COMPARATIVE ANALYSIS OF LABOUR LAWS IN INDIA, UK AND USA

AUTHOR – ARNAV KAUSHIK, STUDENT AT AMITY UNIVERSITY MUMBAI

BEST CITATION – ARNAV KAUSHIK, COMPARATIVE ANALYSIS OF LABOUR LAWS IN INDIA, UK AND USA, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 5 (1) OF 2025, PG. 669-676, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT

Labour laws have always been a subject of discussion all around the world. The Indian labour laws are very different from the labour laws in other countries. India’s labour laws, heavily influenced by colonial-era regulations, emphasize worker welfare but can be complex due to numerous statutes and varying state laws. In contrast, the UK operates under a more unified legislative framework, with a strong focus on employee rights such as fair wages, health and safety, and working hours, regulated primarily by the Employment Rights Act and the Health and Safety at Work Act. The USA follows a decentralized approach where federal and state laws interact, offering essential protections under the Fair Labour Standards Act and Occupational Safety and Health Act, but with fewer guaranteed worker protections compared to the UK and India.

This research paper aims at comparing how minimum wages affect the lower end of the working class, the review period for the minimum wages, relation of minimum wages to inflation, age related minimum wage rates, minimum wage rate and cost of living, across India, UK, and USA. This comparative analysis also examines labour laws in India, the UK, and the USA, focusing on key differences and similarities in employment rights, workplace standards, and dispute resolution.

While all three countries aim to protect worker rights, the extent and approach vary significantly. These differences highlight each country’s unique socio-economic context and legal traditions, underscoring the challenges of achieving uniform labour standards globally.

Keywords: Wages, Working Hours, Labour Laws, Minimum Wage, Uniform Labour Standards, Workplace Standards