The Supreme Court has described the forced employment of minor girls in orchestras, particularly in Bihar and West Bengal, as a “very serious” issue. It has also highlighted the exploitation of these minors in massage parlours across Delhi and Rajasthan, prompting the court to seek comprehensive responses from state authorities regarding protective measures.
During a hearing, Senior Advocate H. S. Phoolka, representing the NGO ‘Just Rights for Children Alliance,’ informed the bench—comprising Chief Justice Surya Kant and Justices Joymalya Bagchi and Vipul M. Pancholi—that girls aged 10 to 16 are being coerced into work in orchestras and massage parlours as a means to settle their parents’ debts. This practice is a clear violation of the Child and Adolescent Labour (Prohibition and Regulation) Act of 1986, which prohibits the employment of minors in hazardous industries.
Phoolka articulated that various sectors, including orchestras, dance bars, dance troupes, and massage parlours, have avoided being classified as hazardous industries, thereby creating a loophole for organized child trafficking and sexual exploitation. The Supreme Court has also issued notices to the National Commission for Protection of Child Rights (NCPCR) and the National Human Rights Commission (NHRC) regarding this issue.
According to the NGO, between March and December of the previous year, over 200 minors were rescued from orchestras, dance troupes, and nautanki groups primarily in Bihar and West Bengal, while an additional dozen were freed from massage parlours and spas in Delhi and Rajasthan.
The NGO reported that children are often recruited from impoverished, tribal, and marginalized communities through deceptive promises of employment, glamour, dance training, marriage, or economic upliftment. These minors are trafficked across districts, states, and even international borders, often living in overcrowded and unsanitary conditions. They are deprived of education and freedom, forced into labour, and subjected to sexual exploitation.
The report emphasized that orchestra and nautanki groups, which initially served as traditional forms of entertainment, now function in a regulatory vacuum, facilitating organized criminal activity with little to no oversight. It noted that minor girls from marginalized communities are often misled through false promises, with some families financially coerced into giving up their children due to severe economic hardship.
The organization stated that girls as young as 12 are trafficked and sold for minimal sums to orchestra operators, creating significant financial incentives for traffickers. The plight of these girls is dire, as they are reportedly forced to perform in sexually provocative clothing, subjected to obscene music in front of intoxicated audiences, and face various forms of violence, including molestation and, in extreme cases, assault with weapons.






