New Delhi, [India], August 20, 2025: The Indian Council of Industrial Management (ICIM) has strongly welcomed the Supreme Court’s directive mandating a nationwide, time-bound six-week survey to verify the constitution and functioning of Internal Committees (IC) — formerly known as Internal Complaints Committees (ICC) — in all Government and Private institutions across every district in India.
The Supreme Court’s order comes against the backdrop of persistent concerns that even after more than a decade of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (PoSH Act) coming into force, compliance in several sectors remains patchy.
The Court’s Directions
As per the order, Labour Commissioners in each district and Chief Labour Officers in every state are required to promptly provide the Deputy Commissioners (or equivalent officials) with a complete list of all registered entities within their jurisdiction. This information will form the foundation for a district-wise verification drive to ascertain whether Internal Committees have been duly constituted in accordance with statutory provisions.
The Bench further issued a stern oral warning: any failure to comply with these directions could result in the Labour Department being ordered not to renew the licenses of defaulting entities. This is one of the rare occasions where the country’s highest court has explicitly linked PoSH Act compliance to business license renewals — underscoring the seriousness of the issue.
ICIM’s Response
Reacting to the development, ICIM Chairman Satendra Singh called the decision “a long-overdue enforcement measure that finally aligns the spirit of the law with concrete action on the ground.”
“The PoSH Act is not merely a formality; it is a lifeline for workplace safety and dignity. Unfortunately, in many organisations, especially in small and medium sectors, Internal Committees are either non-existent or are formed only on paper. The Supreme Court’s proactive intervention is a much-needed wake-up call to all employers,” Mr. Singh said.
He stressed that while the legislation is clear in its mandate, the enforcement mechanisms have historically been weak, allowing non-compliance to go unchecked. This survey, if conducted with transparency and backed by follow-up action, could mark a turning point.
ICIM’s Recommendations for Effective Implementation
- Comprehensive & Accurate Data Collection
Labour Departments must ensure that the entity lists provided to Deputy Commissioners are updated, complete, and verified. Outdated or incomplete records would undermine the purpose of the survey.
- Widespread Awareness Drives
The survey should be complemented by state-wide awareness campaigns explaining PoSH obligations in simple, practical terms — particularly targeting schools, colleges, small industries, and rural enterprises.
- Enforceable Penalties
The Court’s warning on non-renewal of licenses must be strictly implemented, with timelines for rectification clearly specified to prevent prolonged delays.
- National Public Registry of Internal Committees
ICIM proposes the creation of a centralised, publicly accessible database of Internal Committees, listing their formation date, member details, and training status. This would empower employees and enhance transparency.
- Periodic Compliance Audits
Beyond the one-time survey, annual or bi-annual audits should be mandated to ensure continued compliance and to detect dormant or non-functional committees.
ICIM’s Commitment to Support the Initiative
Mr. Singh reaffirmed ICIM’s readiness to work alongside government agencies, offering the Council’s expertise in training, compliance audits, and awareness-building.
“Workplace safety and dignity are not optional checkboxes — they are constitutional rights,” he asserted. “ICIM can provide PoSH training for committee members, assist employers in forming compliant Internal Committees, and conduct third-party compliance verifications. Our goal is to make compliance easier to understand and implement while ensuring accountability.”
He further added that this survey should not be treated as a mere administrative exercise but as an opportunity to create a long-term culture of safety and respect in workplaces.
Why This Matters
The PoSH Act, enacted in 2013, mandates that any workplace with ten or more employees must constitute an Internal Committee with at least four members, including a senior woman employee as Presiding Officer and an external member with expertise in women’s rights or related issues. The absence of a functional IC directly violates the law and leaves employees without a formal redressal mechanism for sexual harassment complaints.
Several studies and audits over the years have revealed that a significant percentage of organisations — especially in the unorganised and semi-organised sectors — have failed to meet even the basic requirements under the Act. By tying compliance directly to licensing, the Supreme Court’s order has introduced a powerful incentive for employers to act without delay.
About ICIM
The Indian Council of Industrial Management is a leading national body dedicated to promoting workplace safety, compliance, and capacity-building across industries. Through its network of experts, ICIM provides training in PoSH compliance, Occupational Health & Safety, Environmental Governance, and other critical workplace standards.
