Magazine 2014
International Peer-Reviewed Journal  
Vibhuti Patel  
Sexual harassment at the workplace (SHW) is a universal problem. Sexual harassment is a form of abuse.  
At the workplace, it is also about power play of a bully over a vulnerable individual, regardless of age,  
class, ethnicity, race, religion or sex. It impinges on the fundamental right to earn a livelihood by making  
it difficult to work.  
Even though the occurrence of SHW is widespread in India and elsewhere, this is the first time it has been  
legally recognised as an infringement of the fundamental rights of a woman, under Article 19(1) (g) of the  
Constitution of India "to practice any profession or to carry out any occupation, trade or business". Ar-  
ticles 14, 15 and 21 of the Indian Constitution provide safeguards against all forms of discrimination. As  
there is no clarity in definition of ‘woman’, transgender community is clubbed with women and when any  
transgender person faces sexual harassment they don’t even get legal redressal.  
SHW at the workplace has been one of the central concerns of the women's movement in India since the  
80s. After 30 years of consistent effort, Indian women have managed to get The Sexual Harassment of  
Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and rules for the same has made  
the Act implementable. Due to pressure from child rights organizations, previous year the Parliament of  
India passed The Protection of Children from Sexual Offences Act, 2012, aimed at protecting children in  
India against the evil of child sexual abuse. It came into force on 14-11-2012, Children’s Day (in India)  
along with the rules framed under the Act.  
Keywords : women's movement, patriarchal bias, male domination, discrimination, injustice, safety  
of women  
Gender under the spotlight in India  
In the month following the gang rape of a 23-year-old physiotherapist in a moving bus in Delhi on 16  
December 2013, debates over the social construction of gender that perpetuates sexual harassment in  
all walks of life have taken centre stage in India. The general public, community leaders, parents,  
youths, education providers, corporate, policy makers, politicians and the media: all are discussing  
the prevalence of sexual violence in our society. The masses, spanning four generations, have started  
deconstructing workplace safety in the context of misogyny, barbarism, the influence of pornography  
in valorising sadomasochistic relations between men and women, the influence of Westernisation on  
women’s dress codes, consumerist culture, hedonism, and how the chivalry toward women that existed  
among civilized cultures is being replaced by hostility toward women.  
Sexual harassment at the workplace has been one of the central concerns of the women’s movement  
in India since the ’80s. After 30 years of consistent effort, Indian women have managed to get The  
Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 and  
rules for the same are awaited so that the Act can be implemented. Due to pressure from child rights  
organizations, previous year the Parliament of India passed The Protection of Children from Sexual  
Offences Act, 2012, aimed at protecting children in India against the evil of child sexual abuse. It  
came into force on 14-11-2012, Children’s Day (in India) along with the rules framed under the Act.  
Women’s Movement against Gender Based Violence  
During the 1980s, militant action by the Forum Against Oppression of Women (Mumbai) against the  
sexual harassment of nurses in public and private hospitals by patients and their male relatives, ward-  
boys and other hospital staff; of air-hostesses by their colleagues and passengers; of teachers by their  
colleagues, principals and management representatives; of PhD students by their guides and so on  
and so forth received a lukewarm response from the trade unions and adverse publicity in the media  
FAOW, 1991). But this trivialisation did not deter the women’s rights activists. More and more working  
women started taking systematic action against SHW. Baailancho Saad (‘Women’s Voice’) in Goa  
mobilised public opinion through demonstrations, rallies and sit-ins against their chief minister (in  
990) who sexually harassed his secretary, till the minister was forced to resign. (Chorine et al, 1999).  
Some Noteworthy Complaints of Sexual Harassment at Workplace (SHW) that came into the national  
limelight due to massive protests, were filed by:  
Rupan Deo Bajaj, an IAS officer in Chandigarh, against ‘super cop’ K P S Gill (1990)  
International Peer-Reviewed Journal  
An activist from the All India Democratic Women’s Association, against the environment minister  
in Dehra Dun (1991)  
An airhostess of Air India against her colleague, in Mumbai (1990)  
A Secretary against Chief Minister of Goa (1990)  
Medha Kotwal Lele vs. Union of India and others (2000)  
Apparel Export Promotion Council vs A K Chopra (1999)  
Nalco chief found guilty in sexual harassment and his service terminated (2002)  
An IAS officer in Thiruvananthapuram, against the state minister (2002)  
A woman Director of KPMG against 6 top bosses including CEOs (2007)  
Sun TV Sexual Harassment Case- Response from Women Journalists (March 2013)  
Three interns of National Law School, Kolkata against the Supreme Court Judges (November,  
013 & January, 10, 2014)  
Owner of Tehalka sexually harassing journalist working for Tehalka (Nov. 2013)  
In the post-independent India, before 1997, women experiencing SHW had to lodge a complaint under  
Section 354 of the Indian Penal Code that deals with the ‘criminal assault of women to outrage women’s  
modesty’ and Section 509 that punishes an individual/ individuals for using a ‘word, gesture or act  
intended to insult the modesty of a woman’. These sections left the interpretation of ‘outraging women’s  
modesty’ to the discretion of the police officer.  
The Supreme Court of India’s Directive on SHW, 1997  
During the 1990s, the most controversial and brutal gang rape at the workplace involved a Rajasthan  
state government employee who tried to prevent child marriage as part of her duties as a worker of the  
Women Development Programme of Government of Rajasthan. The feudal patriarchs who were enraged  
by her (in their words: “a lowly woman from a poor and potter community”) ‘guts’ decided to teach her  
a lesson and raped her repeatedly in public view (Samhita, 2001). After an extremely humiliating legal  
battle in the Rajasthan High Court the rape survivor did not get justice and the rapists — “educated and  
upper caste affluent men” — were allowed to go free. This enraged a women’s rights group called  
Vishakha that filed public interest litigation in the Supreme Court of India (Combat Law, 2003).  
In 1997, the Supreme Court passed a landmark judgment in the Vishakha Case punishing Bhanvari  
Devi’s rapists and laying down guidelines to be followed by establishments in dealing with complaints  
about sexual harassment. The court stated that these guidelines were to be implemented until legislation  
is passed to deal with the issue (Mathew, 2002).  
Pursuant to this, the Government of India requested the National Commission for Women (NCW) to  
draft the legislation. A number of issues were raised regarding the NCW draft, until; ultimately, a drafting  
committee was set up to make a fresh draft. Several women’s organisations were part of this committee,  
including Majlis from Mumbai and The Lawyers’ Collective, Delhi. Women’s organisations and women  
lawyers associated with trade unions in Mumbai had collectively worked on the draft. Particular concern,  
whilst finalising the draft, was to include the unorganised sector and to incorporate provisions of the  
labour law. The bill introduced in Parliament was known as the Sexual Harassment of Women at The  
Workplace (Prevention and Redressal) Bill, 2004. It provided for the prevention and redressal of sexual  
harassment of women at the workplace, or arising during and in the course of their employment and  
matters connected thereto, in keeping with the principles of equality, freedom, life and liberty as enshrined  
in the Constitution of India, and as upheld by the Supreme Court in Vishakha vs State of Rajasthan  
1997(7) SCC.323] and as reflected in the Convention on the Elimination of all Forms of Discrimination  
against Women (CEDAW) which has been ratified by the Government of India.  
Scenario in the post-Vishakha guidelines period  
Several organisations have carried out research on SHW that has been widely disseminated. A survey  
by Sakshi (Delhi) threw up some worrying data: 80% of respondents revealed that SHW exists, 49%  
had encountered SHW, 41% had experienced SHW, 53% women and men did not have equal  
opportunities, 53% were treated unfairly by supervisors, employers and co-workers, 58% had not heard  
of the Supreme Court’s directive of 1997, and only 20% of organisations had implemented the Vishakha  
guidelines (Dalal, 2003). Controversy over SHW by the senior manager of Infosys (Nair, 2003), by the  
chairman and managing director of NALCO (Ramanujan, 2004), the Medha Kotwal petition on SHW of  
a PhD student by her guide at M S University, Vadodara, complaints against a senior professor at  
Lucknow University (Times of India, 2003), complaints about SHW by the film star Sushmita Sen against  
the CEO of Coca-Cola have all alerted employers to the economic burden and efficiency loss from  
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SHW. Still, most private companies and even media houses who report cases of sexual harassment  
refrain from investing funds in such committees. On October 20, 2004, students beat up an anatomy  
professor from Versova, Andheri, for alleged sexual misconduct (The Indian Express, Mumbai Newsline,  
A Sophia Centre for Women’s Studies and Development study showed that awareness and  
implementation of the Supreme Court’s guidelines is very low and there is a need to spread awareness  
about the new law. A study by Samhita (Kolkata), throwing light on the Bhanvari Devi case, has  
highlighted to the state and civil society the gravity of the menace of SHW (SCWSD and ICHRL, 2003).  
During 1997-2013, increasing number of corporate houses, educational institutions, public and private  
sector enterprises and government bodies have started instituting grievance redressal cells within the  
organization to deal with complaints of sexual harassment at workplace. The testimonies of several  
employees projected by media have revealed that SHW is prevalent even in companies where the  
victims are highly educated, are holding important positions and have considerable economic leverage.  
Similar views have been expressed in the business journals. NGO members on committees in several  
MNCs say that complaints sent to global head offices always elicit quicker and pro-active responses.  
Definition of sexual harassment at work- From Vishakha Directive to the The Sexual Harassment of  
Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013:  
The Supreme Court directive of 1997 clearly and unambiguously provides an answer to the question  
What is sexual harassment?’ Even the new law draws heavily from the Vishakha directive.  
As defined in the Supreme Court guidelines (Vishakha vs State of Rajasthan, August 1997), sexual  
harassment includes such unwelcome sexually determined behaviour as:  
Making Physical contact  
A demand or request for sexual favours  
Sexually coloured remarks  
Showing pornography  
Any other unwelcome physical, verbal or non-verbal conduct of a sexual nature, for example,  
leering, telling dirty jokes, m sexual remarks about a person’s body, etc  
The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act,  
013 provides for protection of all working women, including domestic helps and agricultural labourers,  
against sexual harassment at the workplace. The Act makes it mandatory for all workplaces including  
homes, universities, hospitals, government and non-government offices, factories, and other formal  
and informal workplaces to have an internal grievance redressal mechanism for complaints related to  
sexual harassment. The in-house committee has to dispose of a complaint within 90 days. There are  
also safeguard against false or malicious charges. If a woman is found to have filed a complaint with  
mala-fide intentions, she can be punished. Failure to prove charges, however, will not be construed as  
mala-fide intention.  
As per this Act, cases of sexual harassment of women at workplace, including against domestic help,  
will have to be disposed of by in-house committees within a period of 90 days failing which penalty of  
Rs 50,000 would be imposed. Repeated non-compliance of the provisions of the Sexual Harassment  
of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 can even lead to higher  
penalties and cancellation of license or registration to conduct business.  
Major Challenges for Changing the Mindset  
The Supreme Court directive provided the legitimate space for the hidden truth about SHW to surface;  
earlier one only heard about victim-blaming, witch-hunting and blackmailing. Now women are fighting  
back tooth and nail. The electronic and print media have become extremely responsive to the issue of  
SHW. My first-hand experiences with sitting in the grievance redressal committees regarding SHW has  
convinced me that we need to counter the myths about SHW with concrete facts, case studies and a  
Myth:1. Women enjoy ‘eve-teasing’/sexual harassment.  
Fact: Eve-teasing/sexual harassment is humiliating, intimidating, painful and frightening.  
Myth 2 : ‘Eve-teasing is harmless flirtation. Women who object have no sense of humour.  
Fact: Behaviour that is unwelcome cannot be considered harmless, or funny. Sexual harassment  
is defined by its impact on the woman rather than the intent of the perpetrator.  
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Myth 3: Women ask for SHW. Only women who are provocatively dressed are sexually harassed.  
Fact: This is the classic way of shifting the blame from the harasser to the woman. Women  
have the right to act, dress and move around freely without the threat of attack or harassment.  
The most popular slogan of the women’s rights movement of last 3 decades has been:  
However we dress, where ever we go, ‘Yes’ means ‘Yes’ and ‘No’ means ‘No’.  
Myth 4: Women who say NO actually mean YES.  
Fact: This is a common myth used by men to justify sexual aggression and one sided Sexual  
Myth5: Sexual harassment is not really an issue. It doesn’t hurt anyone.  
Fact: Persons subjected to sexual harassment experience a wide range of physical and  
psychological ailments. There are economic consequences for the victim’s physical and mental  
well being and the organisation’s productivity, efficiency and work ethics.  
Myth6: Sexual harassment! It’s only natural male behaviour. A man is a hunter and Woman is  
a prey.  
Fact: Men are not born knowing how to sexually harass others. It’s learned within the context  
of a sexist and patriarchal environment that perpetuates control over women’s sexuality, fertility  
and labour.  
Myth 7: Women keep quiet: that means they like it.  
Fact: Women keep quiet to avoid the stigma attached and retaliation from the harasser.  
Women are afraid that they will be accused of provoking it, of being victimised, of being  
called liars and made the subject of gossip.  
Myth 8: If women go to places where they are not welcome, they should expect sexual harassment.  
Fact: Discriminatory behaviour and abuse is unlawful. Women have equal access to all work  
facilities. Safe work place is women’s legal right.  
In the herstory of combating sexual harassment at workplace over last 3 decades, we have encountered  
the following four perspectives on SHW, as explained below:  
View B  
View A  
Power relation,  
male over woman  
Involves both  
implicit and explicit  
terms of employment  
Consists of  
Improper use of powerto  
extort gratification  
or misunderstanding  
of person’s intentions  
Used as a basis  
for employment  
‘Love affair gone sour Treats women as  
sex objects  
subordinate status  
in society  
Produces consequences Personal matter.  
from submission to/or  
refusal of advances  
Why should  
Asserts women’s  
sex role over her  
work role  
Promotes intimidating,  
hostile or offensive  
work environment  
Can hurt  
reputation of  
Asserts women’s sex role  
over work role  
Aberrant behaviour  
Parallels rape  
Responsibility of Employers  
Both, The Vishakha guidelines and the The Sexual Harassment of Women at Workplace (Prevention,  
Prohibition and Redressal) Act, 2013 categorically state that:  
Every employer shall—  
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a. provide a safe working environment at the workplace which shall include safety from the persons  
coming into contact at the workplace;  
b. display at any conspicuous place in the workplace, the penal consequences of sexual harassments;  
and the order constituting, the Internal Committee under subsection (I) of section 4;  
c. organise workshops and awareness programmes at regular intervals for sensitising the employees  
with the provisions of the Act and orientation programmes for the members of the Internal  
Committee in the manner as may be prescribed;  
d. provide necessary facilities to the Internal Committee or the Local Committee, as the case may  
be, for dealing with the complaint and conducting an inquiry;  
e. assist in securing the attendance of respondent and witnesses before the Internal Committee or  
the Local Committee, as the case may be;  
make available such information to the Internal Committee or the Local Committee, as the case  
may be, as it may require having regard to the complaint made under sub-section (1) of section 9;  
g. provide assistance to the woman if she so chooses to file a complaint in relation to the offence  
under the Indian Penal Code or any other law for the time being 45 of 1860. in force;  
h. cause to initiate action, under the Indian Penal Code or any other law for the 45 of 1860. time  
being in force, against the perpetrator, or if the aggrieved woman so desires, where the perpetrator  
is not an employee, in the workplace at which the incident of sexual harassment took place;  
i. treat sexual harassment as a misconduct under the service rules and initiate action for such  
j. monitor the timely submission of reports by the Internal Committee.  
Thus, it is the duty of the employer or other responsible persons in the workplace or institution to:  
Prevent sexual harassment  
Provide mechanisms for the resolution of complaints  
All women who draw a regular salary, receive an honorarium, or work in a voluntary capacity in  
the government, private sector or unorganised sector come under the purview of these guidelines.  
Complaints mechanism  
All workplaces should have an appropriate complaints mechanism with a complaints committee,  
special counselor or other support services.  
A woman must head the complaints committee and no less than half its members should be  
The committee should include an NGO/individual familiar with the issue of sexual harassment.  
The complaints procedure must be time-bound.  
Confidentiality must be maintained.  
Complainants/witnesses should not experience victimisation/discrimination during the process.  
Preventive steps  
Sexual harassment should be affirmatively discussed at workers’ meetings, employer-employee  
meetings, etc.  
Guidelines should be prominently displayed to create awareness about the rights of female  
The employer should assist persons affected in cases of sexual harassment by outsiders.  
Central and state governments must adopt measures, including legislation, to ensure that private  
employers also observe the guidelines.  
International Peer-Reviewed Journal  
Names and contact numbers of members of the complaints committee must be prominently  
Employers’ responsibilities  
Recognise sexual harassment as a serious offence.  
Recognise the responsibility of the company/ factory/workplace to prevent and deal with sexual  
harassment at the workplace.  
Recognise the liability of the company, etc, for sexual harassment by the employees or  
management. Employers are not necessarily insulated from that liability because they were not  
aware of sexual harassment by staff.  
Formulate an anti-sexual harassment policy. This should include:  
A clear statement of the employer’s commitment to a workplace free of unlawful discrimination  
and harassment.  
Clear definition of sexual harassment (using examples), and prohibition of such behaviour as an  
Constitutions of a complaints committee to investigate, mediate, counsel and resolve cases of  
sexual harassment. The Supreme Court guidelines envisage a proactive role for the complaints  
committee, and prevention of sexual harassment at work is a crucial role. It is thus imperative  
that the committee consist of persons who are sensitive and open to the issues faced by women.  
A statement that anyone found guilty of harassment after investigation will be subject to disciplinary  
The range of penalties that the complaints committee can levy against the offender should include:  
Explicit protection of the confidentiality of the victim of harassment and of witnesses.  
A guarantee that neither complainant nor witnesses will be subjected to retaliation.  
Publishing the policy and making copies available at the workplace. Discussing the policy with all  
new recruits and existing employees. Third-party suppliers and clients should also be aware of  
the policy.  
Conducting periodic training for all employees, with active involvement of the complaints committee.  
Freedom from sexual harassment is a condition of work that an employee is entitled to expect.  
Women’s rights at workplace are human rights.  
Sexual harassment at the workplace is a universal problem. Sexual harassment is a form of abuse. At  
the workplace, it is also about power play of a bully over a vulnerable individual, regardless of age,  
class, ethnicity, race, religion or sex. It impinges on the fundamental right to earn a livelihood by  
making it difficult to work.  
Even though the occurrence of sexual harassment at the workplace is widespread in India and elsewhere,  
this is the first time it has been legally recognised as an infringement of the fundamental rights of a  
woman, under Article 19(1) (g) of the Constitution of India “to practice any profession or to carry out  
any occupation, trade or business”. Articles 14, 15 and 21 of the Indian Constitution provide safeguards  
against all forms of discrimination  
Of late, the problem of sexual harassment at the workplace has assumed serious proportions and  
some of the survivors of SHW are also reporting to the complaints committees. Surprisingly, however,  
in most cases women do not report the matter to the concerned authorities.  
India is rapidly advancing in its developmental goals and more and more women are joining the  
workforce. It is the duty of the state to provide for the wellbeing and respect of its citizens to prevent  
International Peer-Reviewed Journal  
frustration, low self-esteem, insecurity and emotional disturbance, which, in turn, could affect business  
efficacy, leading to loss of production and loss of reputation for the organisation or the employer. In  
fact, the recognition of the right to protection against sexual harassment is an intrinsic component of  
the protection of women’s human rights. It is also a step towards providing women independence,  
equality of opportunity and the right to work with dignity.  
In the last 50 years, various international human rights organisations have been focusing on promoting  
and protecting women’s rights. The United Nations has acknowledged that women’s rights are  
synonymous with human rights. Most international women’s human rights movements have raised  
their voice against abuse and violence perpetrated against women in general. In 1979, the UN General  
Assembly adopted the Convention on the Elimination of all forms of Discrimination Against Women  
CEDAW). Areas where discrimination was found to be rampant include political rights, marriage,  
family and employment. The convention emphasised that discrimination and attacks on a woman’s  
dignity violated the principle of equality of rights. The same was reiterated in the Beijing Declaration,  
With a meteoric rise in the number of cases, the women’s groups in India have begun lobbying with  
parliamentarians to get the rule of the Act in the winter session of Parliament. For any sexual harassment  
law to be successful in India, it is important to be aware of the difficulties confronting our society and  
ways to overcome them. We all know that in a patriarchal society most cases of sexual harassment  
remain unreported. Women are reluctant to complain and prefer silence due to lack of sensitivity on  
the part of Indian society. There is a need to gender-sensitise our society so that the victim does not  
feel guilty and is encouraged to report any form of harassment. The victim’s privacy must be protected.  
The police and the judiciary, in particular, also need to be gender-sensitised. There should be speedy  
redressal and an increase in the conviction rate. Women themselves should be made aware of their  
right to a safe and harassment-free work environment. The concept and definition of sexual harassment  
and range of punishments should be clearly laid down in service books of all industries, enterprises  
and government bodies and the redressal mechanism made known to women in each and every  
sector of the economy. Structures and mechanisms should also be created for women in the  
unorganised/informal sector to combat SHW. Despite bold judgments by the Supreme Court and The  
Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013,  
there is no sexual harassment complaints committee at most workplaces, even in the government  
sector. The apex court must direct the various workplaces to form sexual harassment committees  
within a stipulated time frame.  
In any civilised society, it is the fundamental right of people to be able to lead their lives with dignity,  
free from mental or physical torture. To ensure this, transgressors must pay for their unsolicited sexual  
advances. At the same time organisations such as Men Against Violence and Abuse, that conduct  
gender-sensitisation programmes and self-defense classes to combat sexual harassment at the  
workplace, must be encouraged (Sadani, 2003). To effectively prevent SHW we need both a top-down  
initiative by the state and employers and pressure from civil society- from working women, citizens’  
groups, women’s organisations and trade unions.  
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Sexual Harassment, University of Delhi.  
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Dalal, Sucheta (2003), ‘Bias in the Boardroom’, The Sunday Express, May 18.  
FAOW (1991), ‘Moving...But Not Quite There — Evaluation Report of One Decade 1980-1990’,  
Forum Against Oppression of Women, Mumbai.  
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Groping, Lecherous Advances Made by Male Colleagues at the Workplace’,The Indian Express,  
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Contemporary India: A Reader, Sage Publications.  
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June 15, 2003.  
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in collaboration with Ghanshyamdas Saraf Girls’ College, University of Mumbai.  
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Education and Extension, University of Mumbai  
Prof. Vibhuti Patel : Head of the P.G. Dept. of Economics, SNDT Women’s University, Mumbai