Absent a viable, effective statutory regime for compensation, the courts in their constitutional law jurisdiction have had to forge new tools to give effect to the right of victims of crime to be compensated.51 In the Delhi Domestic Working Women Forum Case, the court directed payment of Rs.10,000 as ex gratia to each of the victims.52 In Gudalure M.J. Cherian v. Union of India53 the State of U.P. was directed to pay a sum of Rs.2,50,000/- as compensation to two Sisters on whom rape had been committed by unidentified assailants. The question of payment of compensation to victims of crime from the wages of prison labour came up for consideration in State of Gujarat v. Hon’ble High Court of Gujarat.54 The court recommended that the State should make a law “for setting apart a portion of the wages earned by the prisoners to be paid as compensation to deserving victims of the offence, the commission of which entailed the sentence of imprisonment to the prisoner, either directly or through a common fund to be created for this purpose or in another feasible mode”