Introduction to POSH Act

There was a time when women and men led separate lives based on gender-defined roles as conformed to by society. Over time, due to industrialization and globalization, the dynamics of gender have undergone radical evolution. While men were considered the sole breadwinners of the household, women were muffled and caged inside the house, as this was considered their duty. Now, that is no longer the case, as women have equal rights not just to survive but to thrive, vote, drive, and do everything that men can do. With an influx of women entering the workforce, there has been a significant rise in the unfortunate cases of sexual harassment against women in the workplace, leading to the need for a prevention and redressal mechanism.

The Foundation of POSH Act in India can be traced back to the Vishakha Guidelines established by the Supreme Court in 1997. Vishakha was a women’s collective who sought to bring focus to the ghastly condition of the working women during the late 90s through the case of Bhanwari Devi. The Supreme Court of India aimed to enforce the fundamental rights of working women under Articles 14 (Right to Equality), 19, (Right to Freedom Of Speech and Expression) and 21 (Right to Dignity) of the Constitution of India and is said to have taken inspiration from the Convention on the Elimination of All Forms of Discrimination against Women, 1979 (CEDAW) which is an approach by United Nations Human Rights. The Supreme Court used Convention on the Elimination of All Forms of Discrimination against Women, 1979 (CEDAW) to underline the need for POSH, stating that international treatise sanctioned by a country, must reform the domestic laws of the country in case of a legislative lacunae.

All Public and Private Sector Organizations in India are required to abide by specific statutory standards under the POSH Act, 2013. Employers and management bear responsibility for ensuring POSH for women at work. To this end, they are instructed to: Establish an Internal Complaints Committee; Conduct Periodic POSH Training on Sexual Harassment Law; and Create an efficient Complaint lodging and redressal Policy.

What is an IC Committee?

An IC Committee is an Internal Complaints Committee or a group constituted for the prevention and redressal of the Sexual Harassment at workplace for Women. Section 4 of the POSH Act mandates the establishment and constitution of an Internal Complaints Committee. It also provides for the constitution of a 4 member committee, serving time period for the four member committee, financial remuneration, if any for the external member and the removal of the members of the committee in case of breach of protocol. This committee stands  for the elimination and prevention of Sexual Harassment at workplace and also deals with providing remedy for the victims of Sexual Harassment.

Section 4(1) dictates that every employer should constitute a workplace Internal Complaint Committee. Given that there are various offices at different levels, there should be a constitution of the Internal Complaints Committee at all levels.

Section 4(2) states the criteria for the membership of the Internal Complaints Committee. According to this subsection, an Internal Complaints Committee should consist of the following members

• senior level executive who’s a female, provided no senior female executive is available, the presiding officers shall be nominated from the other workplace
• Not does not less than 2 employees shall be nominated who are sensitive and dedicated to the cause preferably with a legal knowledge background and experience with social work
• One external member shall be nominated from Non governmental organisation or an association concerned with women’s safety and issues regarding sexual harassment.

Section 4(3) informs about the time period of the functioning of the Internal Complaints Committee. It states that the presiding officer and every member of the committee shall hold office for 3 years, from the date of their nomination, at the discretion of the employer.

Section 4(4) The external member appointed from a Non Governmental Organisation or an external association as mandated in the Section 4(2), is entitled to a payment by the employer as prescribed under the Act.

Section 4(5) Any member of the Committee who contravenes the provisions of Section 16 of the POSH Act, or has been convicted of any previous offence, abused the; or has any previous disciplinary proceeding pending against him; or has abused his position of power in any way.

There is no particular time period prescribed in the Act or the Rules, within which an employer has to form an IC committee. If a workplace has less than 10 employees, then they need not form an Internal Complaints Committee. All the complaints pertaining to such workplaces should be registered with the local committee set up by the District Officers of each District. Hence, the onus of dealing with problems regarding sexual harassment is on the employer. With workplaces fostering more than 10 employees, there is a mandatory need to establish an Internal Complaints Committee.

When an employer does not have 10 employees at the workplace on the date of inception of the Act, he need not constitute an Internal Complaints Committee immediately, but ensure the constitution of the same, when the number of employees at the workplace reaches 10. In case of the number of the employees at a workplace being 10, the employer has to immediately establish an IC Committee, for there is no transition period prescribed by the Act. The Act under Section 1(3), states that the Act and by extension all the subclauses and subsections in the Act are to be enforced on such date as when Central Government by notice in the Official Gazette, appoints the Act.  

An IC Committee has to be a permanent body so as to inspire confidence and provide timely redressal access to victims. It is important to appoint a senior female executive as a presiding officer so as to maintain impartiality and prevent intimidation by colleagues and in case of some victims who are more comfortable with lodging the complaint with another female member only.  In case of absence of a senior female executive member at a workplace, then the presiding officer should be chosen from some other department or workplace headed by the same employer, and in case of absence of the same, the presiding officer can be appointed from another organisation.

The appointment of NGO as external members to the committee is important as it is necessary to bring an outside perspective to the proceedings to ensure objectivity and impartiality in deliberations and finding and also to bring in people from a more detail oriented and knowledgeable background with plenty of experience in handling such matters. When it comes to the qualification criteria for appointment of an NGO as an external member, the first qualification to be ensured is the commitment to the cause of woman safety and development. Furthermore, looking towards the legal perspective of things, the NGO has to have a verified registration and possession of legal knowledge by such NGO members are also necessary to onboard the NGO as an external member of the Internal Complaint Committee. 

An external member of the committee need not be a part of an NGO, they just have to be a person familiar with the issues relating to sexual harassment as a person who has expertise on issues relating to to sexual harassment and includes a social worker with at least five years of experience in the field of social work which leads to the creation of the societal conditions favourable towards empowerment of woman and in particular addressing workplace sexual harassment and a person who is familiar with the labour, service, civil and criminal law. Talking about the remuneration of the IC Committee members, Section 4(4) states that the members of an external NGO or association are entitled to receive a payment of two hundred rupees per day for holding the proceedings of the IC and also reimbursement for travelling expenses.

WHAT TO KEEP IN MIND WHILE CONSTITUTING AN IC COMMITTEE?

Internal Complaints Committee is mandated to be established in any workplace with over 10 employees, under Section 4 of the Prevention of Sexual Harassment Act, 2013. The main reason behind constituting an IC Committee is to Prevent; Prohibit Sexual Harassment and to provide Redressal to the employees of the workplace who have been a victim to the same. Establishing an IC Committee requires some forethought such as:

• Committee members should not have any personal interest or investment in the matter.

Internal Complaint Committee members are not supposed to have a personal interest or inquiry in the matter. In the case of the U.S. Verma, Principle, DPS Vs. NCW , noted irregularities in the functioning of the committee and held that there shouldn’t be any ‘personal knowledge or interest’ and quashed the report of the Committee. The members of the IC Committee should avoid being part of proceedings where there is a personal interest in the matter. They should previously let the other committee members know about it and let the proceedings carry on without them. If not disclosed, it could lead to grounds for dismissal as per the provisions of Section 4(5)(d).

• Conflict of Interest of Committee Members 

Under the rules of the constitution of an Internal Complaints Committee, there should not be a conflict of interest between the committee members and the rest of the employees. Any peculiar and special circumstances would lead to dismissal of the committee. In the case of Linda Eastwood Vs. Union of India & Ors., the High Court of Delhi reported malfunction in the reconstituted committee’s findings and declared it biased and unsustainable. Thus, the entire investigation should be carried out in a manner befitting the order of natural justice and principle of impartiality.

     (c)  Proper cause to be shown for removal of a committee member.

The POSH Act gives the right to both the parties (i.e Complainant and Respondent) to represent themselves and this right includes unwillingness to appear in front of the IC Committee in case it seems to them that the concerned Committee is overtly biased and would not adhere to the rules of established law, or has a conflict of interest. However, an IC Committee is a permanent committee for three years and mere suggestions or apprehensions of  one party is not enough to remove a member or disband the committee. In this case, the onus of proving the conflict relies on the party, to present proof or prove malicious or threatening intent. Not only this, but also the Committee can be challenged based on the constitution of the committee under section 4 of POSH Act, namely lack of proper legal knowledge or lack of sensitivity towards the issue. The contending party is responsible to prove such findings and biases and thus will be granted the right to not appear in front of such a committee and the justice will be carried out so forward in the manner as prescribed.

    (d) Minimum Quorum required for proceedings .

The function of an IC Committee cannot be carried out by the mere presence of one or two members. The minimum quorum required to conduct the functions of an IC Committee is three members including the presiding officer or the chairperson of the committee. If minimum quorum is not maintained during the proceedings, then it opens up the committee to get challenged on their decisions made while this time by the respondent on the grounds of not maintaining the quorum.

Functions of the IC Committee

An Internal Complaints Committee is set up at every district level office or organization with 10 or more than 10 employees. The main function of this committee is to provide methods of Prevention, Prohibition of the Sexual Harassment at workplace & Redressal to any victims of the Sexual Harassment. The primary function of the Committee is to intake complaints from the victims of sexual harassment and to properly investigate and inquire into the complaint and come to a fair and unbiased conclusion for the same.

1. HANDLING & FILING OF COMPLAINTS

Section 9(1) of the POSH Act, mandated the procedure following the filing of a complaint, in writing, to the Internal Complaints Committee, if constituted or in any other case, Local Committee, within a period of three months from the date of the incident or in case of series of incidents, within the period of three months from the last incident.

If, due to any given circumstances, the complaint cannot be made by an aggrieved woman, in writing, the IC Committee, or the members of the committee if constituted, or in any given case, the Local Committee, and the members of the same can should  provide all reasonable assistance and aid in registration of the complaint in writing.

Provided further that the Internal Committee or, as the case may be, the Local Committee may, for the reason to be recorded in writing, provide an extension of time limit for the registration of complaint, due to some circumstances, which prevented the woman from filing a complaint within the said period of three months.

Section (2) of the POSH Act, states the procedure to be followed in case of death of the aggrieved complainant or due to any physical or mental circumstances rendering the woman incapable of filing the complaint, the legal heir or such other person, as prescribed, may make a complaint under the section.

RULE 6 illustrated for the purpose of sub-section (2) of section 9 states the procedure to be followed during filling of the complaint in case of circumstances like, physical or mental incapacity, or death.

(i) In case of physical incapability of the aggrieved woman; complaint can be filed by –

1. Her relative or friend;
2. Her co-worker;
3. An officer of National Commission of Women or State Women’s Commission  
4. Any person with the knowledge of the incident and a written consent from the aggrieved woman.

(ii) In case of mental incapability of the aggrieved woman; complaint can be filed by –

1. Her relative or friend;
2. Any Special Educator
3. A Qualified Psychiatrist or Psychologist
4. A Guardian or Caretaker of the Aggrieved woman
5. Any person with the knowledge of the incident and in the company of the one of the above stated.

(iii) In case of Death of the aggrieved woman; complaint can be filed by –

Any person with the knowledge of the incident  and the written consent of her Legal Heir.

(iv) In case of any other circumstances rendering the aggrieved woman; complaint can be filed by –

Any person with the knowledge of the incident and a written consent from the aggrieved woman.

An Aggrieved woman with the intention of filing a complaint to the IC/LC Committee, should produce six copies of written statements of the complaints. The supporting documents and names And addresses of the witnesses should also be brought on the record and submitted to the concerned authorities within 3 months of the incident or in case of a series of incidents, should be submitted within 3 months from the date of the last incident. The time limit so prescribed is important to be followed to ensure swift action can be taken by the authorities to treat and inquire the complaint in the most authentic manner and in deliverance of justice. Lapse of a long period of time can lead to tampering or destruction of evidence, thus hampering the process of justice.  

The process of getting the aggrieved women justice against sexual harassment at workplace can be done in two primary ways of Conciliation & Inquiry. The process of Conciliation requires the Complainant to opt for the method of Conciliation which is an alternative dispute resolution mechanism as opposed to a full fledged inquiry. The process of Inquiry is the mechanism of investigation as per the service rules dictate.

• CONCILIATION

Section 10(1) of the POSH Act dictates that the Internal Complaints Committee or in cases of absence of the same, Local Complaint Committee, shall before initiating an investigation/inquiry, at the request of the complainant, strive to settle the dispute between the Complainant and the Respondent through Conciliation. Furthermore, monetary compensation cannot be a basis for Conciliation.

Section 10(2) of the POSH Act dictate that if the settlement has been arrived at by the Complainant and the Respondent, the the terms of settlement shall be recorded by the IC Committee or the Local Committee, and forward the same to the employer or the district officer, to take actions as per recommendations.

Section 10(3) of the POSH Act dictates that the IC Committee or the Local Committee is responsible for providing the copies of the agreed upon consent terms to the Complainant and the Respondent.

Section 10 (4) of the POSH Act dictates that when a settlement has been arrived at by the Complainant and the Respondent, no further inquiry shall be conducted by the Internal Complaints Committee or the Local Committee as the case may be. 

Under Section 10 of the POSH Act, when an aggrieved woman files a complaint against sexual harassment, she has an option to chose the alternate method of dispute resolution, as opposed to a full fledged inquiry. According to the POSH Act, only the Complainant can request to opt for the option of Conciliation.  At no point of time can the IC Committee or Local Committee as the case may be, advise the Complainant or Coerce the complainant into opting for the Conciliation redressal medium. The IC/LC Committee can inform the Complainant about her right to request for the process of Conciliation. The settlement terms must be recorded and copies of the same must be provided to both the parties, as well as the employer and the district officer.

The Section also clearly specifies that Monetary Compensation cannot be a part of the Conciliation. There is no prescribed procedure to carry out the procedure of Conciliation and it is expected that the IC Committee members should rely on good sense and principle of natural justice, because every case differs in various factors and thus must be treated authentically. Pertinent to note that Conciliations can only begin with a written request made by the Complainant, upon the acceptance of which, the Complainant is expected to lay out her terms for conciliation which may often involve a written apology or letter of regret.

With regards to conciliation mechanism taking place in case of major offences, it was suggested to the Parliamentary Standing Committee to make a distinction in major sexual harassment offences and minor sexual harassment offences, as punishment rendered for minor offences include a written apology or admission of guilt which would be too less for a major offence and visa versa. However, there are no such distinctions made in the Act for varying degrees of offences.

The principle of Confidentiality is one of the major pillars of the POSH Act. Under Section 16 of the Act, it is provided that any information related to Conciliation or any such processes followed, shall ‘not be published, communicated or made known to the public, press or media in any manner.’ This means that the details of the conciliation, or any information related to the proceeding cannot be disclosed to any external person by the parties, or the IC Committee or its members. It is of key importance to communicate to the parties, to maintain confidentiality as an integral part of the terms of settlement.

• INQUIRY

Section 11(1) dictates that IC/LC may proceed to make an inquiry into the complaint according to the provisions of the service rules applicable to the respondent, and in case of absence of such service rules, or in such a manner as prescribed, or in case of domestic workers, the local committee may direct the complaint to the police within a period of 7 days for registering the case under section 509 ( punishes those who insult a woman’s modesty) of the IPC ( Section 79 of BNS).

If the Complainant informs the IC/LC Committee that the respondent has not complied with the terms of settlement under section 10(2), the IC should probe and launch an investigation into the complaint or conduct an inquiry or in any case, forward the complaint to the police.

 Section 11(2) dictates that the court may, when the respondent is found guilty of an offence, order payment of a certain sum of money with regards to section 15 i.e. determination of compensation.

 Section 11(3) of the Act dictates that an IC/LC Committee have been granted the same power as that of a civil court under Crpc while trying the cases or take any action to aide or move forward the inquiry as such:

• Power to summon any person related to the matter and question under oath..
• Require or Command production of documents
• Any other action which may be prescribed for the process of inquiry.

 According to the Act, the IC/LC Committee will investigate the complainant in line with the terms of the service rules that apply to the respondent and, in the absence of such rules, in any way that may be specified. Regarding the service regulations, the Parliamentary Standing Committee recommended that all private sector service rules explicitly include sexual harassment as a crime. It is also recommended that the same be done to highlight each person’s specific role. The Parliamentary Standing Committee recommended that measures be implemented to implement the Industrial Employment (Standing Orders) Act of 1964, which forbids sexual harassment of private employees. Regarding governmental entities, however, the CCS Rules, 1965 apply to every Government Servant with a few exceptions.

• Industrial Employment (Standing Orders) Act, 1946.

In the following case, the initial complaint must be filed and accepted by the IC as per the provisions of Section 9 of the Act, and thereafter, the inquiry into the complaint, must be made in accordance with the provision of Industrial Employment (Standing Orders) Act, 1946.By an amendment, in 1999, sexual harassment was included in the Model Standing Orders list which amounted to a misconduct. In 2006, another amendment was carried out which guided the provision related to formation of Complaints Committee, which shall hold inquiry as per the provisions laid down by the Industrial Employment (Standing Orders) Act, 1946.

• CCS (Central Civil Services) Rules.

These regulations are applicable to every government servant including every civilian government servant in the Defense Service but does not apply to certain government servants, such as a railway servant, any member of All India Services or a person in casual employment etc. Before 1998, the CCS Rules did not provide for any procedure to handle cases of misconduct including cases of misconduct in the nature of sexual harassment by these government servants. However, after the judgment of the Supreme Court in case of Vishaka V. State of Rajasthan, the CCS Rules were amended in the year 1998 to provide for a procedure to take actions against a government servant who has been allegedly involved in sexual harassment. According to this, the complaint of sexual harassment in the concerned public sector services under CSS Rules, would while inquiring not only follow POSH Rules, but also the Central Civil Services Rules, which are in conformity with the POSH Rules.

(c )  All India Council for Technical Education 

All technical educational institutions in India are subject to the All India Council for Technical Education’s Regulations, 2016, which cover gender sensitization, the prevention and prohibition of sexual harassment of female employees and students, and the redress of grievances in technical educational institutions. From the perspective of the pupils, it also fosters gender neutrality and gender sensitivity.

(d) Securities and Exchange Board of India (Employees Services) Regulations, 2007.

Regulations are established by the Securities and Exchange Board of India, as Regulation 78 and 78A, for prohibition of Sexual Harassment of Women Employees at Workplace and stating that no employee shall indulge in any act of sexual harassment of any woman employee at workplace. Any complaint will be dealt with by the Complaints Committee set up by the Board, which shall be in accordance with the POSH Act guidelines, to set up a complaints committee with a senior woman executive as the head and an external member.

THINGS TO KEEP IN MIND BY IC WHEN CONDUCTING INQUIRY.

(i) IC to conduct inquiry as per service rules : As purported in Section 11, IC must conduct the inquiry while taking inspiration from the service rules of a workplace.

(ii) IC to conduct inquiry within 90 days : As prescribed in the POSH Act, an IC Committee is supposed to complete the inquiry and investigation within 90 days of the filing of the complaint. However, in any case where they fail to do so, under reasonable apprehension, they may be allowed an extension with no liability on the shoulders of the employer.

(iii) Legal Representation during proceedings : in cases where the complainant requests for the assistance of a legal counsel, they must be informed that according to the POSH Act, the Inquiry process was proposed as a quasi judicial proceeding,  which being informal in nature need not require legal representation. The Act however, allows for the complainant to be accompanied by a person for emotional support.

(iv) Manner of inquiry and requisite questions : It is the responsibility of an IC Committee to outline the manner in which the proceedings will take place. No outline has been pre decided as the Parliamentary Standing Committee is of the view that each committee is allowed to have liberty to proceed with the manner as they deem fit, given that it does not violate the principles of natural justice or established legal system. Furthermore, it is required to ascertain whether the offence comes under the purview of sexual harassment. The point of view of the victim is considered as the benchmark in such cases as what may be perceived as harmless conversation or friendly banter to some may be often construed as objectionable to certain people. Thus, the concept of ‘reasonable woman’ was formulated by the US Court of Appeals and adopted by the High Court of Delhi. This concept apprehends and analyses the views of the victim and decides as to what act can be categorised as sexual harassment and what can be misunderstood as a act of sexual harassment by overtly sensitive women.

(v) Dealing with the Respondent : It is the responsibility of an IC Committee to clearly mention the charges against the respondent by detailing out the written statement. In case of an error in the same procedure can create a huge turmoil by misleading the parties to the complaint as well as the concerned authorities and lead to circumstances which may obstruct the due course of justice, such as overly punishing the respondent for a minor offence. Thus, the Act provides for the issuance of a copy of complaint to the respondent, so as to enable him to ascertain the complaint and form his own side of representation.  Dealing with a Respondent can be tough as in some circumstances, the Respondents tend to not take the IC Committees seriously and thus leading them to fail to show up on the appearances and to cooperate with the proceedings. Remedy to this is provided in Section 11 where the IC Committee is granted the powers of a Civil Court under Crpc, 1908. This authorizes the IC Committee to summon the person and to question him under oath, and to issue legal notice to the person in case of failure to show up on decided dates constantly.

2. SUBMISSION OF ANNUAL REPORT

The Internal Complaints Committee is in charge of overseeing the filing and handling of the Complaints & grievances relating to Sexual Harassment as its main function. One of its ancillary functions is to submit an annual report to the employer or district officer under Section 21. The Annual Report which the IC Committee is tasked to prepare should be handed over to either the employer or the District Officer, as the case may be. Enclosed within this report should be details as following :

1. Number of Complaints of Sexual Harassment received in a year

The above mentioned detail is necessary to be added to the report as it details out the number of cases registered, dealt with and disposed off in the past year. This gives the employer a view inside the patterns of the number of cases and relates to the need to create a strong mechanism to tackle sexual harassment.

1. Number of Complaints disposed of during the year

This is another essential addition in the report as it gives the employer a view inside the working of the IC Committee and also provide a scope of work to the Committee members, also accounts them for the additional time taken by them

• Number of workshops or awareness programmes against sexual harassment.

One of the other ancillary function of IC Committee is to spread awareness about the importance of a safe and healthy workplace and also about the prevention, prohibition and redressal of sexual harassment at workplace. For the purpose of the same, IC Committees are required to carry out various workshops and seminars to provide information to the employees of the organisation on the topic of sexual harassment. This will help the employers and well as employees to better understand the issue from the basics and be well informed about the remedy in case of a complaint.

1. Action taken by the Employer

An employer is responsible for the safeguard and well being of the employees under his guidance. Thus, it is primarily an Employer’s duty to ensure the functioning of the IC Committee. The employer’s duties are also listed and analysed in the Annual Report. This makes the Employer responsible for the upkeep of the sexual harassment laws in their respective organisations.

CONCLUSION

The Prevention of Sexual Harassment at Workplace Act (Prevention, Prohibition & Redressal), 2013 is placed to safeguard the rights of working woman and to treat with them equality (Under Article 14) and dignity (Under Article 21). The constitution of IC Committees play a major role in the POSH Act and Guidelines, as it provides for a structure and forum for such aggrieved women to register their complaints and a chance for them to expect redressal. Constitution of an IC Committee is very important in an organisation as they provide a safe means for the redressal of such complaints as well as work towards spreading awareness on these issues.

Over 400 incidences of sexual harassment at work were reported nationwide between 2018 and 2022, according to a recent Business Standard story that referenced statistics from the National Crime Records Bureau (NCRB). During this time, an average of 445 cases per year were reported. Additionally, in 2022, the country reported around 419 cases, or roughly 35 cases per month, with Himachal Pradesh leading the pack, followed by Kerala, Maharashtra, and Karnataka. This report as published in Hindustan Times leaves the readers to understand the burning need of implementation of POSH Act, 2013 at workplaces for the safety of women.

The recent R.G. Kar case in Kolkata where a postgraduate trainee doctor was brutally raped and murdered left a sensational effect on the psyche of all the country. Thousands of such cases happen on a daily basis in India, emphasising on the need for the placement and effective implementation of  a proper preventative as well as redressal mechanism. POSH Act, serves as a cornerstone in addressing workplace sexual harassment. As it is famously said, “Prevention is better than cure”, the constitution of an IC Committee not only prevents incidents of harassment at the workplace, it’s functions also saves the reputation and face of the firm in the public eye.

References:

1. Handbook on the Law of Sexual Harassment At Workplace by Shivangi Prasad & Attreyi Mukherjee.

2. Handbook on POSH by Nishith Desai & Associates (https://www.nishithdesai.com/fileadmin/user_upload/pdfs/Research%20Papers/Prevention_of_Sexual_Harassment_at_Workplace.pdf)

3. The Internal Complaints Committee (ICC) for Sasmira’s Institute of Commerce and Science ( https://sics.edu.in/wp-content/uploads/2022/10/Internal-Complaint-Committee.pdf)

4. India Code Website (https://www.indianic.in/handle/123456789/2104)

5. POSH Annual Return (https://www.ungender.in/posh-annual-return/)

6. Prevention Of Sexual Harassment at Workplace (Prevention, Prohibition and Redressal) Rules, 2013. (https://upload.indiacode.nic.in/showfile?actid=AC_DL_64_789_00006_00006_1593607984940&type=rule&filename=sexual_harassment_at_workplace_rules_sw.pdf)

Parliament of Indian Rajya Sabha – Parliamentary Standing Committee Report on (https://prsindia.org/files/bills_acts/bills_parliament/2010/SCR_Protection_of_Women.pdf)