LITERATURE REVIEW

Introduction:

Definition of gig workers as per ILO and identification of two broad components under it. Focus
on app-based delivery agents.

 ILO Report on ‘Non-Standard employment’ 1

https://www.ilo.org/global/topics/non-standard-employment/crowd-work/lang--en/
index.htm : ILO defines gig economy into two parts: firstly, web-based workers that
are scattered across locations and work through website like freelancing and
secondly, platform-based workers that are locationally connected through the
platforms and asked to provide physical services like delivery, house cleaning etc.

 Gig economy data hub, ‘What is Gig economy’2

https://www.gigeconomydata.org/basics/what-gig-worker:
The article looks at various approaches of defining gig workers and classifying them.
The article has defined gig workers based on three approaches namely, work
arrangement, legal classification and nature of work. In the work arrangement
approach, the contract or the relationship between the workers and the individual or
company who pays them is looked at to determine the type of worker. In the legal
classification approach, the distinction between employees and independent
contractors is gauged. In the nature of work approach, what the people actually do is
looked at to classify them.

1
Digital Labour Platforms (International Labour Organisation) <https://www.ilo.org/global/topics/non-standard-
employment/crowd-work/lang--en/index.htm> accessed on 26th February, 2024
2
What is a gig worker? (Gig Economy Data Hub) <https://www.gigeconomydata.org/basics/what-gig-worker>
accessed on 26th February, 2024
  Looking at the Gig Picture: Defining Gig Work and Explaining Profile Differences in
Gig Workers’ Job Demands and Resources3
https://journals.sagepub.com/doi/abs/10.1177/1059601121996548:
The article identifies the definition of gig work by identifying its primary and
secondary characteristics and distinguishing it from other types of nonstandard work.
The article categorized the identified characteristics of gig workers into primary (i.e.,
characteristics common to all gig workers) and secondary (i.e., characteristics shared
by certain groups of gig workers).

 The Wire, ‘COVID-19 and Employment: Why the Definition of Gig Workers Matters
More Than You Think’4
https://thewire.in/tech/covid-19-employment-gig-workers: This article highlighted the
importance of having a clear definition of ‘gig workers.’ With the platformization of
more and more services in the country, there exists a real need for the definition of
gig workers to be taken seriously as the number of jobs continue to dwindle in the
formal economy in India. The lack of definition leads to confusion in regards to what
gig workers can avail as protections, minimum wages etc. Therefore, it highlights the
necessity of a clear definition of the term ‘gig worker’ in the Indian legal labor
market.

 ‘TAKEN FOR A RIDE: LITIGATING THE DIGITAL PLATFORM MODEL’, Report

by International Lawyers Assisting Network5
https://www.ilawnetwork.com/wp-content/uploads/2021/03/Issue-Brief-TAKEN-
FOR-A-RIDE-English.pdf : Issue brief by International Lawyers assisting workers
3
Watson, G. P., Kistler, L. D., Graham, B. A., & Sinclair, R. R., Looking at the Gig Picture: Defining Gig Work and
Explaining Profile Differences in Gig Workers’ Job Demands and Resources. (2021)
<https://doi.org/10.1177/1059601121996548> accessed on 26th February, 2024
4
Bhavani Seetharaman, COVID-19 and Employment: Why the Definition of Gig Workers Matters More Than You
Think (The Wire, 17th September, 2020) <https://thewire.in/tech/covid-19-employment-gig-workers> accessed on
26th February, 2024
5
Taken for a Ride: Litigating the Digital Platform Model (International Lawyers Assisting Network, March 2021) <
https://www.ilawnetwork.com/wp-content/uploads/2021/03/Issue-Brief-TAKEN-FOR-A-RIDE-English.pdf>
accessed on 26th February, 2024
 network explains the various strategies that corporations undertake to avoid any kind
of obligation against the delivery partners ranging from treating them as independent
contractors to mandatory arbitration clauses.

 NITI Ayog Final Report 2020 on ‘India’s booming gig and platform economy’6.
https://www.niti.gov.in/sites/default/files/2022-
06/25th_June_Final_Report_27062022.pdf : The NITI Ayog report entails a study on
the rapidly burgeoning gig workforce that is ushering in a new economic revolution
globally. India – with its demographic dividend of half-a-billion labour force and the
world’s youngest population, rapid urbanisation, widespread adoption of smartphones
and associated technology – is the new frontier of this revolution. The gig economy
has proven its resilience and potential even in the wake of the Covid-19 pandemic, by
continuing to unlock jobs in the millions and keeping communities connected.
The report gives out detailed statistics of the demography engaged in the gig
economy and platform economy in India. It is estimated that there were 68 lakh (6.8
million) gig workers in 2019-20, using both principal and subsidiary status, forming
2.4% of the non-farm workforce or 1.3% of the total workers in India. It is estimated
that in 2020-21, 77 lakh (7.7 million) workers were engaged in the gig economy.
They constituted 2.6% of the nonagricultural workforce or 1.5% of the total
workforce in India.

 ‘OECD Economics Department Working Papers’ 7

https://www.oecd-ilibrary.org/economics/gig-economy-platforms-boon-or-
bane_fdb0570b-en;jsessionid=ynyf4hu-Gh0UosU85V4acT2wJMxltTa-WlRpfaSh.ip-
6
India’s booming gig and platform economy: Perspectives and Recommendations on the Future of Work, (NITI
Ayog Final Report, 2020) < https://www.niti.gov.in/sites/default/files/2022-
06/25th_June_Final_Report_27062022.pdf> accessed on 26th February, 2024
7
Cyrille Schwellnus, Assaf Geva, Mathilde Pak and Rafael Veiel, Gig economy platforms: Boon or Bane?, (OECD
Economics Department Working Papers, No. 1550, OECD Publishing, Paris)< https://doi.org/10.1787/fdb0570b-
en> accessed on 26th February, 2024
 10-240-5-71 : This paper takes stock of the emerging evidence. The results suggest
that gig economy platforms’ size remains modest (1-3 percent of overall
employment). Their growth has been most pronounced in a small number of services
industries with high shares of own-account workers, suggesting that thus far they
have been a substitute for traditional self-employment rather than dependent
employment. New evidence provided in this paper is consistent with positive effects
of platform growth on overall employment and small negative or insignificant effects
on dependent employment and wages. While most empirical studies suggest that
platforms are more efficient in matching workers to clients, reductions in barriers to
work could offset such productivity-enhancing effects by creating employment
opportunities for low-productivity workers.

Extant discontent amongst the delivery partners:

Demand for rights by these workers.

 Strike By Zomato ‘Partners’ Wins No Concessions But Brings A Benefit Unfamiliar

To India’s Gig Workers, Article 14 8
https://article-14.com/post/strike-by-zomato-partners-wins-no-concessions-but-
brings-a-benefit-unfamiliar-to-india-s-gig-workers-62903ab0f1d5b : demand by
Zomato workers for according labour rights to them. This article showcased the
growing discontent and resentment towards the food delivery platform ‘Zomato.’
According to workers, the new system reduced the flexibility they previously enjoyed
in terms of when and how many deliveries they wished to do in a day, while also
shrinking their earnings per delivery. While protesting, the workers came to the

8
Alisha Dutta, Strike By Zomato ‘Partners’ Wins No Concessions But Brings A Benefit Unfamiliar To India’s Gig
Workers (Article 14, 27th May, 2022) < https://article-14.com/post/strike-by-zomato-partners-wins-no-concessions-
but-brings-a-benefit-unfamiliar-to-india-s-gig-workers-62903ab0f1d5b> accessed on 26th February, 2024
 realization that they had no union whose support they could seek. Although the strike
failed, it taught them the power of unity.

 Report by Digital Foundation on ‘FOOD DELIVERY WORKERS IN INDIA:

EMERGING ENTREPRENEURS OR INFORMAL LABOUR?’9
https://defindia.org/wp-content/uploads/2021/04/swiggy-zomato-delivery-workers-
india-entrepreneurs-labour.pdf :
This study brings attention to the fact that food delivery platforms term their delivery
partners as ‘independent contractors’ and not as traditional ‘employees’ which results
in these workers not getting the benefit from labor rights relating to pay, working
hours, working conditions and collective bargaining rights. It also highlighted the
lack of initiative by the government to gather data on the number of gig workers.

Identity issues/ quest for identity:

Currently, they are identified as ‘independent contractors’ due to the form of standard for
contracts- power imbalance in this.

Identity quagmire because- 1) existing definition of employees erroneously refused to include

them, 2) definition by code of social security

 ILO working paper 106, 2023, by the title- ‘Are platform workers willing to
unionize? Exploring survey evidence from 14 European countries’10
9
Asheef Iqubbal, Food Delivery Workers in India: Emerging Entrepreneurs or Informal Labour? (Digital
Empowerment Foundation, April, 2021) < https://defindia.org/wp-content/uploads/2021/04/swiggy-zomato-
delivery-workers-india-entrepreneurs-labour.pdf> accessed on 26th February, 2024
10
Kurt Vandaele, Agnieszka Piasna, Wouter Zwysen, Are platform workers willing to unionize? Exploring survey
evidence from 14 European countries (International Labour Organisation, February, 2024) <
 https://www.ilo.org/wcmsp5/groups/public/---ed_dialogue/---actrav/documents/
publication/wcms_910689.pdf : As per ILO’s working paper titled “Are platform
workers willing to unionize? Exploring survey evidence from 14 European countries”
this contractor status acts as a hurdle for these delivery partners in collective
bargaining on wages and working conditions.

 Code of Social Security 2020 11

https://labour.gov.in/sites/default/files/ss_code_as_introduced_in_lok_sabha.pdf :
Code of social security 2020, definition of platform workers and gig workers

 Lexology, ‘Platform Workers - Direct Employees or Contractors?12

https://www.lexology.com/library/detail.aspx?g=33f5ec27-3c81-4609-b3c3-
4cad7c760a50 : social security code identifying platform workers outside ‘employee-
employer’ relationship and the impact of this.

 Vidhi Legal Policy paper on ‘Background note on Platform economy’13

https://vidhilegalpolicy.in/wp-content/uploads/2023/08/Vidhi-website_Background-
note_Platform-economy-roundtable.pdf : This report begs the question of how
inclusive the existing laws truly are when it comes to tying together several aspects
affecting platform workers across various sectors. Furthermore, it analyze how the
lack of ‘employee’ status to gig workers renders them unable to form unions to best
represent their collective concerns.
https://www.ilo.org/wcmsp5/groups/public/---ed_dialogue/---actrav/documents/publication/wcms_910689.pdf>
accessed on 26th February, 2024
11
The Code on Social Security, 2020
12
Ayesha Barucha, Platform Workers - Direct Employees or Contractors? (Lexology, 27th December, 2021) <
https://www.lexology.com/library/detail.aspx?g=33f5ec27-3c81-4609-b3c3-4cad7c760a50> accessed on 26th
February, 2024
13
Background note on Platform economy, (VIDHI Centre for Legal Policy) < https://vidhilegalpolicy.in/wp-
content/uploads/2023/08/Vidhi-website_Background-note_Platform-economy-roundtable.pdf> accessed on 26th
February, 2024
  https://english.elpais.com/economy_and_business/2020-09-24/spanish-supreme-
14
court-rules-food-delivery-riders-are-employees.html?rel=listapoyo : Indian Labour
laws can take lessons from different jurisdictions where the nations courts and its
laws consider instant delivery partners as the employees of that particular delivery
company. For instance, Spain's supreme court in one of the cases held that food-
delivery riders are employees, not self-employed workers.

 https://english.elpais.com/economy_and_business/2021-05-12/spain-approves-
landmark-law-recognizing-food-delivery-riders-as-employees.html :- In the aftermath
of Spain’s Supreme Court decision, Spain passed a legislation which recognized
food-delivery riders from digital platforms, such as Glovo and Just Eat, as employees
and not self-employed workers.

What impact does this have?

Impact of the above factors on 3/5 components of labour rights: collectivisation, occupational
safety (working conditions) and social security.

Unionization:

 ILO working paper on ‘Are platform workers willing to unionize? Exploring survey
evidence from 14 European countries’15

14
Manuel V. Gomez, Spanish Supreme Court rules food-delivery riders are employees, not self-employed (El Pais,
24th September, 2020) < https://english.elpais.com/economy_and_business/2020-09-24/spanish-supreme-court-
rules-food-delivery-riders-are-employees.html?rel=listapoyo> accessed on 26th February, 2024
15
Kurt Vandaele, Agnieszka Piasna, Wouter Zwysen, Are platform workers willing to unionize? Exploring survey
evidence from 14 European countries (International Labour Organisation, February, 2024) <
https://www.ilo.org/wcmsp5/groups/public/---ed_dialogue/---actrav/documents/publication/wcms_910689.pdf>
accessed on 26th February, 2024
 https://www.ilo.org/wcmsp5/groups/public/---ed_dialogue/---actrav/documents/
publication/wcms_910689.pdf :
ILO's working paper titled “Are platform workers willing to unionize? Exploring survey
evidence from 14 European countries” explains how algorithmic management suppresses
worker’s voice and how gamification, that is the reliance on client rating systems and
independent contractor status creates an “entrepreneurial orientation” among platform
workers and stimulates between-worker competition. This in turn hampers workers’
collective identity, solidarity and their openness to unionization.

 Indian Express article on ‘Swiggy delivery partners protest in Ahmedabad’16

https://indianexpress.com/article/cities/ahmedabad/swiggy-delivery-partners-protest-in-
ahmedabad-8828604/ :- Last year has seen a shift in this approach as there have been
various protests by the delivery partners to put an end to what they consider as
‘exploitation’ out of their various demands including a standardized pay structure.

Working conditions (including health and safety):

 News article published in Economic times 17

https://economictimes.indiatimes.com/tech/startups/blinkit-delivery-workers-protest-in-
delhi-ncr-over-changes-in-pay-structure/articleshow/99439758.cms?from=mdr and

 New article published in India Today18

16
Rijit Bannerjee, Swiggy delivery partners protest in Ahmedabad (Indian Express, 12th July, 2023) <
https://indianexpress.com/article/cities/ahmedabad/swiggy-delivery-partners-protest-in-ahmedabad-8828604/>
accessed on 26th February, 2024

17
Blinkit delivery workers protest in Delhi-NCR over changes in pay structure, (The Economic Times, 12 th April,
2023) < https://economictimes.indiatimes.com/tech/startups/blinkit-delivery-workers-protest-in-delhi-ncr-over-
changes-in-pay-structure/articleshow/99439758.cms?from=mdr> accessed on 26th February, 2024

18
Blinkit 'temporarily unavailable' after delivery partners protest change in pay structure, (INDIA TODAY, 15 th
April, 2023) < https://www.indiatoday.in/india/story/blinkit-delivery-partners-strike-change-in-pay-structure-
 https://www.indiatoday.in/india/story/blinkit-delivery-partners-strike-change-in-pay-
structure-2360315-2023-04-15 : As the delivery partners don’t have any say in the
decision taken by management due to which there has been arbitrary reduction in their
pay structure and due to which last year a lot of protests from the side of the delivery
partners as their pay was reduced from Rs 25 to 15.

 News article published in Hindustan Times 19

https://www.hindustantimes.com/business/unhappy-with-revised-pay-structure-over-1-
000-blinkit-delivery-executives-join-rival-firms-report-101682320745667.html : This
article shows that in response to the decision of lowering the pay of the delivery partners
by blinkit around 1000 blinkit delivery partners joined rival firms.

 ‘India’s Gig Workers: The death of a food delivery boy reveals obstacles in health-care
benefits’ published by Think Global Health20
https://www.thinkglobalhealth.org/article/indias-gig-workers#:~:text=Throughout
%202022%2C%20the%20Indian%20media,agony%20and%20loss%20of%20earnings :
This article shows how the zomato and swiggy delivery partners are assaulted and
threatened. In such instances as well as in cases of road accidents and danger to the safety
of these partners, the platform promises to extend some benefits to them, however the
same has never reached the victims.
In light of this, the current legislations by the government conveniently refuses to cover
platform workers under their ambit, leading all the hopes for legislative/ legal assistance
to vain.

2360315-2023-04-15> accessed on 26th February, 2024

19
Unhappy’ with revised pay structure, over 1,000 Blinkit delivery executives join rival firms: Report, (Hindustan
Times, 24th April, 2023) < https://www.hindustantimes.com/business/unhappy-with-revised-pay-structure-over-1-
000-blinkit-delivery-executives-join-rival-firms-report-101682320745667.html> accessed on 26th February, 2024
20
Shefali Malhotra, India’s Gig Workers: The death of Food Delivery Boy reveals obstacles in health care benefits,
(Think Global Health, 22nd February, 2023) < https://www.thinkglobalhealth.org/article/indias-gig-
workers#:~:text=Throughout%202022%2C%20the%20Indian%20media,agony%20and%20loss%20of
%20earnings> accessed on 26th February, 2024
  Outlook article ‘Harassment, Discrimination, Extra Burden: Women In Gig Economy’21
https://www.outlookindia.com/national/harassment-discrimination-extra-burden-women-
in-gig-economy-news-286360 :
This article tries to analyse the problems suffered by women in platform economy. With
more women joining the gig workforce, they continue to be paid less than their male
counterparts for the same jobs. According to TeamLease, there is an eight to 10 per cent
salary disparity between male and female delivery executives, ranging between Rs
15,000 and Rs 30,000 per month. As much as 60% of the jobs are in food tech, 30% in e-
commerce and courier services and 10% in hyperlocal delivery, it said.
Other than pay disparity, despite women’s increasing participation in the gig economy,
gender-based discrimination, unruly customers, abrupt change in company policies, job
insecurity and safety issues remain a growing and unresolved concern for women.

 Gender and the Gig Economy: A qualitative study of Gig platforms for women workers-
published by Observer Research Foundation 22
https://www.orfonline.org/research/gender-and-the-gig-economy-a-qualitative-study-of-
gig-platforms-for-women-workers-65948/#_edn9 : This study highlights another issue of
core relevance to the sector: an inability to facilitate women’s movement into the
workforce. Infact, India has observed a slow decline of female labour participation from
the workforce for more than two decades now. It has decreased from 30.2% in 1990 to
20.8% in 2019. The ORF study discovers that gig platforms have no specific policies that
make women’s inclusion in gig work easier. Additionally, there is no mechanism to
safely dispute redressal without the threat of loss of income. There is also no legislation
that governs these digital platforms.

21
Harassment, Discrimination, Extra Burden: Women In Gig Economy (Outlook, 15th May, 2023) <
https://www.outlookindia.com/national/harassment-discrimination-extra-burden-women-in-gig-economy-news-
286360> accessed on 26th February, 2024

22
Ria Kasliwal, Gender and the Gig Economy: A qualitative study of Gig platforms for women workers, (Observer
Research Foundation, 24th May, 2023) < https://www.orfonline.org/research/gender-and-the-gig-economy-a-
qualitative-study-of-gig-platforms-for-women-workers-65948#_edn9> accessed on 26th February, 2024
Social Security:

 Indian Federation of App-Based Transport Workers v. Union of India and Others 23: In
this case, platform workers sought some security benefits to be declared for them.

 Journal Article on ‘UNDERSTANDING SOCIAL SECURITY FOR GIG WORKERS:

ANALYZING RECENT DEVELOPMENTS’24
https://nliulawreview.nliu.ac.in/wp-content/uploads/2022/02/3.-Understanding-Social-
Security-for-Gig-Workers.pdf : In this article, the author highlights the impact on the
social security benefits of platform workers, especially in light of the new definition
accorded to them by Code of Social Security 2020. As per the definition, these workers
are ‘outside of the traditional employee-employer relationship’. This means that these
workers become ineligible for several existing legislations ensuring social security. These
include- the Employee State Insurance Act that primarily provides benefits to employees
in case of sickness, maternity and employment injuries, linking the provision of social
security benefits to an individual‟s status as an “employee”. The Employees‟
Compensation Act, is yet another significant legislation which provides compensation for
employment-related injuries, as well as occupational diseases. The Payment of Gratuity
Act, 1972, which provides for payment of gratuity upon cessation of employment to
employees completing “continuous service”, again provides social security benefits, to
individuals who are “employees”.
Even for certain government benefits, the coverage of social security benefits for
platform workers is restricted.

23
Indian Federation of App-Based Transport Workers v. Union of India and Ors, Writ Petition(s)(Civil)
No(s).1068/2021
24
Ulka Bhattacharyya* & Soumya Jha, Understanding Social Security for Gig Workers: Analyzing recent
developments, (NLIU Law Review, Vol XI, Issue I)
  Rajiv Gandhi Shramik Kalyan Yojana (“RGSKY”) 25
https://www.esiwb.gov.in/main/home/rgsky_allowance#:~:text=Under%20the
%20Scheme%2C%20an%20Insured,maximum%20period%20of%20two%20years : The
Rajiv Gandhi Shramik Kalyan Yojana (“RGSKY”) was introduced in 2005. The scheme
provides for unemployment allowance payments for loss of employment in specified
situations. The RGSKY does not cover individuals who are not employed, hence, its
application to gig workers who are outside the confines of the traditional employment
relationship does not arise

 Atal Beemit Vyakti Kalyan Yojana (“ABVKY”) 26

https://pib.gov.in/PressReleasePage.aspx?PRID=1849796#:~:text=Atal%20Beemit
%20Vyakti%20Kalyan%20Yojana%20(ABVKY)%20is%20a%20welfare
%20measure,'%20(IPs')%20unemployment : Atal Beemit Vyakti Kalyan Yojana
(“ABVKY”) provides unemployment benefits as cash compensation to unemployed
persons. The ABVKY targets employees already covered under Section 2(9) of the ESI
Act. Introduced in July 2018 for an initial period of two years, the ABVKY was initially
extended till June 2021; subsequently, it was extended till June 2022. However, the
ABVKY again ultimately applies to insured persons in „insurable employments‟;
therefore, its applicability to gig workers is moot.

Need for acknowledgement of the status:

Two solutions: 1) Reinterpretation of platform workers as per the employee-employer tests laid
down until now; 2) Hybrid model
25
Rajiv Gandhi Shramik Kalyan Yojana, <https://www.esiwb.gov.in/main/home/rgsky_allowance#:~:text=Under
%20the%20Scheme%2C%20an%20Insured,maximum%20period%20of%20two%20years> accessed on 26th
February, 2024
26
Atal Beemit Vyakti Kalyan Yojana, (PIB, Ministry of Labour and Employment, 8th August, 2022) <
https://pib.gov.in/PressReleasePage.aspx?PRID=1849796#:~:text=Atal%20Beemit%20Vyakti%20Kalyan
%20Yojana%20(ABVKY)%20is%20a%20welfare%20measure,'%20(IPs')%20unemployment>
  Article published in Times of India27

https://timesofindia.indiatimes.com/blogs/voices/social-security-for-gig-workers-a-joint-
responsibility/ : reflects the need to strengthen the ambit of social security for gig workers.
The Code on Social Security, 2020 (Code) which has been enacted but not yet effective, will
legally recognise the relationship by introducing and defining a gig-worker as “a person who
performs work or participates in a work arrangement and earns from such activities outside
of traditional employer-employee relationship.” Until the code comes into force, gig workers
are dependent on contractual benefits offered by individual platform employers.

 Report published by Norton Fulbright, ‘Doing business in the gig economy: A global
guide for employers’28
https://www.nortonrosefulbright.com/en-fr/knowledge/publications/87afaec5/doing-
business-in-the-gig-economy-a-global-guide-for-employers#:~:text=In%20France%2C
%20the%20business%20model,often%20gives%20rise%20to%20disputes : inspiration of
hybrid-model has been taken from the Canadian system. This article undertakes a
comparative analysis of the legal status of gig workers across jurisdictions.

 Indicorp blog by the title, ‘Labour Law and the Gig Economy: Towards a Hybrid Model
of Employment’29

27
Vikram Shroff, Social security for gig workers – a joint responsibility? (The Times of India, 10th June, 2023) <
https://timesofindia.indiatimes.com/blogs/voices/social-security-for-gig-workers-a-joint-responsibility/> accessed on
26th February, 2024

28
Doing business in the gig economy: A global guide for employers, (Norton Rose Fulbright, December 2020) <
https://www.nortonrosefulbright.com/en-fr/knowledge/publications/87afaec5/doing-business-in-the-gig-economy-a-
global-guide-for-employers#:~:text=In%20France%2C%20the%20business%20model,often%20gives%20rise
%20to%20disputes> accessed on 26th February, 2024
 https://indiacorplaw.in/2022/12/labour-law-and-the-gig-economy-towards-a-hybrid-
model-of-employment.html : This article also analyzes the hybrid model of employment,
taking inspiration of comparative study and drawing analogies from the foreign labour
law jurisdictions like Canadian and Spanish systems.

29
Sahaj Mathur, Labour Law and the Gig Economy: Towards a Hybrid Model of Employment, (IndiaCorpLaw, 25 th
December, 2022) < https://indiacorplaw.in/2022/12/labour-law-and-the-gig-economy-towards-a-hybrid-model-of-
employment.html> accessed on 26th February, 2024