Introduction

India is experiencing a rapid escalation in extreme heat events, with policy experts warning that the absence of a comprehensive legal and policy framework is transforming heatwaves into a systemic socio-economic and human rights crisis.

Scale of the Heat Crisis

  • 57% of districts (housing 76% of the population) face high to very high heat risk
  • 400-490 million informal workers possess zero "cooling autonomy"
  • In 2024, India lost 247 billion labour hours and approximately USD 194 billion in income due to extreme heat
  • Urban heat island effect intensifies temperatures in densely built neighbourhoods

Thermal Injustice: The Demographic Divide

Factors Creating Thermal Inequality

  • Poverty and overcrowding in informal settlements
  • Weak infrastructure and inadequate public services
  • Impacts sharply divided along class, caste, and gender lines

Disparity in Cooling Access

Better-off HouseholdsPoorer Households
Air-conditioningLimited fans
Insulated housingShade
Backup powerInadequate public cooling infrastructure
Private transportNo cooling autonomy

Impact on Informal Workers

  • Construction workers: Face radiant heat from steel and concrete
  • Sanitation workers and waste pickers: Handle heated waste materials without protective gear
  • Street vendors: Dual crisis of health deterioration and income loss
  • Gig economy workers: Algorithm-driven pressure to meet delivery timelines during extreme heat

India Cooling Action Plan (ICAP)

Overview

  • Launched in 2019 by Ministry of Environment, Forest and Climate Change (MoEFCC)
  • First country in the world to develop a comprehensive national policy addressing cooling requirements
  • Cooling demand projected to increase eight-fold by 2037-38
  • Provides 20-year perspective (2017-18 to 2037-38)

Core Targets (Baseline: 2017-18)

  • Reduce cooling demand across sectors by 20-25%
  • Reduce energy requirements by 25-40%
  • Reduce refrigerant demand by 25-30%

Kigali Amendment Compliance

Under the Kigali Amendment to the Montreal Protocol, India will phase down Hydrofluorocarbons (HFCs):

  • 10% reduction by 2032
  • 20% reduction by 2037
  • 30% reduction by 2042
  • 85% reduction by 2047

Legal and Policy Gaps

1. Exclusion from Disaster Framework

  • Heatwaves not notified as disaster under Disaster Management Act, 2005
  • States limited by 10% SDRF cap for heat relief
  • No access to National Disaster Response Fund (NDRF)

2. Inadequate Labour Laws

  • Factores Act, 1948: Only protects indoor workers, ignoring outdoor sectors
  • OSHWC Code, 2020: Does not mandate heat safety standards; leaves it discretionary
  • Millions of agricultural and construction workers remain unprotected

3. Weak Heat Action Plans (HAPs)

  • Remain largely advisory rather than enforceable
  • Lack legal backing, dedicated funding, and implementation mechanisms
  • No binding obligations for cooling shelters or public water access

4. Measurement Deficiencies

  • Current classification relies on dry-bulb temperature only
  • Ignores humidity (Heat Index)
  • Coastal areas with high humidity face severe heat stress without official response

Supreme Court Recognition

In M.K. Ranjitsinh & Ors. v. Union of India & Ors (2024), the Supreme Court recognized that protection from adverse effects of climate change is a fundamental right under Article 21.

Recommended Measures

Legislative Reforms

  1. Notify heatwaves as national disaster: Accept 16th Finance Commission's recommendation to include heatwaves and lightning in the Notified National Disaster list for 2026-31
  2. Transition to Heat Index: Combine temperature and relative humidity as primary legal trigger for declaring heatwaves
  3. Enforce binding safety rules: Mandate protected work-rest cycles under Section 23 of OSHWC Code
  4. PPE obligations: Make specialized Personal Protective Equipment a non-negotiable employer requirement

Gig Economy Protection

  • Prohibit delivery time penalties during heat alerts
  • Ensure statutory thermal safety net regardless of contractor status
  • Mandate penalty waivers, hazard pay, and rest periods

Right to Cool

  • Urban Local Bodies must ensure access to cooling shelters
  • Free public water facilities as part of right to life under Article 21

Financial Mechanisms

  • Provisions for income compensation on extreme heat days
  • SEWA's parametric heat insurance scheme as blueprint for innovative models

Heat Index Explained

The heat index is the "feels-like" temperature combining air temperature and relative humidity:

  • High humidity: Reduces sweat evaporation, making body feel hotter than actual temperature
  • Low humidity: Allows faster cooling, making it feel cooler
  • As both temperature and humidity increase, heat index rises, increasing risk of heat-related illnesses

Constitutional and Legal Provisions

  • Article 21: Right to life and personal liberty (Supreme Court expansion to include climate protection)
  • Disaster Management Act, 2005: Current exclusion of heatwaves
  • Factories Act, 1948: Limited to indoor workers
  • OSHWC Code, 2020: Discretionary heat safety provisions
  • Montreal Protocol and Kigali Amendment: HFC phase-down schedule