The Supreme Court on Monday asked the Centre, the National Commission for Protection of Child Rights (NCPCR) and the National Human Rights Commission (NHRC) to respond to a PIL seeking an absolute ban on employment of children and adolescents in orchestras, dance troupes, massage parlours, and spas.
Terming the situation “serious”, a Bench led by Chief Justice of India Surya Kant also issued notices to union ministries of labour and law and justice on the petition filed by child rights collective ‘Just Rights for Children Alliance’ (JRCA) after senior advocate HS Phoolka submitted that minor girls aged 10 and 11 were being employed in orchestras and dance bars.
“For spas and massage parlours, some states have made rules of 18 years as the minimum age,” Phoolka told the Bench – which also included Justice Joymalya Bagchi and Justice Vipul M Pancholi.
Petitioner JRCA alleged that these sectors had evolved into “clandestine fronts” for organised trafficking, sexual exploitation, and forced labour of minor girls across the country.
Highlighting a critical “enforcement vacuum” in the Child and Adolescent Labour (Prohibition and Regulation) Act (CALPRA), 1986, the petitioner NGO pointed out that under the law, “hazardous” occupations where adolescent labour was strictly prohibited are listed under Part A of the CALPRA Schedule but massage parlours and spas fell under Part B, which meant that the employment of adolescents was merely “regulated” rather than banned.
As “orchestra” and “dance troupe” sectors — notoriously prevalent in Bihar and West Bengal, — remained entirely unlisted, traffickers exploited this statutory ambiguity to disguise the commercial sexual exploitation of children as “lawful employment” in the entertainment and wellness industries, the PIL submitted.
Citing data from rescue operations conducted between March 2025 and May 2026, the petitioner said 212 minor girls were rescued from orchestras and dance groups in Bihar and West Bengal and 12 minor girls were rescued from massage parlours and spas in Delhi and Rajasthan.
The victims — as young as 12 — were lured from impoverished communities on false promises of glamour, dance training, or film roles, the NGO submitted.
In fact, many of them were sold to operators for Rs 10,000 to Rs 50,000, forced into debt bondage, and compelled to perform in “sexually provocative attire” before intoxicated audiences, it said.
Citing a 2023 report by the Bharatiya Institute of Research and Development, the NGO said 44.04 per cent of all identified trafficking victims in India were minor girls and that spas were frequently used as fronts for “disguised sexual exploitation”.
