Constitution of Internal Committees by Organised Sector for Attending to Sexual Harassment Complaints

 

Article

Constitution of Internal Committees by Organised Sector for Attending to Sexual Harassment Complaints

 

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 provides for constitution of two types of committees to attend to complaints of sexual harassment at work place –

 

a)    Internal Committee for “organised sector”; and

b)    Local Committee for “unorganised sector”.

 

The unorganised sector in relation to a workplace includes enterprise owned by individuals or self-employed workers and engaged in the production or sale of goods or providing service of any kind whatsoever, and where the enterprise employs workers, the number of such workers is less than ten.

 

Responsibilities of Complaints Committee: The complaints committee has to effectively address sexual harassment complaints at workplace by following the due process of law and giving each party an opportunity to present its case and a chance to be heard. The members of the committee must be well versed about the provisions of the Act, Rules, and Regulations for conducting a fair enquiry. The members should keep themselves abreast with latest judgements of various courts, decisions of Central Information Commission, amendments in laws and rules, etc. The committee should ensure that parties are made aware of the process and their rights and responsibilities under the Act.

 

Constitution of Internal Committee: All employers of organised sector are required to constitute a committee to be known as the "Internal Committee" in compliance with section 4 of the Act for attending to sexual harassment complaints. The committee should be constituted in writing. The internal committee shall be constituted at all administrative units or offices, including the workplace as are located at different places or divisional or sub-divisional level. Failure to set up such a committee is a non-cognizable offence. 

 

Deemed Committee for Members of All India Services: The complaints committee established in each Ministry or Department or Office for inquiring into sexual harassment complaints, shall be deemed to be the inquiring authority appointed by the disciplinary authority for the purpose of these rules in respect of members of All India Services[1].The complaints committee shall hold, if separate procedure has not been made for the complaints committee for holding the inquiry into the complaints of  sexual harassment, the inquiry as far as practicable, in accordance with the procedure laid down in these rules.

 

Constitution of Committee: The committee shall be headed by a Presiding Officer and shall have at least two Members from amongst employees preferably committed to the cause of women or who have had experience in social work or have legal knowledge. It should have one member from amongst non-governmental organisations or associations committed to the cause of women or a person familiar with the issues relating to sexual harassment. At least fifty per cent of the total nominated members shall be women.  In case a senior level woman employee is not available, the Presiding Officer shall be nominated from other offices or administrative units of the workplace. 

 

Tenure of office: The Presiding Officer and every Member of the internal committee shall hold office for such period as mentioned in his nomination letter but it shall not exceed three years, from the date of their nomination. Modifications in the constitution of the committee should be made promptly, when due.

 

Remuneration: The Members appointed from amongst the non-governmental organisations or associations shall be paid such fees or allowances for holding the proceedings of the internal committee, by the employer, as are prescribed under the Rules.

 

Removal of Presiding Officer or Member: The Presiding Officer or any Member of the internal committee can be removed on any of the following grounds-

 

·    contravenes the provisions relating to prohibition of publication or making known the contents of complaint and enquiry proceedings ; or

·      has been convicted for an offence or an inquiry into an offence under any law for the time being in force is pending against him; or

·     he has been found guilty in any disciplinary proceedings or a disciplinary proceeding is pending against him; or

·      has so abused his position as to render his continuance in office prejudicial to the public interest.

 

Section 4 of the Act reads as under:

 

“4. Constitution of Internal Committee.— (1) Every employer of a workplace shall, by an order in writing, constitute a Committee to be known as the “Internal Complaints Committee”:

Provided that where the offices or administrative units of the workplace are located at different places or divisional or sub-divisional level, the Internal Committee shall be constituted at all administrative units or offices.

(2) The Internal Committees shall consist of the following members to be nominated by the employer, namely: —

(a) a Presiding Officer who shall be a woman employed at a senior level at workplace from amongst the employees:

Provided that in case a senior level woman employee is not available, the Presiding Officer shall be nominated from other offices or administrative units of the workplace referred to in sub-section (1):

Provided further that in case the other offices or administrative units of the workplace do not have a senior level woman employee, the Presiding Officer shall be nominated from any other workplace of the same employer or other department or organisation;

(b) not less than two Members from amongst employees preferably committed to the cause of women or who have had experience in social work or have legal knowledge;

(c) one member from amongst non-governmental organisations or associations committed to the cause of women or a person familiar with the issues relating to sexual harassment:

Provided that at least one-half of the total Members so nominated shall be women.

(3) The Presiding Officer and every Member of the Internal Committee shall hold office for such period, not exceeding three years, from the date of their nomination as may be specified by the employer.

(4) The Member appointed from amongst the non-governmental organisations or associations shall be paid such fees or allowances for holding the proceedings of the Internal Committee, by the employer, as may be prescribed.

(5) Where the Presiding Officer or any Member of the Internal Committee, —

(a) contravenes the provisions of section 16; or

(b) has been convicted for an offence or an inquiry into an offence under any law for the time being in force is pending against him; or

(c) he has been found guilty in any disciplinary proceedings or a disciplinary proceeding is pending against him; or

(d) has so abused his position as to render his continuance in office prejudicial to the public interest, such Presiding Officer or Member, as the case may be, shall be removed from the Committee and the vacancy so created or any casual vacancy shall be filled by fresh nomination in accordance with the provisions of this section.

 

Knowledge, Skills, Training: Dealing with workplace sexual harassment complaints is often complex. Hence complaints committee/s must possess critical skills/capacity to effectively carry out their role. That includes a sound grasp of the Act, Vishaka Guidelines, applicable Service Rules, relevant laws and an understanding of workplace sexual harassment and related issues. Complaints committee skills must include an ability to synthesize information i.e. relevant documents, the law and interviews.

 

They should also be able to communicate effectively, write clearly, listen actively and conduct interviews. They should be competent at showing empathy, being impartial and being thorough. They should be able to identify sexual harassment and its impact. 

Complaints committee is required to be trained in both skill and capacity to carry out a fair and informed inquiry into a complaint of workplace sexual harassment. In absence of such training will lead to unequal and unfair results, which can cost employers, employees, complainants as well as respondents.

 

Sexual Harassment Rules: The Government of India has notified Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013 for proper implementation of the Act and regulating fees etc.

 

Rule 3 lays down the entitlement of allowances payable to Members appointed from amongst nongovernment organisations. They shall be entitled to an allowance of two hundred rupees per day for holding the proceedings of the internal committee and also reimbursement of travel cost incurred in travelling by train in three tier air condition or air conditioned bus and auto rickshaw or taxi, or the actual amount spent by him on travel, whichever is less. 

Rule 4 lays down criteria for appointment of persons familiar with the issues relating to sexual harassment etc. For the purpose of this Act person familiar with the issues relating to sexual harassment shall be a person who has expertise on issues relating to sexual harassment. He or she may be a social worker with at least five years’ experience in the field of social work which leads to creation of societal conditions favourable towards empowerment of women and in particular in addressing workplace sexual harassment. A person who is familiar with labour, service, civil or criminal law can also be appointed as a Member.

Bombay High Court Judgement: The Bombay High Court ruled that it would not interfere with an order of punishment passed by the Internal Complaints Committee in relation to a sexual harassment complaint, unless the order is shockingly disproportionate. The Court referred to its decision in Om Kumar v Union of India and reaffirmed the principles of judicial restraint to be exercised by courts under Article 226 of the Constitution. The Court held that unless the Order is shockingly disproportionate to the act of the delinquent employee, it will be circumspect in interfering with the Order[2].



[1] Vide Notification dated 18th June, 2014

[2] Vidya Akhave v. Union of India and Ors

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