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Authored By: Dr. Manu Sharma, Professor of Law & Co-Authored By: Ms. Barsa Rani, Ph.D. Scholar (Law), School of Legal Studies & Governance, Career Point University, Hamirpur, Himachal Pradesh,
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I. INTRODUCTION:
Child rights in India have evolved from limited colonial regulations to strong constitutional safeguards. Pre-Independence laws like Apprentice Act, Factories Acts, and Child Marriage Restraints Act were early attempts to address Child Labor Juvenile Justice, and social evils, with limited success. After independence, the Indian Constitution recognized children special needs with provisions such as Article 15(3), Article 24, and Article 39. Judicial interpretation and legislation such as the Juvenile justice Act, Right to Education Act, POCSO Act have further strengthened child protection. Thus, the journey of child rights under the Constitution reflects a continuing struggle to secure protection, dignity, and development for every child. The primary objective of this study is to examine the laws and constitutional provisions related to child rights and to trace the evolution of these rights within the framework of the Indian constitution[1]. Child means everything to us; they are our whole world. We protect our world from evil eyes. It is not possible to be with their child all day. This is why it is critical to ensure children’s safety and protection in places such as our home or neighborhood, school, college. The majority of crime, such as sexual assault, rape, and molestation, occurred in society, schools, or even their own home. Sometimes they are raped or abused by their family members. A child is not capable of distinguishing between rights and wrong and can easily be influenced or misled by others. Therefore, it is the responsibility of teachers and everyone who is around the child to ensure their safety and well-being. This duty extends beyond individuals-it is collective responsibility of our district, state, and nations to safeguard the rights of every child. And as children grow and begin to understand their rights, it is equally important to educate and empower them so they can stand up and fight for their right themselves[2]. The number of crimes against children in India has been increased with 162,449 cases reported in the NCRB 2022 report, an 8.7% rise from 2021. A majority of these cases related to Kidnapping and abduction were filed under the Protection of Children from Sexual Offence Act.[3] These crimes including kidnapping, abduction, sexual offences under the POCSO Act and cybercrimes, show that children remain vulnerable despite legal protection. So, in the present scenario child rights are the essentials freedoms and rights that every person under the age of eighteen is entitled to regardless of their circumstances, origin or nationality. The Indian constitution, which acknowledges the special needs and vulnerability of children, is the foundation for the development of child rights in India. The constituents Assembly recognized the significance of safeguards children through special provision from the very beginning of constitution drafting. The extent of these rights has been greatly increased over time by judicial ruling and constitutional amendment [4].
II. OBJECTIVES:
- To identify and analyze constitutional provisions that safeguard and promote the rights of children.
- To examine the role of judiciary in interpreting and expanding child rights through [public interest litigation (PILs) and landmark judgment.
- To recommend legal and policy reforms for strengthening the constitutional framework and ensuring holistic development.
III. METHODOLOGY:
For the present research paper, the Doctrinal methodology has been adopted. For this purpose, various statutes, books, journals, commentaries, reports, magazines, newspapers, websites etc. have been consulted and referred to. For preparing this paper analytical, critical, historical, evaluative and socio-legal approaches are also applied to examine the existing laws, policies and their effects.
IV. MEANING & CONCEPT OF CHILD RIGHTS IN INDIAN CONSTITUTION:
Child rights are fundamental freedoms and protection specially meant for individuals below the age of 18years. These rights recognize that children are not just the future citizens of a country but also human beings who deserve dignity, security, and opportunities in the present. The evolution of child rights in India means the change over time in how society and law look at children. Earlier, children were treated like property or just as small adults, but now they are recognized as individuals who have their own basic rights. These include the right to life, survival, education, development, and protection, which together ensure that every child can grow with dignity and opportunities. The farmers and the guardians of our constitution also believed that child rights form a fundamental pillar of our constitution. Among the farmers of our Constitution was Dr. Bhim Rao Ambedker who played crucial role in its drafting. From his early childhood, Dr. Ambedkar faced numerous struggles, particularly due to caste-based discrimination. He began his fight against social injustice at a very young age. These early experiences deeply shaped his commitment to equality, human dignity, and social reform. As a visionary leader, jurist and social reformer, he dedicated his life to uplifting the marginalized sections of society. While darting the constitution, he gave special importance to child rights. His vision continues to inspire India’s commitment to social justice and inclusive growth. The preamble of our constitution which promises justice, liberty, equality, and fraternity, serves as the foundation for the protection of children’s rights. Ensuring that every child lives with dignity, safety, and equal opportunity is a direct reflection of the values enshrined in the preamble. Indian constitution has increasingly moved towards recognize and protecting child rights, thereby ensuring the welfare, development and protection of children. Child rights in India have evolved significantly through judicial pronouncements, legislative enactments, and constitutional provisions[5].
IV.I WHO IS CHILD?
The definition of “child” in India has evolved over time, shaped by social reform, constitutional ideals, and the need from legal protection in various contexts. The recognition and protection of children’s right in India have gradually developed through various laws, each addressing a specific need of the time. Many Acts were enacted both before and after independence, and in every Act the age of child was defined differently. But the question remained the same: who is child? There is certain Act in which the term “child” has been specifically defined. One of the first laws in India to deal with the problem of child labour was the Factories Act of 1881, which for the first time legally defined who could be considered a child. This act treated anyone under the age of 12 as a child and limited their working hours. But in 1948, after the independence of the factories act was amended, the minimum age of child workers increased to 15 years. Such employment was also prohibited in dangerous processes to protect their health and safety[6]. And later the Mines Act of 1923 defined a child as a person below of 15years and restricted or prohibited their employment in underground mines. These acts mark an early attempt to protect children from hazardous labour. These provisions reflected the earliest recognition of the hazardous nature of mining work for children, though they remained the same definition. After independence, the Mines Act of 1952 retained the same definition of child as one who has not completed fifteen years ages but introduced a stricter prohibition on the employment of children in any mine[7]. The evolution of the age definition of child under Immoral Traffic laws highlights India’s progressive approach towards child protection. Initially both colonial and early independence laws treated a child as one below sixteen years, which left older adolescents vulnerable to exploitation. With growing international pressure and India’s ratification of child right convention, the 1986 amendments to the Immoral Traffic Act raised the age limit to eighteen years[8]. When the Indian Penal Code (IPC) of 1860 was drafted, the primary goal was to define offence and prescribe punishments not to provide uniform definitions for social categories such as “child”. At the time, India had numerous laws in various areas, such as labor, marriage, and guardianship, each with its own age limit based on the purpose of the law. There was no single definition of “child.” The law only talked about certain ages in different sections. Sections 82 of Indian Penal Code said that a child below the age of 7 years cannot be punished for any crime. Section 83 of Indian Penal Code said that the child who is above 7 can be punished only if the court believes the child had enough maturity to understand that their act was wrong or against the law. If the child did not have this understanding there is no punishment[9]. The Reformatory Schools Act 1897 prohibited employment of children below 14 years in certain occupations and regulated their work conditions. This act was amended in 2016. It was a major change. It completely banned the employment of children below 14 years in any occupation, except for helping in family business after school hours it also introduced the “adolescent.” category, meaning persons between the ages of 14 to 18 years. Adolescents cannot be employed in hazardous occupations such as mining, chemical plants or explosives, but they may work in non- hazardous jobs. This was done to protect teenagers from physical harm while allowing them opportunities to learn skills safely. The Child Marriage Restraints declared that anyone under 18 years is legally considered a child. In this act child divided into two categories the one is child in conflict with law, means a child accused of committing an offence and the other one is a child who is neglected, abandoned, abused or otherwise in a vulnerable condition. This act ensures such children are not treated as adults’ criminals but are given care, rehabilitation, and social reintegration. The 2015 amendment made the law stricter by introducing faster trials for serious crimes committed by children aged 16-18 and by strengthening measures to protect children from exploitation and abuse. The Bhartiya Naaya Sanhita, 2023 (BNS) a major step in the evolution of child rights within Indian criminal law. With the implementation of the Bharatiya Nyaya Sanhitaaa, 2023 (BNS) in place of the Indian Penal Code, 1860 (IPC), some significant changes have occurred in relation to children and child related crime. The BNS now clearly defines for the first time “child” under Section 2(13) as a person under the age eighteen. The IPC did not expressly state this uniform definition, but many provision address age indirectly. A major change appears in offence against children under the Bharatiya Nyaya Sanhita, 2023 (BNS). Crime such as child trafficking, sexual offence, cruelty, and exploitation receive special attention, with clearer definition and in some cases, harsher penalties[10]. Under the Indian Penal Code (IPC) kidnapping had two different ages limit based on gender. According to 361 IPC, taking away a boy under 16 years without the consent of their lawful guardians amounted to kidnapping. This distinction caused confusion and was inconsistent with modern principles of equality and child protection. The Bhartiya Nyaya Sanhita, 2023 (BNS) has corrected this by introducing section 135, which clearly defines Kidnapping of a child as a taking away from the custody of their lawful guardian without the consent. This new modification in BNS means that the law now treats boys and girls equally by fixing 18 years as the uniform standard age of protection. This change is important because it removes gender-based discrimination. With this new change it also provides broader protection and brings criminal law in line with other child protection legislation such as the Juvenile Justice Act and the POSSCO Act[11].
V. PRE- CONSTITUTIONAL SCENARIO:
Before the adoption of the Indian Constitution in 1950, children in India had very little legal protection and were often exposed to exploitation, neglect, and abuse. Due to poverty, illiteracy, and traditional social practices, many children were compelled to work as child labourers, bonded labourers, or were subjected to early marriage. There were no comprehensive laws to safeguard their right to education, health, or overall well-being, leaving many children deprived of necessities and opportunities for proper development. During There are some Pre- independence Acts which deal with the evolution of child rights and also played an important role in the development of child rights in India. This legislation were the initial attempts made by the British Government to regulate child labor, education, protection from exploitation. Though limited in scope, they laid the foundation for later constitutional provisions and modern child welfare laws. Such act marked the beginning of legal recognition that children are entitled to special care and protection. During the colonial period, laws such as The Apprentice Act 1850 came into existence. The Apprentice’s Act of 1850 was one of the first laws to deal with children.it allowed master’s to take children as apprentices to learn trades. But in practice, it frequently forced them to work long hours with little regard for their health or education. This shows that, at that time children were primary viewed as a source of labor rather than individuals with rights. However, this Apprentice Act 1850 is important in the evolution of child rights because it marks the beginning of legal recognition that children’s work needed regulation. Later laws such as the Factories Act 1881, and its amendments in 1891, 1911 and 1934 slowly reduced working hours and fixed minimum age for child labour.[12] Another Act introduced by the Britisher for juvenile offenders was the Reformatories Schools Act 1897. Prior to Independence, India slowly recognizes that children in conflict with laws should not be treated in the same way as adult criminals. The Reformatories School Act 1920 was a significant step in this direction. It if children under a certain age who were convicted of crimes be sent a reformatories Schools rather than prisons. This act defined that boys under the age of 15 years and girls under the age of 18 years who were convicted of an offence could be sent to reformatories schools instead of prison[13]. In addition, the Indian Penal Code, 1860 included provisions to address crimes committed by and against children. This act contained several provisions for protecting children from offence like kidnapping, infanticide, and sexual abuse. It was a major step taken by Britishers as it specifically recognized child related offence as separate category under criminal law. By giving special mention to crimes against children, the IPC marked the beginning and differentiated treatment of child offenses, highlighting that children required a higher degree of legal protection[14]. Another initiative taken by the British for child protection was the Child Marriage Restraint Act 1929. Prior independence this Act, was a significant step in the evolution of child rights in India. This Act is also known as Sarda Act 1929. It was the first law to set minimum marriage age of 14 years for girls and 18 years for boys. It laid the foundation for later reforms which gradually increased the minimum age and provided stronger protection to children, especially girls, against early marriage. Thes Another important measures taken by the Britisher was the Factories Acts 1881 Acts placed restrictions on child labour by fixing minimum age limits, reducing working hours, and ensuring basic health and safety standards. They were among the earliest legislative attempts to control the exploitation of children in industrial establishment. Although the provisions were limited and enforcement was weak, they marked an important recognition by British Government that children required protection from hazardous labor and harsh working conditions[15].
VI. PRESENT CONSTITUTIONAL SCENARIOS:
Indian constitution went into effect on January 26, 1950, and it contained several provisions that laid the groundwork for child rights in India. The rights of the children in India have evolved through a complex interplay of constitutional vision, political will, and international influence. At the time of Constitutional making, child specific rights were not fully codified as separate fundamental rights, though the need for their protection was clearly acknowledged by leaders like Jawaharlal Nehru, Dr. B.R Ambedkar, and Mulana Abudal Kalkam Azad. These leaders were clearly aware of the exploitation, poverty, and illiteracy faced by children in per-independence India.[16] The first constitutional protections for children were included in 1950 through the following articles. The Indian Constitution’s framers laid the groundwork for child protection in 1950 including key provisions such as Article 15(3), Article 24, Article 39(e) 39 (f). The provisions under Article 15(3), Article 24, and clauses (e) and (f) of Article 39 were incorporated in the original Constitution of India in 1950, reflecting the framer’s commitment to child welfare. These Articles laid the foundation for protecting children from exploitation, ensuring their development, and allowing special laws for their benefit. Article 15 (3) is a very important provision in the original constitution of India.it empowers the state to make special provisions for women and children. Article 15 generally prohibits discrimination on the grounds of religion, race, caste, sec, or place of birth. But this exception shows that farmers of our constitution were fully aware of the unique needs and vulnerability of children. By including this clause, we can see that they laid the foundation for child friendly laws and policies, ensuring the protection of child rights in India. However, these rights were not enforceable rights, but rather moral obligations imposed on the state[17]. Article 24 is a fundamental provision of the Indian Constitution and has been part of it since its inception in 1950. It prohibits the employment of children below the age of 14 years in factories, mines, or any other hazardous occupation the inclusion of this Article in the constitution was result of the visionary leadership of Dr. Bhim Rao Ambedker and the support of other members of the constituent assembly, including Dr. Bhim Rao Ambedkar, John Mathai, K.M Munshi. At that time, the International Labor Organization (ILO) strongly advocated the prohibition of child labour and exploitation. The framers of the Indian Constitution took cognizance of these international standards and incorporated similar safeguard in the Constitution, particular through Article through Article 24, to prohibit child labour and ensure safe childhood[18]. Article 39(e) or 39(f) was incorporated in the original Constitutions by the framers of the Indian Constitution. These provisions are part of the Directive Principal of State policy, which although not enforceable by the courts. Directive principles serve as the guiding principle for the government. Article 39(e) or 39 (f) remind us of our moral responsibility to protect the rights and dignity of women, children, and workers. The main aim of these articles provides a constitutional direction to the state to ensure social justice and human dignity. The state cannot make any law that violates the principal laid down in the directive principal of state policy. If the state enacts such a law, it shall be considered invalid[19]. Article 45 is also one of the original provisions of the constitution of India that reflects framers’ vision for children’s education and welfare e. It is part of the Directive Principles of State Policies which serve as guidelines for the state. Article 45 clearly demonstrates that the Constitution’s farmers recognized the importance of child education and sought to ensure that every child had access to basic education. While several child rights were included in the original text of the Indian constitution such as Article 15(3) and Article 24, as well as the Directive Principles under Article 39 (e) and (f) recognition of children’s rights evolved over time. However, later in 2002, an amendment was made, and this provision was converted into a fundamental right[20].
VII. JUDICIAL ROLES IN THE EVOLUTION OF CHILD RIGHTS:
The Indian judiciary has played an important role in developing and protecting child rights in the country. Through various landmark judgments, the courts expanded the meaning of basic rights to include children’s welfare. The judicial recognition was a significant milestone in the evolution of child rights in India because it broadened the scope of Constitutional protection for children before the legislature formally amended in the constitution. The first landmark case in India that dealt with forced labour and the violation of child rights was People Union for Democratic Rights vs. Union of India (1982) also known as Asiad Workers Case. This case arose during the construction of facilities for the Asian Games held in Delhi in 1982. A social organization found that many labouers including children were working under extremely harsh and exploitative conditions. And they were not receiving the legally prescribed minimum wages and working extremely harsh and exploitative conditions. It was also found that these workers were compelled to work due to poverty and had no means of leaving the job, which amounted to forced labour. The Supreme Court held that forcing anyone to work for less than the minimum wage amounts to forced labor which is prohibited under Article 23 of Indian Constitution. This judgment broadened the meaning of “forced labour” and become a foundation for protecting child laborers’ rights in India[21]. In another case, Bandhua Mukti Morcha vs. Union of India (1984), Supreme Court held that, right to life guaranteed by Article 21 includes not only survival but also living with dignity. Children must be given the opportunity to grow up in safe, healthy environment without being forced into labor. In this case court also ordered the government to take steps to free and rehabilitate these children[22]. Education rights had also evolved through judicial interpretation in Mohini Jain vs. State of Karnataka (1992), In this case a young student challenged the high capitation fees charged by medical college. The court held that education is an important part of the right to life because without education a person cannot live with dignity. The rights to education were first recognized as a fundamental right by the Supreme Court in where it was declared to be part of the right to life under Article 21 A.[23] In another case Unnikrishnan J.P. vs. State of Adhra Pradesh (1993), the Supreme Court further clarified the scope of this right. In this case Supreme Court held that free and compulsory education is guaranteed for children up to the age of 14 years. This judgment is historical because it recognized education not just as a Directive Principle but a fundamental fear which is enforceable[24]. In this case, People’s Union for Civil Liberties vs. Union of India (2001) the rights to life were redefined but the Supreme Court to include not just physical survival but also the right to live with human dignity. This case concerned hunger and malnutrition, particularly among schoolchildren. The court ordered the government to provide free cooked midday meals in schools to ensure that children not only attend school but eat properly. In this case court held that right to food is part of the right to life under Article 21[25]. The judiciary’s proactive role in protecting child rights was further strengthened through this case which is Bachapan Bachao Andolan vs. Union of India (2011). This was a series of public interest litigation filed by NGO Bachapan Bachao Andolan, led by activist Kailash Satyarthi. This petition revealed shocking realities that children were being bought and sold, forced to work in factories, domestic work, and subject to abuse in illegal activities. The Supreme Court treated this matter with utmost seriousness and issued multiple directions. The court directed increased efforts to rescue trafficked children, prosecute offenders, and rehabilitate victims. The government was directed to strictly enforce the Child Labor Prohibition and Regulation Act and immoral traffic Prevention Act[26].
VIII. LOOPHOLES AND DRAW BACKS:
Although the Indian Constitution has gradually expanded protections for children, but several loopholes still weaken their full enforcement.
The major loopholes include:
VIII.I LACK OF EFFECTIVE EXECUTION:
While rights such as free and compulsory education exists in our Constitution under Article 21 A But their effectiveness is reduced due to the lack of infrastructure, teacher shortage, and poor monitoring.
VIII.II DELAYED RECOGNITION OF RIGHT TO EDUCATION:
In the original Constitution of 1950, education for children was mentioned only under the Directive Principal of State Policy under Article 45, which directed the state to provide free and compulsory education for all children. It was only after the 86th Constitutional Amendment, 2002, that Article 21 A was inserted, making free and compulsory education for children aged 6 to 14 years a fundamental right. This clearly shows a constitutional delay in transforming education from a mere policy goal in the original Constitution to enforceable rights.
VIII.III GAP BETWEEN LAW AND REALITY:
Although the Constitution provides several safeguards for children, there is a wide gap between legal provision and ground realities. Child labour continues despite Article 24’s prohibition. The lack of proper infrastructure, corruption, poverty, and weak monitoring mechanism have together turned children’s symbolic guarantees rather than practical protection.
VIII.IV LACK OF LEGAL AWARENESS AND EDUCATION:
While the Constitution guarantees several rights for children, it does not ensure that children are educated about these rights. The absence of legal literacy makes children more vulnerable to exploitation, as they remain unaware of Constitutional safeguards and remedies available to them.
IX. CONCLUSION:
The Indian Constitution has played a very important role in the evolution of child rights. In the original constitution of India, 1950, only a few provisions for the welfare of children. Article 15(3), Article 24, and Article 39(e) and (f), this article laid the foundation of child rights in India. However, the needs of children changed, and the Constitution evolved further for their betterment of child. Article 21 A is a historical step which made education free and compulsory between the age of 6 to 14 years. Judicial interpretation of Article 21 also expanded the meaning of right to life, ensuring protection, health and dignity for every child. Article 21 (A) marks a significant milestone in the evolution of educational rights in India, introduced by the 86th Constitutional Amendment Act, 2002. Prior to this amendment, education was merely a part of the Directive Principal of State Policy. It was not legally enforceable. It was only after the enactment of the 86th Constitutional Amendment Act, 2002 that the right to education attained the status of a fundamental rights in India. Article 51 A(k) was also introduced in 2002, making it a fundamental duty of parents or guardians to provide educational opportunities for their children. These later additions reflect the Indian Constitution’s dynamic nature and commitment The development of child rights in India reflects a continuous effort by the legislature, judiciary, and civil society to ensure the protection and well-being of children. Over time, these rights have grown from protection against exploitation and forced labour to include education, nutrition, and safety from abuse, supported by laws such as the Child Labour (Prohibition & Regulation) Act, 1986, the Juvenile Justice (Care and Protection of Children) Act, 2015, the Right of Children to Free and Compulsory Education Act, 2009, and the POCSO Act, 2012. Judicial interventions in landmark cases like People’s Union for Democratic Rights, Bandhua Mukti Morcha, Bachpan Bachao Andolan, and Mohini Jain have strengthened these rights, ensuring that children can grow in a safe, supportive, and dignified environment. This evolution shows that child rights are an integral part of human rights and require continuous legal enforcement, effective policies, and social awareness.
X. SUGGESTIONS:
X.I EXTENSION OF THE RIGHT TO EDUCATION UP TO 18 YEARS:
In our Constitution, Article 21-A of the Indian Constitution guarantee the right to free and compulsory education between the age of 6 to 14 years. Such an extension would also address the high dropout rates after elementary schooling, preventing children from being pushed into child labor and empowering adolescents. This reform would ensure that education is not only universal but also holistic, preparing children for responsible citizenship and a dignified life.
X.II PROPER IMPLEMENTATION OF CHILD RELATED LAWS:
India has progressive laws for children’s protection and development, including the Juvenile Justice Act, the POSCO Act, the Child Labour (Prohibition and Regulation) Act, and the Right to Education Act. However, many of these laws are only effective on paper due to lack of enforcement. As a result, strict monitoring, authority accountability, and community awareness are required to ensure their proper implementation on the ground. Only then the Constitutional visions of protecting children’s rights become reality.
X.III LEGAL EDUCATION TO CHILDREN:
There should be legal education for children in schools so that they know what crime is and what is not. Due to modernization, children are becoming mature at a very early age, but they don’t have proper legal awareness. There are many examples where a child commits serious crimes like murdering their family members or their friends due to aggression without knowing the consequences or punishment. If legal education is given in schools, then the children will learn about laws, rights, duties and punishment, which will help them to take better decisions and stay away from crimes. It will also guide them to control their aggression and understand that every action has legal results. This awareness can prevent many children from becoming either criminals or victims in society. Legal education can make them aware of illegal activities and give them the courage to talk openly instead of suffering in silence.
X.IV COMMUNITY PARTICIPATION:
Encourage active community involvement: Local communities and non-governmental organizations should be engaged in monitoring and protecting children, so that violations of child rights can be identified early and children receive timely support and protection.
X.V REGULAR POLICY UPDATES:
Child protection policies should be periodically reviewed and revised to address new challenges, such as online abuse, cyber exploitation, and emerging forms of child labour, ensuring that laws remain effective and relevant.
Cite this article as:
Dr. Manu Sharma & Ms. Barsa Rani, “An Evolution of Child Rights under Indian Constitution”, Vol.6 & Issue 2, Law Audience Journal (e-ISSN: 2581-6705), Pages 75 to 89 (6th Nov 2025), available at https://www.lawaudience.com/an-evolution-of-child-rights-under-indian-constitution/.
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[13] Id at 24.
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[18] Id. at 65.
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[20] Id.at 57
[21] People Union for Democractic Roights v. Union of India, AIR (1982) 3 SCC 235.
[22] Bandhua Mukti Morcha v. Union of India, AIR 1984 SC 802.
[23] Mohini Jain v. State of Karntaka, AIR 1992 3SCC 666.
[24] Unikrishnan J.P.v. State of Andhra Pradesh,AIR 1993SC 2178.
[25] People Civil Liberties v. Union of India,AIR 1997 SC 568.
[26] Bachapan Bachao Andolan v. Union of India, AIR 2011 5 SCC 1.
