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8. On behalf of the petitioners, it is submitted thus :

Migration of unemployed labour from villages to cities is a compulsion for those migrating. The urban population needs labour for urban development. No urban development can be achieved without involvement of manual labour. The landless agriculturists or unemployed labour who migrate to cities are employed for national growth, housing, raising of multi-storey complexes, construction of roads, sewerages, canals, electricity and telephone lines, pathways and various other kinds of public and private works. Some unemployed labour not so utilised seek private employment for work in the factories or domestic work in the houses. To earn a living, such poor persons are compelled to squat by the side of the roads and sometimes to erect hutments or slum colonies on vacant available public land. Sometimes such labour employed on a work site are allowed to squat or live just near the work site or at a distance from such sites. When the work or need of employment for them is over at one place, they are asked to immediately shift and sometimes even without giving them a reasonable notice. In urban development, the unemployed poor are engaged for the needs of affluent sections of the society for providing the latter shelters and sometimes better shelters. Those who are employed for providing shelters to others cannot be allowed to be rendered without shelter.