Allegations: The complainant alleges the systematic violation of freedom of
association rights by the Government, including through repeated acts of anti-union violence
and other forms of retaliation and union busting by factory management. The complainant
organization also alleges the lack of law enforcement
- 95. The Committee last examined this case (submitted in April 2016) at
its June 2025 meeting, when it presented an interim report to the Governing Body [see
411th Report, paras 150–165 approved by the Governing Body at its 354th Session].
- 96. The International Trade Union Confederation (ITUC) submitted
additional allegations in a communication dated 2 October 2025.
- 97. The Government provided its observations in a communication dated 14
November 2025.
- 98. Bangladesh has ratified the Freedom of Association and Protection of
the Right to Organise Convention, 1948 (No. 87), and the Right to Organise and
Collective Bargaining Convention, 1949 (No. 98).
A. The complainant’s allegations
A. The complainant’s allegations- 99. At its June 2025 meeting, the Committee made the following
recommendations [see 411th Report, para. 165]:
- (a) The Committee expects the
Government to step up its efforts in investigating any pending allegations of
physical violence, threats and murder of union leaders and members to avoid impunity
for such serious violations.
- (b) The Committee also requests the Government
to keep it informed of further steps taken in relation to the mentioned initiatives
and their impact on the investigation of anti-union violence and its reduction,
including on the proposed increase of penalties for certain anti-union acts and the
streamlining of legal processes, and trusts that these measures will contribute to
reducing impunity for such acts.
- (c) The Committee further expects the
Government to continue to engage with the social partners concerned in the process
of identifying obstacles impeding full investigation of recurrent acts of anti-union
violence and exploring concrete ways of effectively addressing them, including,
where appropriate, through the establishment of a mechanism to swiftly and
independently investigate such allegations, whether committed by private persons or
state agents.
- (d) The Committee expects the above measures, together with
the interim Government’s commitment to strengthen the labour rights framework, to
effectively result in an increased protection of trade unionists and their rights.
- (e) The Committee requests the Government to keep it informed of progress
made in the ongoing court proceedings concerning the murder of Mr Islam, which it
expects to be expeditious, and to provide the judgment once issued. In light of the
commitment expressed by the Government, the Committee urges the Government to take
any further measures to shed full light on the facts and motives behind the attack
and ensure that the perpetrators and instigators are held accountable and to keep it
informed thereof.
- (f) The Committee draws the Governing Body’s attention to
the serious and urgent nature of this case.
B. The complainant’s additional allegations
B. The complainant’s additional allegations- 100. In its communication dated 2 October 2025, the ITUC alleges that the
proposals to increase penalties and strengthen legal responsibility for anti-union
discrimination were not fully reflected in the negotiations and the proposed amendments
to the Bangladesh Labour Act. In addition, the complainant alleges that no feedback
mechanism exists with the Government to assess the effectiveness of the
awareness-raising training provided to officials.
C. The Government’s reply
C. The Government’s reply- 101. In its communication dated 14 November 2025, the interim Government
indicates that it has embarked on a series of reforms and refers to measures aimed at
increasing penalties and providing for compensation for unfair labour practices and
anti-union discrimination under the amended Bangladesh Labour Act. It further states
that it has been developing a relevant legal and administrative framework to prevent the
recurrence of such cases and refers to the establishment of three Commissions – on
police, judiciary, and women’s affairs.
D. The Committee’s conclusions
D. The Committee’s conclusions- 102. The Committee recalls that this case, which was first examined in
2017, concerns allegations of violation of freedom of association in particular through
acts of violence, including murder, anti-union discrimination and other retaliatory acts
against union leaders and members in numerous enterprises. The Committee notes that the
majority of the additional allegations made by the ITUC in its communication of 2
October 2025 (as well as the response of the Government, insofar as they concern these
allegations) have been addressed in Case No. 3263 [see 413th Report, paras 59–91
approved by the Governing Body at its 356th Session] and that the Government’s
observations are limited to broad indications of legislative and administrative
developments and do not provide further details.
- 103. Regarding its previous recommendations, the Committee regrets to
note that the Government has not provided any further information concerning the
investigation into the murder of Mr Shahidul Islam in June 2023 (further to the
information provided in the Committee’s previous examination of the case that a hearing
against several accused had been held in November 2024). The Committee therefore once
again recalls that it is important that investigations into the murders of trade
unionists should yield concrete results in order to determine reliably the facts, the
motives and the persons responsible, in order to apply the appropriate punishments and
to prevent such incidents recurring in the future. As concerns allegations that legal
proceedings are overly lengthy, the Committee has recalled the importance it attaches to
such proceedings being concluded expeditiously, as justice delayed is justice denied.
The Committee has also drawn attention to the importance that should be attached to the
principle that not only must justice be done, it must also be seen to be done [see
Compilation of decisions of the Committee on Freedom of Association, sixth edition,
2018, paras 96, 169 and 173]. The Committee therefore firmly requests the Government to
step up its efforts to shed full light on the facts and motives surrounding the murder
of Mr Islam, to ensure that both the perpetrators and instigators are held accountable,
and to inform it of the progress made in the ongoing court proceedings, which it expects
to be conducted expeditiously, and to provide a copy of the judgment once issued.
- 104. The Committee further recalls that, in its previous report, the
Government acknowledged the Committee’s concerns regarding persistent obstacles to the
full investigation of recurrent acts of anti-union violence and committed to several
initiatives aimed at reducing such violence or retaliatory measures, namely: (i)
increasing penalties for violence or retaliation against union members; (ii)
streamlining legal processes to ensure the swift identification and punishment of
perpetrators; (iii) undertaking awareness-raising activities for workers and employers;
(iv) implementing training programmes for law enforcement agencies to sensitize them on
freedom of association, trade union rights and the need for unbiased investigations; (v)
establishing Government monitoring committees in the ready-made garment (RMG) sector to
assist with dispute resolution and provide reports on the labour situation; and (vi)
increasing the monitoring of workplaces, particularly in industries with a history of
union-related conflicts. Concerning the Committee’s recommendation that it be kept
informed of the implementation of these measures and their impact, the Committee notes
the Government’s reference to the reform of the Bangladesh Labour Act, to the
development of a relevant legal and administrative framework to prevent the recurrence
of such cases, and to the newly established Commissions on police, judiciary, and
women’s affairs. While it observes the lack of more detailed information in this
respect, the Committee nevertheless takes note of the information submitted by the newly
elected Government to the Governing Body at its 356th Session (March 2026) in the
framework of the follow-up to the complaint pending under article 26 of the ILO
Constitution. In particular, the Committee welcomes the tripartite engagement at the
national level that led to the adoption of the Bangladesh Labour (Amendment) Ordinance,
2025, including strengthened penalties for violations relating to anti union
discrimination and unfair labour practices, and expressly defining the blacklisting of
workers as an unfair labour practice. The Committee further understands, on the basis of
publicly available information, that the Ordinance was endorsed by the Parliament as the
Bangladesh Labour (Amendment) Act on 9 April 2026. In light of the above and recalling
that the Conference Committee on the Application of Standards and the Committee of
Experts on the Application of Conventions and Recommendations (Committee of Experts)
have, for numerous years, been examining the compatibility of national legislation with
the Conventions on freedom of association ratified by Bangladesh, the Committee requests
the Government to provide a copy of the Bangladesh Labour Act, as amended, to the
Committee of Experts, to which it refers this legislative aspect of the case.
- 105. While further noting that the Government has not provided
information concerning the other initiatives referred to in its previous report, the
Committee nevertheless observes that, some relevant information was provided by the
Government in the context of the above-mentioned article 26 complaint, particularly
concerning awareness-raising activities for workers and employers, as well as training
for law enforcement agencies responsible for handling cases of alleged acts of violence
and harassment against workers. While taking note of these measures, the Committee also
notes the complainant’s allegations that no feedback mechanism exists with the
Government to assess the effectiveness of the awareness raising training provided to
officials. In the absence of more comprehensive information, the Committee firmly
requests the Government to provide information on the further steps taken under the
mentioned initiatives and their impact on the investigation of anti-union violence and
its reduction, and expects that these measures will contribute to reducing impunity for
such acts.
- 106. In this respect, the Committee also recalls that the Government had
previously committed to engaging in consultation with trade union representatives and
civil society organizations to better understand the obstacles that may hinder
investigations. With regard to the Committee’s recommendation to continue engaging with
the social partners concerned in the process of identifying obstacles to the
investigation of recurrent acts of anti-union violence and to explore concrete ways of
effectively addressing them, the Committee observes that the Government has not provided
any details in this regard. Recalling the extensive technical assistance provided by the
Office to the Government, the Committee reiterates its expectation that the Government
engage with the social partners concerned in the process of identifying obstacles
impeding the full investigation of recurrent acts of anti-union violence and of
exploring concrete measures of effectively addressing them, including, where
appropriate, the establishment of a mechanism to swiftly and independently investigate
such allegations, whether committed by private persons or state agents.
- 107. Recalling its earlier recommendations concerning persistent
obstacles that impede the full investigation of recurrent acts of anti-union violence,
so as to ensure the identification and punishment of perpetrators of such acts, the
Committee hopes that the recent legislative developments and measures, combined with
ongoing and close consultation with the social partners to address any obstacles in this
respect, and the continued work with the Office, will soon lead to tangible progress in
ensuring accountability for any acts of anti union violence and preventing their
recurrence.
The Committee’s recommendations
The Committee’s recommendations- 108. In the light of its foregoing interim conclusions, the Committee
invites the Governing Body to approve the following recommendations:
- (a) The
Committee firmly requests the Government to step up its efforts to shed full light
on the facts and motives surrounding the murder of Mr Islam, to ensure that both the
perpetrators and instigators are held accountable, and to inform it of the progress
made in the ongoing court proceedings, which it expects to be conducted
expeditiously, and to provide a copy of the judgment once issued.
- (b) The
Committee firmly requests the Government to provide information on the further steps
taken under the mentioned initiatives and their impact on the investigation of
anti-union violence and its reduction, and expects that these measures will
contribute to reducing impunity for such acts. It requests the Government to provide
a copy of the Bangladesh Labour Act, as amended, to the Committee of Experts, to
which it refers this legislative aspect of the case.
- (c) The Committee
reiterates its expectation that the Government engage with the social partners
concerned in the process of identifying obstacles impeding the full investigation of
recurrent acts of anti-union violence and of exploring concrete measures of
effectively addressing them, including, where appropriate, the establishment of a
mechanism to swiftly and independently investigate such allegations, whether
committed by private persons or state agents.
- (d) The Committee draws the
Governing Body’s attention to the serious and urgent nature of this
case.