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The Employment and Labour Relations Act of 2004 and Its Success in Tanzania
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2. THE EMPLOYMENT AND LABOUR RELATIONS ACT OF 2004 AND ITS
SUCCESS IN TANZANIA
BY
ASHERRY MAGALLA
6. v
ABSTRACT
Labour law gives specification of rights, obligations and it regulates and
tells the subjects on how they can conduct themselves on contractual terms
and how they can enforce their rights. In other words, labour law sets a
forum or an institution to enable the effective enforceability of both the
employers’ and employees’ rights. Labour law has Substantive Labour Law
and Procedural Law. Substantive law is that branch of labour law that
prescribes the standards to be observed by both employers and
employees. Specifically, substantive law deals with things like contracts of
service and for services, termination of contract/employment, benefits e.t.c.
These are provided for by the Employment and Labour Relations Act No. 6
of 2004, while Procedural Law is that branch of Labour Law that prescribes
procedures to be followed in all labour matters. This is done by providing
for institutions for implementation of the substantive standards, and
enforcement of rights. This is provided for by the Labour Institutions Act
No.7 of 2004 and the specific rules issued in 2007 GN Nos. 42, 64, 65, 66
and 67 of 2007.
The main objective of labour law is to balancing conflicts of interests as
between employers and employees by defining their rights and duties and
regulating their conducts. And it is from this paper whereby such
equilibrium is shown within the Act or how does the Act has successfully
manage to create such equilibrium.
7. vi
TABLE OF CONTENTS
ASHERRY MAGALLA...................................................................................................... i
COPYRIGHT STATEMENT .............................................................................................ii
DEDICATION..................................................................................................................iii
ACKNOWLEDGEMENT..................................................................................................iv
ABSTRACT ..................................................................................................................... v
TABLE OF CONTENTS ..................................................................................................vi
The Employment and Labour Relations Act of 2004 and its Success in Tanzania.......... 1
1.0 An Introduction .......................................................................................................... 1
1.1 Brief History of Labour Laws ..................................................................................... 2
1.2 Employment and Labour Relations Act, 2004 ........................................................... 6
1.3 The Objects of the Employment and Labour Relations Act, 2004............................. 7
1.4 The Employment and Labour Relations Act 2004 and its success in Tanzania ........ 8
1.4.1 Establishment of the Commission for Mediation and Arbitration (CMA) and the
Labour Court ................................................................................................................... 8
1.4.2 Establishment of the Employment and Labour relations (Code of Good Practice)
Rules, 2007..................................................................................................................... 8
1.4.3 Promotion of the Right to Work .............................................................................. 9
1.4.4 The right to fruit of one’s labour............................................................................ 10
1.4.5 Maintaining Employer’s Obligations ..................................................................... 11
1.4.6 Maintaining Employee’s Obligations..................................................................... 12
1.4.7 Striking the Balance between the Employer’s and Employee’s Rights................. 12
8. vii
1.5 Conclusion .............................................................................................................. 14
Bibliography .................................................................................................................. 16
Text books..................................................................................................................... 16
Statutes......................................................................................................................... 16
Case laws...................................................................................................................... 16
Articles and journals...................................................................................................... 17
International Agreement................................................................................................ 17
Rules............................................................................................................................. 17
Report ........................................................................................................................... 18
9. 1
The Employment and Labour Relations Act of 2004 and its Success in
Tanzania
By
Asherry Magalla
1.0 An Introduction
Labour Law sometimes referred to as Employment law or Industrial Law is
that branch of law which is basically concerned with the various aspects of
master-servant, employer-employee relationship. It defines your rights and
obligations as workers, union members and employers in the workplace.
Labour law gives specification of rights, obligations and it regulates and
tells the subjects on how they can conduct themselves on contractual terms
and how they can enforce their rights. In other words, labour law sets a
forum or an institution to enable the effective enforceability of both the
employers’ and employees’ rights.
An Employee1
is an individual who has entered into a contract of
employment or any other contract where the individual undertakes to work
personally for the other party to the contract, that other party not being a
client or customer of any profession, business or undertaking, furthermore
any individual will be considered an employee if the minister deems him to
be so.2
LL.B Degree Holder at the University of Iringa (Formerly known as Tumaini University Iringa
University College) 2009-2012, Masters Holder in Information, Communication and Technology
Law at the University of Iringa 2012-2013.Article and Legal Papers Author at academicians
websites. Book writer at Lambert Academic Publishing Company in German and DL2A – Buluu
Publishing Company in France. Contact details, magallajr@gmail.com.
1
Section 4 of the Employment and Labour Relations Act, 2004
2
Section 98(3) of the Employment and Labour Relations Act, 2004
Asherry
Magalla
Digitally signed by Asherry Magalla
DN: cn=Asherry Magalla
gn=Asherry Magalla c=Tanzania,
United Republic Of l=TZ
o=Independent Researcher
ou=Independent Researcher
e=magallajr@gmail.com
Reason: I am the author of this
document
Location: Dar Es Salaam-Tanzania
Date: 2018-11-28 16:24+03:00
10. 2
An Employer is also defined by section 4 to mean any person including the
Government and executive agency who employees an employee.3
1.1 Brief History of Labour Laws
The extension of the principle of free trade, which
induces between nations such a competition that the
interest of the workman is liable to be lost sight of and
sacrificed in the fierce international race between
capitalists, demands that such organizations [unions]
should be still further extended and made international.
Karl Marx 4
Labour law arose due to the demands of workers for better conditions, the
right to organize, and the simultaneous demands of employers to restrict
the powers of workers in many organizations and to keep labour costs low.
Employers' costs can increase due to workers organizing to win higher
wages, or by laws imposing costly requirements, such as health and safety
or equal opportunities conditions. Workers' organizations, such as trade
unions, can also transcend purely industrial disputes, and gain political
power - which some employers may oppose. The state of labour law at any
one time is therefore both the product of, and a component of, struggles
between different interests in society.5
Some Asian scholars have identified labour standards as far back as the
Laws of Hammurabi and rules for labour-management relations in the Laws
of Manu; Latin American authors point to the Laws of the
Indies promulgated by Spain in the 17th century for its New World
3
The Employment and Labour Relations Act, 2004
4
Marx, Karl (September 1869). "Report of the General Council to the Fourth Annual
Congress". Basle, Switzerland.
5
https://us.search.yahoo.com/yhs/search?hspart=visicom&hsimp=yhs-
weathernow&p=labour+laws&type=907_TZ_us-retrieved on 18th
August 2017
11. 3
territories. None of these can be regarded as more than anticipations, with
only limited influence on subsequent developments. Labour law as it is
known today is essentially the child of successive industrial
revolutions from the 18th century onward. It became necessary when
customary restraints and the intimacy of employment relationships in
small communities ceased to provide adequate protection against the
abuses incidental to new forms of mining and manufacture on a rapidly
increasing scale at precisely the time when the 18th-century
Enlightenment, the French Revolution, and the political forces that they set
in motion were creating the elements of the modern social conscience. It
developed rather slowly, chiefly in the more industrialized countries of
Western Europe, during the 19th century and attained its present
importance, relative maturity, and worldwide acceptance only during the
20th century.6
The history of labour law concerns the development of labour law as a way
of regulating and improving the life of people at work. In the civilisations of
antiquity, the use of slave labour was widespread. Some of the maladies
associated with unregulated labour were identified by Pliny as " diseases of
slaves."7
In the early phases of development the scope of labour law is often limited
to the most developed and important industries, to undertakings above a
certain size, and to wage earners; as a general rule, these limitations are
gradually eliminated and the scope of the law extended to include
handicrafts, rural industries and agriculture, small undertakings, office
6
Johannes Schregle, C. Wilfred Jenks, Labour Laws accesses at
https://www.britannica.com/topic/labour-law-retrieved on 19th August 2017
7
H. D. Traill, (1896) Social England, v. 602.
12. 4
workers, and, in some countries, public employees. Thus, a body of law
originally intended for the protection of manual workers in industrial
enterprises is gradually transformed into a broader body of legal principles
and standards, which have basically two functions: the protection of the
worker as the weaker party in the employment relationship, and
the regulation of the relations between organized interest groups (industrial
relations).8
A serious outbreak of fever in 1784 in cotton mills near Manchester drew
widespread public opinion against the use of children in dangerous
conditions. A local inquiry presided over by Dr Thomas Percival, was
instituted by the justices of the peace for Lancashire, and the resulting
report recommended the limitation of children's working hours.9
Child labour was not seen as a problem throughout most of history, only
disputed with the beginning of universal schooling and the concepts
of labourers' and children's rights. Use of child labour was commonplace,
often in factories. In England and Scotland in 1788, about two-thirds of
persons working in water-powered textile factories were children.10
A lengthy campaign to limit the working day to ten hours was led by
Shaftesbury, and included support from the Anglican Church. Many
different groups, including many Quakers, workers, and even some factory
owners like John Fielden also supported it.11
Many committees were
formed in support of the cause and some previously established groups
8
Johannes Schregle, C. Wilfred Jenks, Labour Laws accesses at
https://www.britannica.com/topic/labour-law-retrieved on 19th August 2017
9
B. Leigh Hutchins and Amy Harrison (1903), History of Factory Legislation, pp. 5
10
Galbi, Douglas A. (13 June 1994). "Child Labor and the Division of Labor in the Early English
Cotton Mills". Galbi Think!.
11
"The Ten Hours' Bill", The Times (19449), p. 7, 18 January 1847, retrieved 19 August 2017
13. 5
lent their support as well. One of the most influential groups to spring up
was the "Ten Hours' Advocate and the Journal of Literature and Art".12
The
campaign finally led to the passage of the Factory Act of 1847, which
restricted the working hours of women and children in British factories to
effectively 10 hours per day. The debate had been a rather contentious one
in Parliament and was defeated several times by a coalition of
conservatives and free traders.13
The first landmark of modern labour law was the British Health
and Morals of Apprentices Act of 1802, sponsored by the elder Sir Robert
Peel. Similar legislation for the protection of the young was adopted in
Zürich in 1815 and in France in 1841. By 1848 the first legal limitation of
the working hours of adults was adopted by the Landsgemeinde (citizens’
assembly) of the Swiss canton of Glarus. Sickness insurance and
workmen’s compensation were pioneered by Germany in 1883 and 1884,
and compulsory arbitration in industrial disputes was introduced in New
Zealand in the 1890s. The progress of labour legislation outside western
Europe, Australia, and New Zealand was slow until after World War I. The
more industrialized states of the United States began to enact such
legislation toward the end of the 19th century, but the bulk of the present
labour legislation of the United States was not adopted until after the
Depression of the 1930s. There was virtually no labour legislation in Russia
prior to the October Revolution of 1917.14
12
Yale University Library holds full text versions of the Ten Hours' Advocate in its microfilm
department
13
Bloy, Marjorie http://www.historyhome.co.uk/peel/factmine/factory.htm "The Factory Question"
accessed 17 March 2017
14
Johannes Schregle, C. Wilfred Jenks, Labour Laws accesses at
https://www.britannica.com/topic/labour-law-retrieved on 19th August 2017
14. 6
Following World War One, the Treaty of Versailles contained the first
constitution of a new International Labour Organization(ILO) founded on
the principle that "labour is not a commodity", and for the reason that
"peace can be established only if it is based upon social justice".15
ILO's
primary role has been to coordinate international labour law by issuing
Conventions. ILO members can voluntarily adopt and ratify the
Conventions. For instance, the first Hours of Work (Industry) Convention,
1919required a maximum of a 48-hour week, and has been ratified by 52
out of 185 member states.
In Tanzania, the very first trade union of the Tanzania was the Motor
Drivers Union which was formed in the year 1927. In the year 1937, the
Asian workers formed the Asiatic Labor Union which led to the formation of
many unions in Tanzania. These organizations did not have any
involvement in the industrial conflicts. Their main objective was to help their
members. The beginning of the modern labor movement in Tanzania dates
back to 1940s. Five unions were formed by the year 1947 which were
registered by the authorities. The government of the colonies was against
the formation of the unions and had enacted laws to keep the movement
low.16
1.2 Employment and Labour Relations Act, 2004
This Act was passed as law in the parliament on the 14th April 2004 and
assented on the 6th day of June 2004The Act was enacted to make
provisions for core labour rights, to establish basic employment standards,
15
Treaty of Versailles (1919) Part XIII, Section I, and Article 427
16
http://www.historyrocket.com/World-History/history-of-africa/tanzania-history/History-Of-
Labour-Law-In-Tanzania.html-retrieved on 17th August 2017
15. 7
to provide a framework for collective bargaining, to provide for the
prevention and settlement of disputes, and to provide for related matter.17
The Act does not apply to the Tanzania Peoples defence Forces, the Police
Force, the Prisons services or the National services.18
However sections 5,
6 and 7 which deal with prohibition of child labour, forced labour and
discrimination respectively applied to members of forces and services.19
1.3 The Objects of the Employment and Labour Relations Act, 2004
A major concern of Labour Law is basically on;
i. The aspect of labour power, that is to say capacity of a person to work.
ii. Another concern is a relationship between capital and labour.
According to Duddington, J,20
employment law (labour Law) is divided into
two parts;
i. The relationship between employers and those who work for them
(employees or workers). i.e. individual employment law (includes right to
wages, health and safety e.t.c)
ii. The relationship between employers and groups of employees or
workers. He reefers this as collective employment which includes the law
on trade unions, strikes and other industrial actions.21
17
Preamble to the Act
18
Section 2 of the Employment and Labour Relations Act, 2004
19
The Employment and Labour Relations Act, 2004
20
Duddington, J (2007) Employment Law, 2nd Ed p 3
21
Duddington, J (2007), Ibid
16. 8
1.4 The Employment and Labour Relations Act 2004 and its success
in Tanzania
This part provides as to what extent are the objectives of the Employment
and Labour Relations Act, 2004 have been successfully fulfilled in
Tanzania, particularly by looking at what has been established by the Act
itself and the feedback on the accomplishment of what has been
established in reflection of the Act objects.
1.4.1 Establishment of the Commission for Mediation and Arbitration
(CMA) and the Labour Court
The Labour Institutions Act establishes the organs which are responsible to
settle labour disputes while the Employment and Labour Relations Act
provides for the procedure to be used in settling labour disputes. This Act is
enacted to establish the labour institutions and provide for the functions,
powers and duties of institutions, these institutions includes the
Commission for Mediation and Arbitration (CMA) and the Labour Court
which are established by part III and VII of the LIA respectively. Since its
establishment a number of cases have been successfully decided to the
satisfaction of parties, the employer and employee.
1.4.2 Establishment of the Employment and Labour relations (Code of
Good Practice) Rules, 2007
Apart from these principle legislations there are rules that are enacted to
apply with these principle legislations these rules are;
The Employment and Labour relations (Code of Good Practice) Rules,
2007 which came into force by GN no. 42 of 16th February 2007.22
These
22
Employment and Labour relations (Code of Good Practice) Rules, GN no. 42)
17. 9
rules are made under s 99(1) of ELRA.23
These rules to provide for
standard of conduct of both the employers the employees and the
organizations, mediators, arbitrators, judges, assessors and government
officials.
1.4.3 Promotion of the Right to Work
The right to work may imply among other things, the right to demand for
better and fair wages, the right to withhold labour by use of strikes and
other means. Article 22 of The Constitution24
provides for the right to work.
This right is absolute. This right goes hand in hand with the right of every
citizen to be afforded equal opportunity and with equal condition to occupy
any position in the service of the United Republic.25
To the larger extent the right to work is aligned with the very survival of an
individual and the society in whole. It is said to be closely related to the
right to life t hat being the case the right to work requires legal protection.26
Lord Denning M.R (as he then was) in the case of Lee v Showmen’s Guild
of Great Britain27
was of the view that ’’a man’s right to work is just as
important to him as if not more important than his rights of property. The
courts intervene everyday to protect rights of property. They must also
intervene to protect the right to work
Mwalusanya, J, in Augustine Masatu v Mwanza Textiles Ltd28
had a view
that for work to be sustained, it requires that opportunities to be set open so
23
Section 99 (1) of the Employment and Labour Relations Act, 2004
24
The Constitution of the United Republic of Tanzania of 1977 as amended from time to time
25
CP Maina (1997), Human Rights in Tanzania: selected cases and material, p 170
26
CP Maina (1997), Human Rights in Tanzania: selected cases and material, p 169
27
[1952] 2 Q.B. 329
28
H.C at Mwanza, Civil case No. 3 of 1986 (Unreported)
18. 10
that members of the society can strive their material necessities of life. In
his own words he stated inter alia that
‘’for this right to exist in a real sense, it is necessary that economic,
political and legal order of the society assure everybody who is capable of
working of the possibility of participating in building his society through work
in accordance with his capacity and education and the right to earn an
income proportion to the quantum of his work. And so job security is the
hall-mark of the whole system’’
The right to work is the product of a long term and historic struggle of the
working class against capital and exploitation of labour.
1.4.4 The right to fruit of one’s labour
Article 23 of the constitution29
provides that every person is entitled to
remuneration commensurate with his work without any kind of
discrimination. This remuneration will take into consideration the ability of
the person working and the nature of work done. These remunerations
must be just.
It is said that labour is one of the most treasured assets that human beings
have Labour does not only guarantee generation of wealth but also
guarantees the very survival of human beings, therefore its protection is a
crucial matter. Hence labour laws should be able to cutter for these
constitutional provisions by providing provisions that protect and profess
the right to work in which the current Act30
have provide for that as one
among the object to keep employers and employees relationships in good
terms, fair and just.
29
The Constitution of the United Republic of Tanzania of 1977 as amended from time to time
30
The Employment and Labour Relations Act, 2004
19. 11
1.4.5 Maintaining Employer’s Obligations
The employer has obligation to provide work or assignments to employee.
If an employee fails to provide work to employee he will still have to pay the
wages to him for the whole time he failed to provide work. The Act provided
for this. It provided inter alia that, this obligation will be maintained unless
the employee has broken his contract or there is an Act of God. In the case
of Mathew Leonard Kato v National Poultry Co. Ltd,31
the court issued a
declaratory judgment to the effect that the appellant was in continuous
employment all the time of his termination Mackaja j stated that, ‘so long as
payment of wages is one of the express terms of the contract of
employment, the employee fulfils his part of the bargain by placing himself
under the control of his employer who at once is required to assign him
work. Whether or not work is assigned, the employee becomes entitled to
his wages’’.
According to Sikalumba, A.J a rule of practice suggest that an employee
has a duty to obey his employer’s lawful orders and the employer has to
reciprocate that by treating the employee with respect, high level of
confidence and trust .
In the case of Kihanira Kilunge Kibaya v UnitedAfrica Company of
Tanzania Ltd32
the appellant complained that his supervisors victimised him
when they served him a notice of termination of contract. He was not
promoted instead his juniors were promoted and his supervisor assigned
his tasks to unskilled juniors to spoil his reputation, because the basis of his
31
Civil Case No. 122 of 1990 (Unreported) H.C
32
Civil Appeal no 36 of 1987 (Unreported
20. 12
termination was that he performed poorly. The court was of the view that
public policy in this country prohibits victimization in employment.
1.4.6 Maintaining Employee’s Obligations
The employee is duty bound to obey all lawful and reasonable orders and
instructions concerning his work from his employer. Failure to abide to this
duty may result to disciplinary actions against the employer either by
established code of conducts by the employer or by general disciplinary
actions as established by labour laws.
If there is misconduct or, where employee disobeys lawful orders. This is
defined as termination of contract of employment without notice. It is a
disciplinary measure taken by the employer. (See Kitundu Sisal estate v
Shingo Mshuti & others)33
1.4.7 Striking the Balance between the Employer’s and Employee’s
Rights
This is the main objective of the Act that there must be a balance between
the employee and employer in regarding to contractual agreement. In
contractual bargaining, if there was no law regulating such bargaining, the
employer definitely would be in bargaining power as to what the employee
has to do, also how much would that employee being paid. Thus, the law
despite of the power the employer has, still such employer must adhere to
the regulations therein. The law may also used to defend the employer in
regarding to any agreement created within the employment contract. For
instance, in the case of Joseph M. Mutashobya V. Mis Kibo Match
33
[1970] E.A 557
21. 13
Group Limited,34
the main issues were;
i. Whether Employer may terminate it before expiry of the specified
period
ii. Whether employer may decide to terminate it without givingreasons
Article 13(6) of the Constitution.
iii. Whether termination of employment by employer is violative of the
employee’s constitutional right to work - Article 22(1) of the
Constitution.
In this case;
The appellant was employed by the respondent for a specific period of
three years subject to renewal upon mutual agreement. This was made in
writing, which had clause 13(b) of the contract provided for early
termination of the employment. The respondent unilaterally terminated the
employment without assigning any reasons. Aggrieved, the appellant
instituted a suit in the High Court, claiming TZS.38 703 862 for wrongful
termination of the agreement by the respondent. The High Court dismissed
the suit, hence this appeal.
It was held that;
(i) The open words of clause 13 of the Employment Agreement clearly gave
right to the respondent to prematurely terminate the agreement without
giving reasons for the decision;
(ii) Judicial observation that reasons must be given whenever anybody acts
or decides any matter is not of general application but is limited to public
authorities.
Appeal dismissed
34
Civil Appeal No. 53 Of 2001 [2004] T.L.R
22. 14
1.5 Conclusion
Despite of having a number of successful, the Act also have some
challenges in some of its provisions which in one way or another may
distort the main objective of labour law regarding to the equilibrium
between the rights of employees and employers.
As discussed by Jaba Shadrack that;
The new law provides no grounds for employees to embark on a conflict of
rights.
(ii) Gives workers the right to strike on disputes of interests on the one
hand, and indirectly denies it on the other. For example, Section 75 of the
Act gives employees the right to strike but the right should be in line with
limitations stated thereto. This is due to the facts that, Workers strike for a
variety of reasons, but the mostly for economic reasons such as poor
remuneration, poor working tools, an unfavourable working environment,
lack of motivation and dissatisfaction. Section 80 stipulates that before
engaging in a strike, workers should ensure that the dispute is of interest
and that the dispute has gone through mediation and remains unresolved
after mediation. The law also calls for a trade union to approve the strike
through a ballot conducted under union constitutions. The prevailing legal
discrepancy is costly to the employees especially when engaging in
disputes, because failure to meet the conditions necessary to the strike
might be taken to mean violation of laws, therefore civil or criminal
proceeding might be taken against them. Generally, the ELRA allows the
right to strike on the one hand, and indirectly takes away the right by
imposing strict conditions, which workers must follow before they strike.
23. 15
(iii) The Act does not define a contract of service and a contract for service.
[The Labour Institutions Act, 2004 under Section 61 provide for a
presumptions as to who may be deemed as an employee].
(iv) The ELRA is silent as to what happens to the employees' rights where
the employer is insolvent.35
35
Jaba Shadrack, Labour Law In Tanzania accessed at
http://jabashadrack.blogspot.com/2009/01/labour-law-in-tanzania.html-retrieved on 19th August
2017
24. 16
Bibliography
Text books
B. Leigh Hutchins and Amy Harrison (1903), History of Factory
Legislation, p
CP Maina (1997), Human Rights in Tanzania: selected cases and material
Duddington, J (2007) Employment Law, 2nd Ed p
H. D. Traill, (1896) Social England, v. 602.
Sikalumba, A.J, (2003), legal aspects of Employment contracts and Dispute
settlement schemes in Tanzania
Statutes
The Constitution of the United Republic of Tanzania of 1977
Employment and Labour Relations Act, 2004
Law of Contract Act, [Cap.345, R.E. 2002]
Case laws
Augustine Masatu v Mwanza Textiles Ltd H.C at Mwanza, Civil case No. 3
of 1986 (Unreported)
Janet Lesilwa v Tausi Swalehe. [1983] TLR 14
Joseph M. Mutashobya V. Mis Kibo Match Group Limited, Civil Appeal No.
53 Of 2001 [2004] T.L.R
Kihanira Kilunge Kibaya v UnitedAfrica Company of Tanzania Ltd Civil
Appeal no 36 of 1987 (Unreported)
Kitundu Sisal estate v Shingo Mshuti & others [1970] E.A 557
Laws v London Chronicle, [1959] 2 ALL ER 285 at 287
Lee v Showmen’s Guild of Great Britain [1952] 2 Q.B. 329
25. 17
Mathew Leonard Kato v National Poultry Co. Ltd, Civil Case No. 122 of
1990 (Unreported) H.C
Mathias Kanondo v TANU Regional Secretary [1976] LRT 34.
Shaban H. Msengesi v National Milling Corporation H.C, Civil Appeal No.
44 of 1994
Articles and journals
Bloy, Marjorie http://www.historyhome.co.uk/peel/factmine/factory.htm "The
Factory Question"
Galbi, Douglas A. (13 June 1994). "Child Labor and the Division of Labor in
the Early English Cotton Mills". Galbi Think!.
Jaba Shadrack, Labour Law In Tanzania accessed at
http://jabashadrack.blogspot.com/2009/01/labour-law-in-tanzania.html
http://www.historyrocket.com/World-History/history-of-africa/tanzania-
history/History-Of-Labour-Law-In-Tanzania.html
Johannes Schregle, C. Wilfred Jenks, Labour Laws accesses at
https://www.britannica.com/topic/labour-law
"The Ten Hours' Bill", The Times (19449), p. 7, 18 January 1847,
retrieved 19 August 2017
International Agreement
Treaty of Versailles (1919)
Rules
Employment and Labour relations (Code of Good Practice) Rules, GN no.
42)
26. 18
Report
Marx, Karl (September 1869). "Report of the General Council to the Fourth
Annual Congress". Basle, Switzerland.
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