IN JUNE 2025, as Delhi's temperatures edged past 45°C, construction work continued uninterrupted across the city's skyline. Daily-wage labourers, street vendors, and sanitation workers braved the scorching sun with little choice, their livelihoods tethered to exposure. The National Disaster Management Authority (‘NDMA’) had issued a significant advisory calling for the integration of informal workers into Heat Action Plans (‘HAPs’), acknowledging their vulnerability to extreme heat. While this is a step forward, it also exposes a deeper truth: heatwaves are not merely a meteorological crisis but a crisis of political economy.
India has experienced a sharp rise in heatwave days in recent years, with 2024 marking one of the most severe summers on record. In a historic anomaly, the Indian Meteorological Department (‘IMD’) recorded heatwave conditions as early as February 2025, with states like Goa and Maharashtra experiencing temperatures far above seasonal norms.
Yet the impact of such climate extremes is far from being evenly distributed. Over 90 percent of India’s workforce is employed in the informal sector, and a large share of these workers operate outdoors: in construction, delivery, sanitation, and vending without access to climate-controlled environments or mandated rest breaks. According to the International Labour Organization (‘ILO’), India lost approximately 259 billion labour hours annually between 2001 and 2020 due to extreme heat and humidity. By 2030, India is expected to lose nearly 6 percent of its total annual working hours due to extreme heat, which could translate into more than 34 million full-time job losses.
India has experienced a sharp rise in heatwave days in recent years, with 2024 marking one of the most severe summers on record.
These figures are more than economic abstractions. They represent an everyday grind marked by dizziness, dehydration, reduced productivity, and long-term health risks, particularly for women workers who often juggle both domestic and income-generating work. Vulnerability here is layered: by occupation, gender, geography, and access to shade, water, and healthcare.
Legal gaps and governance failures
Despite growing evidence, heat remains under-recognised in India's disaster management and labour protection frameworks. Heatwaves are still not classified as "notified disasters" under the Disaster Management Act, 2005, which limits budgetary allocations from disaster response funds.
India's labour legislations are similarly ill-equipped; the Occupational Safety, Health and Working Conditions Code, 2020 (‘OSHWC’) does not recognise ambient heat as a workplace hazard, nor does it mandate hydration breaks or shade provisions. The Factories Act, 1948 and the Inter-State Migrant Workmen Act, 1979 offer no specific provisions for thermal stress, despite high-risk occupations being overrepresented in these sectors. The Labour Ministry’s advisory (April 2025), which encourages hydration breaks and flexible work hours, is non-binding. As a result, workers continue to labour through peak heat periods, without enforceable rights to protection.
Patchy policy and implementation
While NDMA's 2025 advisory is significant in naming vulnerable informal workers and calling for gender-sensitive HAPs, most Indian cities either lack such plans or have underfunded, copy-paste versions. According to the Climate Policy Initiative, only 30% of HAPs mention funding, and even fewer detail implementation protocols.
Ahmedabad remains the rare exception as its Heat Action Plan which was launched after a deadly 2010 heatwave has reduced heat-related deaths by over 60%, through early warning systems, medical training, and opening daytime shelters for vulnerable populations. However, its replication is slow and piecemeal.
Urban inequality and the politics of exposure
The urban poor live and work in the hottest corners of our cities: tin-roofed houses, unshaded vending areas, unpaved construction sites. Cooling is a class privilege, as less than 10 percent of Indian households have air conditioning. Climate resilience has barely shaped urban planning. The Smart Cities Mission privileges digital surveillance and beautification over climate adaptation. Tree cover continues to fall, with no regulations mandating shaded public infrastructure. Inadequate water supply exacerbates dehydration risks.
For example, a tea-stall vendor interviewed in Delhi by SPRF reported that during menstruation, the heat made her feel faint and unable to stand for long hours. Brick kiln workers in West Bengal reported a 2% decline in productivity with every 1°C temperature rise.
Municipalities often cite a lack of funds, yet mechanisms exist in the forms of the State Disaster Relief Fund, CAMPA funds, and Smart Cities budgets.
From policy charity to rights-based governance
There is a risk that climate adaptation becomes charity: ice packs, water kiosks, and awareness drives and no doubt that these are helpful, these are no substitute for rights-based protections.
Legal amendments are necessary; the OSHWC Code must explicitly address thermal stress, the Street Vendors Act should incorporate urban heat zoning and employment guarantee schemes like Mahatma Gandhi National Rural Employment Guarantee Act (‘MGNREGA’), 2005 should be adapted for urban settings, with climate adaptation work such as cool roofing, tree planting, and water harvesting. Worker welfare boards should be empowered to distribute heat-protection kits and provide insurance against income loss. Employees State Insurance Corporation (‘ESIC’) facilities can include heat illness treatment desks, especially in industrial zones.
Financing heat resilience
Municipalities often cite a lack of funds, yet mechanisms exist in the forms of the State Disaster Relief Fund, CAMPA funds, and Smart Cities budgets. Even Corporate Social Responsibility (‘CSR’) allocations can be directed toward urban heat adaptation. Additionally, climate finance from national and global sources including the National Adaptation Fund for Climate Change should prioritise heat resilience infrastructure and informal worker safety.
Toward a constitutional response
The Directive Principles of State Policy (Articles 39, 41, 42 and 47) enshrine the state's duty to ensure humane working conditions and public health. Article 21, guaranteeing the right to life, has been interpreted by the Supreme Court to include health and dignity. The failure to protect workers from foreseeable, fatal heat exposure is a governance gap that risks violating these constitutional commitments. In the long term, the courts may need to intervene whether through a Public Interest Litigation (‘PIL’) or through future jurisprudence recognising a "right to climate-safe work".
India’s heatwave crisis is not only an environmental problem it is a crisis of justice. Labour rights, urban design, and climate resilience must converge into a coherent policy and legal framework. Informal workers should not be asked to survive the summer on their own. The state must move beyond advisories and pilot projects. Heat governance must be codified, funded, and enforced.
As temperatures rise, the true measure of India’s climate preparedness will lie not in global rankings, but in the lives and rights of those who cannot afford to stop working.