Concerns were raised in 1980s about lack of appropriate compensation for sugar factory harvest workers in South Gujarat. M. C. Bhatt was appointed court commissioner for inquiry into this matter. His report resulted in payment of minimum wages to 1 lakh 25 thousand migrant workers at 9 sugar factories and set a precedent. Similarly, concerns were raised regarding use of bonded labour at IFFCO. Bhatt conducted inquiry as court commissioner which ultimately resulted in release of the bonded labourers.
