Comments- All the poor household of the village should be beneficiary of the programme (In our definition any person who is ready to do 8 hours hard labour as casual manual laborer is a poor person therefore any person who volunteer their application for the employment should be within the scope of the act).Taking all the poor househo;ld and not just BPL families is essential because it seems that in future all the work in the village(presently under various schemes) may be incorporated under one umbrella- the EGA therefore person who are not in BPL will be denied to any employment if this act is put into operation .Furthermore in Jharkhand contest there are so many irregularity in the BPL listing which will lead to improper targeting of the scheme. Therefore all the capable adults in individual Poor House hold must get the opportunity to work under the Scheme.

Provisions- "minimum wage", in relation to any area. means the minimum wage fixed by the State Government under section 3 of the Minimum Wages Act, 1948 agricultural labourers as applicable in that area;Comments- Universal wage rate for the whole country and should not be as per

the notification of the state Government.

Provisions- that no such rate shall be less than one-fourth of the wage rate for the first thirty days during the financial year and not less than one-half of the wage rate for the remaining period of the financial year.

Comments- Unemployment despite the act should be seen as the failure of Government therefore laborer should not be victimized and get 1/4 or ½ of the full wage. Worker should get the full wage in case Government is not able to provide the employment. Priority should be to provide employment and not unemployment allowances.

provisions- providing at least one hundred days of guaranteed wage employment in every financial year to every household

Comments- It should be minimum of 200 days of employment (100 days employment does not seems to be creating extra work-humandays particularly if one count all the work-humandays created by present schemes it is equivalent or rather more than 100 days. Therefore the bill should ensure at least 200 days of employment)

Provisions-Applicants continuously remains absent from work, without obtaining a permission from the concerned implementing agency for a period of more than one week or remains absent for a total period of more than one week in any month,shall not be eligible to claim the unemployment allowance payable under this Act for a period of three months but shall be eligible to seek employment under the Scheme at any time.

Comments- This is not practical in the State like Jharkhand where villagers migrate to outstation for long duration and this is a type of punishment and should be deleted from the provisions.

Comments-( Addition) Opposition party should also be in the committee and the representative of the Human rights commission, National and state commission of women, workers organisation and reputed civil society organizations representatives. It should also include labour commissioners.

Comments- They have the maximum authority to handle the scheme(if one goes by the structure and spirit of the proposed act) .In all likelihood these post will be merged with collector and BDO/CO. The bill should clearly mention that these post will not be merged with existing post of collector and BDO/CO.These posts are so stately and power filled that a common person will always fear in making them accountable.Furthermore the act should spell out such mechanism which will ensure transparency and accountability in their functioning.Furthermore if they fail to render the services as per the provisions of the act they should be held responsible and punitive actions should be taken against them.

Provisions-The Central Government may, in consultation with the Comptroller and Auditor General of India, prescribe appropriate arrangements for audits of the accounts of the Schemes at all levels.

Comments-CAG must also be authorized to include the report of Social audit and it should also be necessary to do the physical verification by the CAG on the basis of report of Social audit organized by the Gram sabha.

Comments (addition)- Gram Sabha must issue the Utilization and completion certificate and all the Bills and voucher on Wage and material component must be approved by the Gram sabha. 100% of the work should be implemented by the Gram sabha and not only 50%.

Provisions- No suit, prosecution or other legal proceedings shall lie against the District, Programme Coordinator, Programme Officer or any other person who is, or who is deemed to be, a public servantComments- Gram sabha should have the legal authority to file the complain against the officer in case not responding the villagers as per the norms and accordingly steps to be taken by the higher authority and power must be given to an individual and the organisation for suiting legal case in case if things are not moving in the right direction .

Addition- If any women worker applied for the work and during the work duration is pregnant then under the maternity benefit she must get the full wages. And 50% work opportunity must be provided to the women if they volunteered for work.

Provisions-In cases the employment i~ provided outside such radius, it must be provided within the Block, and the labourers shall be paid ten per cent. of the wage rate as extra wages to meet additional transportation and living expenses.

Provisions- If a person employed under a Scheme dies or becomes permanently disabled by accident arising out of and in the course of employment, he shall be paid by the implementing agency an ex gratia payment at the rate of ten thousand rupees or such amount as may be notified by the Central Government, and the amount shall be paid to the legal heirs of the deceased or the disabled, as the case may be.Comments-Workmen compensation Act must be in function in the case may be and not the implementing agency but the Government has to bear the cost of compensation.

(Addition)- At work site all the information regarding the Scheme and the person working in the scheme should be displayed before the commencement of work and will be displayed till last.

(Addition)-In the true spirit of affirmative action there should be extra provisioning for drought-affected areas.