A joint fact-finding report by PUCL, AILAJ, and Domestic Workers' Rights organisations documents the Bengaluru police crackdown on Bengali-speaking migrant workers, treating them as illegal immigrants without due process. The report argues the State cannot use immigration law as a mask for ethnic profiling. Workers were detained, harassed, and displaced solely on linguistic and ethnic grounds, violating constitutional guarantees of free movement, residence, and equality under Articles 19 and 14.

This report foregrounds three interlocking constitutional provisions.

Article 19(1)(d) and (e) guarantee every citizen the right to move freely throughout India and to reside and settle in any part of India. These rights are available only to citizens, but all persons — citizens and non-citizens — retain the protection of Article 14 (equality) and Article 21 (life and personal liberty) against arbitrary state action.

The court-tested limitation on Art 19(1)(d)/(e) is found in Art 19(5): the State may impose reasonable restrictions in the interests of the general public or for the protection of the interests of any Scheduled Tribe. 'Reasonable' requires a nexus between the restriction and the object; ethnicity or linguistic identity alone cannot constitute that nexus without amounting to discrimination under Art 15(1).

The deeper constitutional wrong identified by the report is the use of immigration powers — designed to identify non-citizens — against internal migrants who are citizens. This conflates 'foreign national' with 'person from another State,' a category the Constitution explicitly protects. The Foreigners Act 1946 places the burden of proving citizenship on the detenu, making internal migrants from minority-language communities especially vulnerable to profiling.

Seminal precedents: Maneka Gandhi v Union of India (1978) held Art 19 and Art 21 are not silos — any law curtailing movement must satisfy Art 14's reasonableness standard and Art 21's just, fair, and reasonable procedure test simultaneously. Satwant Singh Sawhney (1967) and subsequent rulings established that freedom of movement is not contingent on the State's convenience.