Bombay HC Says BMC Community Health Volunteers Must Get Minimum Wages

Mumbai, August 14, 2026: “Though branded as volunteers, CHVs almost work as workers of the Municipal Corporation,” the Bombay High Court observed while holding that Community Health Volunteers (CHVs) working with the Municipal Corporation of Greater Mumbai (BMC) are entitled to minimum wages under the Minimum Wages Act, 1948.

Justice Sandeep Marne, on August 13, dismissed a batch of petitions filed by the civic body challenging an order directing it to pay CHVs the difference between the notified minimum wages and the honorarium already paid to them.

BMC Challenge Dismissed

The BMC had challenged the September 7, 2020, order of the Authority under the Minimum Wages Act, 1948, and the Assistant Commissioner of Labour, Mumbai City, which had upheld the CHVs’ entitlement to minimum wages.

The court said the CHVs perform important public health duties and have been working with the civic body for decades. They help spread health awareness, support government health programmes and act as a link between health posts and local communities, especially in slum areas. The programme has been running for nearly 38 years.

Court Finds Structured Employment

The judge noted that the CHVs do not merely volunteer but carry out assigned duties for the BMC “for reward”. He pointed out that they report for duty, work fixed hours, follow instructions from medical staff and receive a fixed monthly payment.

The civic body had argued that there was no employer-employee relationship and that the CHVs were only volunteers. The civic body also submitted that they currently receive an honorarium of Rs 14,000 per month for five hours of work a day.

The court rejected the argument that describing the payment as an “honorarium” would take the CHVs outside the scope of the Minimum Wages Act. It said the nature of work and control exercised over them showed they were performing structured duties.

No Right To Permanency

The court also clarified that the case was not about regularisation or making CHVs permanent employees. It said the only issue was whether they were entitled to minimum wages, and granting them such wages would not give them any right to permanency or additional service benefits.

Justice Marne further noted that the BMC itself ensures minimum wages for workers engaged through contractors. He said it was difficult to justify denying the same protection to CHVs who are directly paid by the civic body.

The court held that CHVs must be paid the notified minimum wages according to the hours they work.

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Stay Request Rejected

The court also rejected the BMC’s request for a six-week stay on the judgment.

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