India eases restrictions on workplaces in the third phase of lockdown

May 4, 2020

On May 1, 2020, the Indian government further extended the ongoing countrywide lockdown until May 17, 2020. The third phase of the lockdown is based on demarcation of districts into three (3) zones and reasonably well-defined exemptions for each zone under the revised guidelines (the “Revised Guidelines”) issued yesterday. The Revised Guidelines will be effective from May 4, 2020.

This update discusses the categorization of districts and the exemptions under the Revised Guidelines.

Zonal demarcation

The Indian government has divided districts into the following three (3) zones on the basis of COVID-19 positive case count as of April 30, 2020. This list will be updated on a weekly basis.

  • Red Zone: All the major metropolitan cities in India, including, New Delhi, Mumbai, Chennai, Hyderabad, Bengaluru and Pune have been notified as red zones. Other districts with a significant case count have also been identified as red zones.
  • Green Zone: The districts that have not had a single confirmed COVID-19 case until date or have not had any confirmed cases in the previous twenty-one (21) days have been classified as green zones.
  • Orange Zone: The remaining districts across the country, that are neither red zones nor green zones, have been classified as orange zones.

Exemptions for workplaces

The Revised Guidelines specify exemptions for establishments and workplaces for each zone. These exemptions are not applicable to workplaces located in a containment zone in a red or orange zone. Containment zones are identified by the State government, Union Territory or District administrations.

Permitted work places in red zones

The Revised Guidelines have permitted private offices to operate with a maximum of thirty-three (33%) strength, with the remaining employees working from home. In addition, the Revised Guidelines provide that no fresh permissions will be required for activities which were permitted to operate under the lockdown guidelines applicable until May 3. A list of exempt workplaces under the earlier guidelines is available at The Indian government’s social distancing guidelines may not be easy to comply.

Permitted workplaces in the orange and green zones

Barring a few establishments in the hospitality, retail and education sector, all commercial establishments, private offices, industrial establishments and factories have been permitted to resume operations in orange and green zones.

Mandatory social distancing norms

The Revised Guidelines require the permitted categories of businesses to comply with certain prescribed social distancing norms at the workplace. The mandatory social distancing norms are largely the same as those in the lockdown guidelines dated April 15, 2020 and are available at The Indian government’s social distancing guidelines may not be easy to comply.

That said, the Revised Guidelines do not expressly mention the following norms which featured in the earlier guidelines:

  • Provide medical insurance;
  • Prohibit more than two (2) to four (4) persons from using lifts in office or factory premises, depending on the size of the lift;
  • Prohibit entry of non-essential visitors; and
  • Require parents of children below five (5) years of age to work from home.

Our comments

Although the lockdown has been extended, the Indian government has expanded the scope of permitted activities in red and orange zones and almost completely relaxed restrictions in the green zones. This is a move back to normalcy with a focus on allowing non-critical areas to resume operations. The States and Union Territories are not permitted to dilute the requirements under the Revised Guidelines. As some States had issued additional restrictions earlier, employers will have to check if there are any restrictions from the relevant State government as well.

From a practical standpoint, the key issue for employers will be to ensure compliance with the extensive social distancing norms as well as ensure that employees are able to reach the office or factory as public transport is still not permitted in red and orange zones.

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