In the case concerning Manjeet Singh and Indraprastha Gas Limited in the Delhi High Court, the controversy emerged within Indraprastha Gas Limited, a public sector joint venture engaged in the distribution of natural gas

CS Professional · Labour Laws and Practice · PYQS · June 2026
In the case concerning Manjeet Singh and Indraprastha Gas Limited in the Delhi High Court, the controversy emerged within Indraprastha Gas Limited, a public sector joint venture engaged in the distribution of natural gas. Complainant served as Senior Executive Secretary to the Vice President (HSE & JV). On 26 January 2016, following the Republic Day celebrations organized by the company, she visited her superior's office to attend to routine professional responsibilities. During this time, Mr. Singh, who occupied a senior managerial position, was also present. It was alleged that during the interaction he made remarks praising the attractiveness of foreign women while making disparaging comparisons with Indian women, comments that caused significant discomfort to the Complainant. The situation escalated when Mr. Singh insisted on capturing her photograph on his mobile phone despite her reluctance and, according to the allegations, attempted to embrace her without consent, an act she perceived as an intrusion upon her personal dignity and professional boundaries. Initially, Complainant discussed the incident informally with certain colleagues and members of the Human Resources Department but refrained from immediately filing a formal grievance. However, the experience continued to cause emotional distress, prompting her upon encouragement from co-workers to submit a written complaint to the Managing Director of the company on 8 February 2016. Acting in accordance with the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, the organization constituted an Internal Complaints Committee (ICC) to examine the allegations. The Committee undertook a formal inquiry, recording the statements of the complainant, the accused officer, and certain individuals who were considered relevant witnesses in the matter. Upon completion of its inquiry, the ICC concluded that although the conduct of Mr. Singh might not have been deliberately pre-planned, his behavior displayed a "flirtatious" character that exceeded the acceptable limits of workplace decorum. The Committee determined that the acts complained of constituted sexual harassment within the meaning of the POSH Act. Based on the findings of the ICC, the disciplinary authority imposed a major penalty by demoting Mr. Singh from the position of Vice President to that of Chief General Manager. His departmental appeal challenging the decision was subsequently rejected, thereby affirming the disciplinary sanction imposed by the employer. Aggrieved by these outcomes, Mr. Singh approached the Delhi High Court, challenging both the procedural propriety of the ICC inquiry and the legality of the disciplinary measures. He argued that the inquiry process had violated the principles of natural justice because he was not permitted to cross-examine the complainant, and further contended that the allegations lacked independent corroborative evidence. The High Court scrutinized the procedural framework governing inquiries under the POSH Act and ultimately concluded that the proceedings were vitiated due to the denial of an opportunity to cross-examine the complainant. Such denial, the Court held, undermined the fairness of the inquiry and prevented effective testing of the allegations. Observing also the absence of sufficient corroborative material, the Court set aside the ICC report as well as the disciplinary and appellate orders arising from it, emphasizing that inquiries under the statute must strictly adhere to procedural fairness and safeguard the rights of all parties involved. Based on the facts of the case, answer the following (a, b & c) questions: Critically analyze the scope and limits of the powers of the Internal Complaints Committee (ICC) under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 in the context of the judicial review exercised by the Delhi High Court.

Answer & Explanation:

The Internal Complaints Committee (ICC) established under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 functions as a quasi-judicial body entrusted with the responsibility of investigating allegations of workplace sexual harassment. Its role includes examining complaints, recording statements, evaluating evidence, and recommending disciplinary measures to the employer. However, its powers are not absolute and must be exercised in accordance with the principles of procedural fairness and natural justice. In the case involving Manjeet Singh and Reena Mohanty, the Delhi High Court scrutinized whether the ICC had adhered to these procedural safeguards. The Court observed that although the ICC has autonomy in conducting inquiries, it must still ensure fairness to both parties. Denial of the opportunity to cross-examine the complainant undermines the credibility of the inquiry process. The Court further emphasized that ICC proceedings should maintain transparency, impartiality, and evidentiary reliability. Any deviation from these procedural standards may render the findings legally unsustainable. Consequently, the Court reaffirmed that ICC decisions are subject to judicial review where procedural irregularities occur. This ruling illustrates that while the ICC plays a vital role in protecting employees, its actions must remain consistent with established legal principles. The ICC is a mechanism put in place to assist women who complain of sexually harassment at their place of work. Nevertheless, it is equally important that the goodwill, fair name and dignity of an innocent accused be dealt with the utmost care. An accused/ charged officer must be presumed to be innocent until there is evidence to show otherwise. The dignity of neither party can be trifled with in an inquiry proceedings.

Topics: Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act)

Open in Interactive Practice Hub · Full Practice Hub · Chapter Weightage · More in this subject

Related Questions in this Topic