLADESH

INTRODUCTION
Child Labour is a crucial issue faced by many countries in the world, in present day context 1. It
could simply be defined as the employment of children in mental, social, physical and
psychologically harmful work, which cause a negative impact over the education and well- being
of them2. Considering the legal aspect, it could be defined as violation of children’s rights and
hindering their development in terms of education, childhood and potentials. Millions of children
are employed in hazardous work such as mining, domestic work, agriculture etc. Identifying
these issues, the international community has imposed certain laws, regulations, awareness
programs and policies to control the issue to date and there are many more actions to be taken to
counter the problem completely3.
Countries use child labour, due to various reasons such as illiteracy, poverty, lack of higher
education, cultural beliefs, and economic manipulation. Children who come from poor families
will be subverted or forced to work to supplement their family's income or to survive themselves.
Some cultural beliefs would also promote the ideology that children must contribute to their
family income or learning and practicing a trade from their young age 4. Moreover, industries
may exploit children's vulnerability by paying low wages, avoiding regulations and providing
cheap labour. Use of child labour is a complex issue that requires addressing the root causes of
poverty, lack of education, and economic exploitation.
Aligning with the fact, both Bangladesh and Sri Lanka were identified as two nations which
facing this issues since decades and further, made several attempts to counter the problem 5.
Therefore, the requirement of a comprehensive legitimate framework is required 6 to address the
root causes of this problem has come into limelight in order to protect child rights and to combat
child labour, in both countries.
The International Labour Organization (ILO) has declared child labour as a violation of human
rights, as it steals the childhood of children and their potential7. Both Sri Lanka and Bangladesh
have ratified the ILO Convention on the Worst Forms of Child Labour (No. 182) and enacted
laws to address child labour. The legal framework of Sri Lanka includes the Employment of
Women, Young Persons, and Children Act (No. 47) of 1956 8, the Children and Young Persons

1
Edmonds, E.V., 2007. Child labor.
2
Edmonds and Pavcnik, 2005. Child labor in the global economy. 
3
Humbert, 2009. The challenge of child labour in international law 
4
Siddiqi and Patrinos, 1995. Child labor: Issues, causes and interventions.
5
Herath and Sharma, 2007. Child Labour in South Asia.
6
Haspels and Jankanish, 2000. Action against child labour.
7
International Labour Organization. (2017). ILO Global Estimates on Child Labour
8
Dissanayake, 2021. Occupational “safety and health” in Sri Lanka: in the sight of Labor law
Ordinance (No. 25) of 19399, and the National Child Protection Policy of 201710. Considering the
Bangladesh, its legal framework consists with the Labour Act of 2006 11, the Bangladesh Labour
Rules of 2015, and the National Child Labour Elimination Policy of 2010.
Despite of above legal frameworks, child labour remains as an insistent problem in both
countries. Considering the Sri Lankan context, children are utilized in hazardous work such as
operating of machinery, household work and agriculture activities. Being a leading apparel
dealer, Bangladesh employ their children in garment industry in a greater extend 12. Moreover,
they employ children in domestic work and in informal sector too.
Considering above fact, this research aims to conduct a critical analysis on the legal frameworks
on eliminating child labour in Bangladesh and Sri Lanka along with the effectiveness of these
laws and to identify the similarities and differences between both frameworks. Finally, the
research will suggest recommendations for strengthening the existing framework in Sri Lanka,
by comparing it with the Child Labour related legal frameworks of Bangladesh.
This research will use a qualitative methodology where the data will be collected using document
analysis, case studies etc. to get in- depth understanding on the legal frameworks and their
effectiveness in eliminating child labour. The findings of this study will contribute to the existing
literature on child labour and provide recommendations for strengthening the legal frameworks
in Sri Lanka and Bangladesh to ensure the protection of children.

Note: You have to use the format given in the chapters.

Chapter 1 should be organized as follows
1.1 – Background of the Study
1.2 – Research Problem Identification
- Symptoms of the Problem
- Justification of the problem
- Defining Research Problem
1.3 – Research Question
1.4 – Objectives of the Study
1.5 – Significance of the Study
1.6 – Limitations of the study
1.7 – Chapter Outline

Please follow the above format

LITERATURE REVIEW
9
Perera, et al, 2022. Policy and legal framework on protecting children’s rights in Latvia and Sri Lanka.
10
Vinodani and Amarasinghe, 2017. Exploitation of Child Labour in the Informal Sector of Sri Lanka’s
Rural Economy.
11
Islam, 2015. Bangladesh Labour Law.
12
Yunus and Yamagata, 2012. The garment industry in Bangladesh.
The existing Sri Lankan legislative framework on child labour and gaps
Sri Lanka has ratified important international conventions including ILO C 1385 Minimum Age
for Employment, ILO C 1826 Worst Forms of Child Labour, ICCPR7, Convention on the Rights
of the Child. Above Conventions namely:
 Sri Lanka's National Employment and Human Resources Policy
 Shop Employees Act and Office
 Employment of Women
 Young Persons and Children Act
 Minimum Wages Act12
 Factory Act
According to the Sri Lankan Children Rights Charter, it is the duty of the country to protect them
from abuse and exploitation based on economic requirements and hazardous work performed by
children, which are interfering negatively over their education while protecting them from so
called employment, to assure the spiritual, moral, physical and mental well- being. Dangerous
activities related to child labor and the most curtail form of child labor which is need to be
eliminated through certain legal provisions and awareness programs on these child labor
occupations and the government's approach of multidisciplinary harmonization with workers,
employers, organizations and civil society organizations13.
Despite Sri Lanka's strict legislation to avoid child labour, it is luckless that child labor is still
prevailing in the society, as per the statistics from the National Child Protection Agency 14.
However, cases of internal trafficking of under ages kept unreported or cannot be verified in
court proceedings due to their existence parental consent15. However, the Sri Lankan Penal Code
prohibits the use of children under the age of ten years in forced labour, production of
pornography, prostitution, slavery and illegal activities16. The Sri Lankan Police are authorized to
prosecute violators of the aforementioned regulations under Sections 286 A20, 288 B21, 358
A22, 360 A23, 360 C24, and 36325 of the Criminal Code. Sri Lanka has further ratified the
Optional Protocol on the involvement of children in armed conflict.
Furthermore, the Sri Lankan government has taken measures to prevent children from being
employed as domestic servants. As a result, the passage of the Domestic Violence Prevention
Act 28 and the extraordinary publication of Section 20(A) of the EWYCA in 2010 have
established 51 categories of hazardous work and prohibited persons to perform such duties 17. In
order to protect the rights of underage domestic workers, the term “data subject” in the above
laws and regulations should be amended to include underage domestic workers in the same way
as local courts in Sri Lanka. Lanka could offer protection, support and counseling to victims in
such circumstances.
13
Otobe, 2017. Employment Policy Department EMPLOYMENT Working Paper No. 236.
14
Jayathilake, 2023. A Comparative Analysis of the Existing Legal Framework of Sri Lanka with Regard to
the Elimination of Child Labour
15
Sarveswaran, 2010. An Evaluation of Sri Lankan Labour Standards
16
Menaka, 2012. Ensure National Security through Protecting Children in Insecurity
17
Jayathilake, 2023. A Comparative Analysis of the Existing Legal Framework of Sri Lanka
The Child Activity Survey 201618 estimated that 90.15% of Sri Lankan children between 5 to 17
ages were in school, 9.9% were out of school and most children attended both domestically and
cheaply. Children with an age difference between 15 and 17 years are mainly found in the urban
sector, with 72% participating only in household or economic activities without attending school.
The survey further revealed that most of the children had unskilled jobs and worked in
companies without being paid properly. Therefore, in addition to various legal instruments to
protect child labor problems, unique monitoring systems should be improved and put in place as
mechanisms to eliminate child labor in Sri Lanka.
Additionally, Sri Lanka has established a separate juvenile court system to hear cases involving
children. Therefore, the introduction of a privacy provision for sensitive data related to evidence
and parties involved in these child labor issues would reduce the public community's reluctance
to become involved in juvenile cases where it would disclose sufficient evidence without
addressing confidentiality concerns. The existing legal framework is the lack of a coherent set of
laws regarding cruelty suffered through child labour. However, the Police Department has the
power to report such incidents in cases of serious injury under Sections 31435, 31536 and 31637
of the Criminal Code. Therefore, the implementation of this legislation directly depends on the
perseverance of the bodies dealing with such cases19.
In accordance with the provisions of ILO C 138, Sri Lanka has raised the minimum age for
admission to employment from fourteen to sixteen. Accordingly, the definition of a young
person as a person between the ages of sixteen and eighteen has been amended. Further, in view
of current child labor issues, amended the definition of a child to include people under the age of
sixteen.
In preparation for these changes; Section 1044 of the Shop and Office Employees Act was
amended by Section 2 of the Bill45, raising the minimum age for employment from fourteen to
sixteen. Section 3446 of the EWYCA has been amended by section 747 of the bill, which defines
a youth as a person between the ages of 16 and 18 and a child as a person under the age of 16,
and raises the age to attend primary school at age 16. Accordingly, Section 348, Section 949 and
Section 2050 of the EWYCA are to be amended to modify the new definitions of children and
young personnel arising from the law.
Referring to the amendments to the Ordinanza Fabbriche; Section 12751 was amended by
Section 752 of the Bill, which raised the minimum age for employability to sixteen, Sections
6653, 7854 and 8655, which established that a young person was a person who had not attained
the age of eighteen. With regard to working time, Article 67(b)56 was amended by Article 257 of
the Bill, which stipulates that a juvenile's daily working time shall not exceed 12 hours between
6:00 a.m. and 8:00 p.m. on any day of the week that the working time ends must, at 1 p.m. one
day a week.
Minimum Wage Ordinance Amendments, Section 258 of the Bill amended Section 459 by
raising the employment age to sixteen during; Section 1860 was amended by Section 461 of the

18
Child Activity Survey.
19
Penal Code (Amendment) Act No. 22 1995
bill, which raises the employment age for female employment to sixteen to accommodate
payment of the minimum wage. However, children are not prevented or exempt from engaging
in family agricultural businesses, commercial activities related to charitable or educational
purposes, in which the child may participate before or after school starts in such businesses. It
should be recommended that Sri Lanka's current child labor legislation be reviewed and amended
to achieve children's welfare and close loophole20.
Although child labor surveys in Sri Lanka indicate relatively low child labor rates, many
instances of child labor in the corporate sector go unreported. These conditions exist because the
Sri Lankan public has insufficient knowledge of child labor laws and the public is reluctant to
complain about such sensitive issues affecting them as vulnerable violations of child labor rights.
International child labor conventions amending existing Sri Lankan laws always exist nor
inconsistencies and gaps in the legislation implementing these child labor laws.
The existing Bangladesh legislative framework on child labour and gaps
Considering the existing child labor laws in Bangladesh, as a British colony, it inherits all the
laws and regulations of Britain21 The illiteracy rate in Bangladesh is on the rise mainly due to
economic conditions families in the country. In addition, inefficiencies in child registration led to
child labor. Pakistan Domestic Employees Registration Ordinance, Tea Plantation Labor
Ordinance, Shops and Factory Act and Factories Act. Bangladesh's export-oriented garment
industry has led to the emergence of child labor, where the government of Bangladesh has put in
place several mechanisms to address these issues. Although international and national legislators
often made efforts to eliminate child labor, Bangladesh as a country has yet to address child
labor due to continued acceptance by society. The constitution of Bangladesh could be identified
as basic human rights, although it does not explicitly mention the prohibition of child labour22.
However, sections 15, 17, 28(4) and 34 of Labour Act of Bangladesh provide for different
statutory provisions on child labour. Serving as highly influential national child labor legislation.
The 2013 amendment introduces new provisions; Article 21 of the Labor Act identify a child as
an individual who has reached the age of 14 years. The law declares persons between the ages of
fifteen and eighteen to be adolescents within the meaning of Section 34 and Section 34(1) and
restricts child labor in any occupation or establishment. Section 35 restores section 34(1)
prohibiting a parent or guardian of children from arranging with their children to be employed in
a profession.
In addition, the Bangladesh Supreme Court has questioned the lack of protection of child labor
by harshly criticizing the Bangladesh government for not acting towards these workers as if
neglecting a fundamental right of the Bangladesh Constitution and directing them to take action
to take action to protect these rights by extending the scope of the Labor Code 2013 to all types
of domestic workers.136 the provisions in line with the Supreme Court's opinion.

20
Jayathilake, 2023. A Comparative Analysis of the Existing Legal Framework of Sri Lanka on Child labour
21
Norpoth, et al 2014. Child labour in Bangladesh
22
Norpoth, J., Groß, L. and Aktar, R., 2014. Child labour in Bangladesh-an analysis of gaps and weaknesses of the
existing legal framework (No. 204). IEE Working Papers.
However, article 4423 grants an exception for light work performed by children from the age of
twelve and states that such work is permissible without impeding their educational, mental and
physical development in their school environment. Article 34(2) sets out the conditions to be
taken into account when recruiting young people. Articles 39, 40 and 42 mention the dangerous
professions prohibited for young people. Section 41 mentions acceptable work hours for
teenagers against expanded occupational hazards. Therefore, one of the main shortcomings of
labor law is its limited scope of application, which excludes several economic sectors from its
application, although the territorial scope is country-wide24.
In addition, the Children Act25 repealed the old law of 1974 which provided comprehensive
protections against child labor based on the UN CRC standards, which have been described as
the cornerstone for children in Bangladesh. Here, a minor is defined as a person under the age of
eighteen, which the old law defined as sixteen. Minors are forced to beg, supply drugs, sell
weapons to minors, abuse and criminalize minors in the workplace.
The Bangladesh government has made progress in tackling the worst forms of child labor by
passing a law to deter and combat human trafficking. The primary function of this law is to
combat human and labor trafficking, paying particular attention to domestic and transient human
trafficking activities. It is imperative that this law is implemented and enforced in Bangladesh as
child trafficking is considered to be one of the worst forms of child labour. It should also carry
severe penalties such as fines, imprisonment and the death penalty. Bangladesh has implemented
child labor policies regulatory frameworks, which are considered part of national education
policy and child labor abolition policy
UNICEF and MOLE 2002 help reach children and eliminate child labor in urban and rural areas.
Further details are contained in the first and second optional protocols on the worst forms of
child labor and trafficking, child pornography and child prostitution, to be signed and ratified
respectively by Bangladesh. However, the Committee on the Rights of the Child has issued a
statement released recently in 2009 is concerned that in Bangladesh, where the worst forms of
child labor still prevail, there are no mechanisms in place to protect child labor despite the
ratification of these international conventions.
Bangladesh has also ratified international conventions such as ILO Convention 182 and UN
CRC to address child labor issues and fill gaps in Bangladesh's legal framework relating to child
labour. In addition, the Government of Bangladesh has announced the ratification of ILO C 138,
which has yet to be ratified, and Bangladesh would ratify all United Nations conventions on
child labor if signed.
Regarding statistical surveys on child labor issues in Bangladesh, it has been reported that
children engage in child labor for payment or profit or to support family businesses and
exploitation by these owners. If you consider the reasons for the prevalence of a dramatically
high rate of child labor, such as; Poverty, deaths, low-income families, debt, serious illnesses of
adults due to factors such as natural disasters and the impact of the economic situation in
23
Labour Act (Amended) 2013, Section 44
24
Ibid
25
Children Act 2013
Bangladesh where children are being forced to work under the minimum age for gainful
employment. Society would be dependent on the income from child labor26.
In addition, to enforce child protection, the establishment of a child protection committee at
national level and the establishment of a child protection unit in each police station to which
children can lodge complaints about violations of their rights at work could be recommended 27.
However, these welfare procedures can only be effectively implemented on the basis of
governmental considerations and allow such implementation to take place effectively and
efficiently.
In summary, each of the above jurisdictions has an obligation to amend, revise, renew and
implement appropriate laws to prevent such unfortunate situations in which children lose their
ability to receive adequate educational institutions under sound economic conditions. If the
children of the nations do not receive a solid education in the interest of the general public, the
tendency towards illiteracy increases, which hampers the economic, social and political
standards of the countries. It is the collective duty of the legislature, judiciary and executive
branch to protect the future of every nation by creating a sound environment in which to stabilize
the economy to eliminate child labor problems. Therefore, a collective understanding that the
future of any country depends on the literacy rate of its future generations would go a long way
towards mitigating and eliminating child labor from decades of social traditions.

METHODOLOGY
This chapter outlines the methodology used to conduct the comparative analysis of the legal
frameworks for eliminating child labour between Sri Lanka and Bangladesh. The study used a
qualitative research design, and only literature was used in the research. This chapter explains the
research approach, data collection methods, and analysis techniques used in the study.

Research Approach
The research approach used in this study is a qualitative comparative analysis. The comparative
analysis approach allows for a systematic comparison of legal frameworks in Sri Lanka and
Bangladesh concerning child labour elimination. A qualitative approach was used as it allows for
an in-depth exploration of the topic and provides a better understanding of the legal frameworks
in the two countries.

Data Collection

26
163 J Norpoth, L Grob and R Aktar, ‘Child Labour in Bangladesh

27
Dr. R Siddiqua, ‘Laws Relating to Child Labour in Bangladesh and their Shortcomings
This study's data came from a wide range of sources. The primary sources of data were academic
journals, books, reports, and other relevant literature on child labour laws in Sri Lanka and
Bangladesh. The data were collected from reputable sources such as the International Labour
Organization, UNICEF, and the World Bank.

Data Analysis
The data collected for this study was analyzed using a thematic analysis approach. The thematic
analysis involved the identification of themes or patterns within the data. The process involved
reading and re-reading the literature to identify recurring themes or patterns related to the legal
frameworks for eliminating child labour in Sri Lanka and Bangladesh. The themes were then
compared to identify similarities and differences between the two countries' legal frameworks.

Ethical Considerations
This study used only literature as its source of data. No interviews or surveys were conducted.
Therefore, there were no ethical concerns related to informed consent, privacy, or confidentiality.
The study adhered to ethical principles such as academic integrity, avoiding plagiarism, and
giving credit to the original authors.

Limitations
The study's limitations include the reliance on literature, which may not provide a comprehensive
understanding of the situation on the ground. Additionally, the study did not involve primary
data collection, such as interviews or surveys, which may have provided more detailed
information. Finally, the study focused only on legal frameworks and did not consider the actual
implementation of these frameworks in practice.

Conceptual framework
The conceptual framework of the research on the comparative analysis of the legal frameworks
for eliminating child labour between Sri Lanka and Bangladesh is a critical component that
provides a framework for understanding the study's research questions and objectives. The
conceptual framework outlines the key concepts, variables, and relationships between them.
Additionally, it guides data collection and analysis.
The central concept of the research is child labour. This concept is defined as the employment of
children under the age of 18 in work that is hazardous or interferes with their education,
development, or health. Child labour is a significant issue in many developing countries,
including Sri Lanka and Bangladesh. The legal frameworks for eliminating child labour are the
key variables in this study. The legal frameworks refer to the laws, policies, and regulations in
place in Sri Lanka and Bangladesh that aim to eliminate child labour. The study aims to compare
and analyze the legal frameworks in both countries to determine their effectiveness in
eliminating child labour.

The study will examine the key components of the legal frameworks, such as the minimum age
for work, the types of work prohibited for children, the penalties for non-compliance, and the
mechanisms for monitoring and enforcing the laws. By comparing the legal frameworks in Sri
Lanka and Bangladesh, the study seeks to identify similarities and differences, strengths, and
weaknesses.

The relationship between the legal frameworks and child labour is an essential aspect of the
conceptual framework. The study assumes that strong legal frameworks play a crucial role in
reducing and ultimately eliminating child labour. The study hypothesizes that the legal
frameworks in Sri Lanka and Bangladesh have both strengths and weaknesses that impact their
effectiveness in eliminating child labour. The conceptual framework for this research provides a
roadmap for data collection, analysis, and interpretation. It provides a clear understanding of the
key concepts, variables, and relationships between them. The conceptual framework helps to
ensure that the research is focused and that the results are relevant and applicable to
policymakers and stakeholders concerned with eliminating child labour in Sri Lanka and
Bangladesh.
In this study, the legal frameworks for eliminating child labour are the independent variables,
while the incidence of child labour is the dependent variable. The legal frameworks are the key
factors that are expected to impact the incidence of child labour, and hence are independent
variables. The dependent variable, on the other hand, is the outcome of interest that is influenced
by the independent variables, which in this case is the incidence of child labour. The study aims
to compare the legal frameworks for eliminating child labour in Sri Lanka and Bangladesh and
analyze their effectiveness in reducing the incidence of child labour. Therefore, the legal
frameworks are the independent variables, while the incidence of child labour is the dependent
variable in this study.

Chapter Summery

This chapter outlined the methodology used to conduct the comparative analysis of the legal
frameworks for eliminating child labour between Sri Lanka and Bangladesh. A qualitative
research approach was used, and the data were collected from literature. Thematic analysis was
used to analyze the data, and ethical considerations were taken into account. Additionally, the
study's limitations were discussed. Overall, this methodology provides a systematic and in-depth
analysis of the legal frameworks for eliminating child labour in Sri Lanka and Bangladesh.

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