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. Discuss the evidentiary standards applied by the Delhi High Court while reviewing the findings of the Internal Complaints Committee in the case cited above.

Answer & Explanation:

While reviewing the matter, the Delhi High Court assessed whether the conclusions reached by the Internal Complaints Committee (ICC) were supported by credible and sufficient evidence. The Court noted that the allegations primarily rested on the statement of the complainant without substantial corroboration from independent witnesses. Although workplace harassment inquiries do not require proof beyond reasonable doubt, there must still be a reasonable evidentiary basis supporting the conclusions. The Court examined the testimonies recorded by the ICC and observed certain inconsistencies in the narrative presented during the inquiry. It also considered whether the available evidence could reasonably establish misconduct by Mr. Manjeet Singh. The absence of corroborative testimony or supporting material weakened the evidentiary foundation of the Committee's findings. In administrative proceedings, conclusions must still be grounded in logical and credible material. The Court therefore found that the ICC's determination lacked adequate evidentiary support. This deficiency, combined with procedural irregularities, undermined the legitimacy of the inquiry. As a result, the disciplinary actions imposed by the employer were set aside. The judgment underscores the necessity of evidentiary reliability even in internal workplace investigations.

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

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