POSH India Help LogoPOSH India Help
Skip to section overview

Chapter II · Internal Committee

Section 4

Constitution of Internal Committee

Section OverviewPending legal verification
Every employer of a workplace shall, by an order in writing, constitute a Committee to be known as the Internal Complaints Committee:
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 every administrative unit or office.
The Internal Committee shall consist of the following members to be nominated by the employer, namely:—
a Presiding Officer who shall be a woman employed at a senior level at the workplace from amongst the employees:
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);
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 within the district where the office is located;
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;
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 one-half of the total Members so nominated shall be women.
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.
The Presiding Officer or any Member of the Internal Committee shall, notwithstanding the expiry of the period specified under sub-section (3), continue to hold office until the new Presiding Officer or Member, as the case may be, is nominated.
The employer shall, while nominating Members under sub-section (2), take into account the following provisions, namely:—
one-half of the total Members shall be women;
the Presiding Officer and all the Members shall be the employees of the organisation;
the Members other than those referred to in clauses (a) and (b) shall be drawn from persons familiar with the issues relating to sexual harassment and may be from non-governmental organisations or associations committed to the cause of women or any other person familiar with the issues relating to sexual harassment.
The Internal Committee or the Local Committee, as the case may be, shall have the same powers as are vested in a civil court under the Code of Civil Procedure, 1908 when trying a suit in respect of the following matters, namely:—
summoning and enforcing the attendance of any person and examining him on oath;
requiring the discovery and production of documents; and
any other matter which may be prescribed.
The employer shall provide necessary facilities to the Internal Committee for dealing with the complaints and conducting inquiries.
The Internal Committee shall make an annual report to the employer and the District Officer regarding the number of cases filed and disposed of.

Temporary structural and explanatory content only; it is not a verbatim reproduction. Complete statutory text and legal commentary will be integrated after separate legal verification.

Plain Language

Every employer with ten or more workers must create an Internal Committee (IC) by written order. This is not optional and not deferred until a complaint arises.

The IC must be led by a senior woman employee as Presiding Officer. If no senior woman is available at that office, the employer must look to other units or even other workplaces in the same district.

The committee must include at least two employee members, one external member from an NGO or association focused on women's issues, and at least fifty percent women overall.

The external member is a structural requirement, not a consultant who can be added later. The committee does not legally exist without proper composition.

Why It Matters

Without a properly constituted IC, the employer cannot lawfully receive or process complaints of sexual harassment. The complaint mechanism itself depends on correct composition.

The external member serves as an independent check. Without one, any inquiry outcome could be challenged on procedural grounds.

The gender balance requirement ensures that the committee is not dominated by members who may not fully understand the complainant's perspective.

The written order requirement creates an auditable compliance record. Verbal nominations are insufficient.

Practical Example

Presiding Officer fallback

Scenario: A company with 15 employees in Mumbai has no woman in a senior role. Their only senior employees are men.

Outcome: The employer must nominate a Presiding Officer from another office or administrative unit of the same organisation, or from another workplace of the same employer within the district.

Scenario: An employer forms a three-person committee with two male employees and one female HR manager, with no external member.

Outcome: This committee is not validly constituted. It fails on two counts: no external member and less than fifty percent women. Any inquiry conducted by this committee can be challenged.

Scenario: A start-up with 12 employees argues it does not need an IC because it has never received a complaint.

Outcome: The duty to constitute an IC arises from the headcount, not from having received a complaint. The committee must exist before any complaint is filed.

Who Must Act

employer

  • Constitute the Internal Committee by written order at each office or administrative unit.
  • Nominate a senior woman employee as Presiding Officer, using the fallback chain if necessary.
  • Ensure at least two employee members and one external member from an NGO or association.
  • Ensure at least fifty percent of total members are women.
  • Provide necessary facilities for the IC to handle complaints and conduct inquiries.
  • Nominate replacement members before existing terms expire to avoid a gap in committee validity.

ic member

  • Hold office for a term not exceeding three years unless a successor is nominated.
  • Understand that the IC has civil-court-style powers for summoning, oath, and document production.
  • Cooperate in preparing the annual report to the employer and District Officer.

employee

  • Understand that the external member is a legal requirement, not an optional advisor.
  • Know that the IC's composition can be challenged if it does not meet statutory requirements.

Compliance

Constitute IC by written order at each office or administrative unit

Actor: Employer · Rule: Section 4(1)

Nominate a Presiding Officer who is a senior woman employee

Actor: Employer · Rule: Section 4(2)(a)

Include at least two employee members in the IC

Actor: Employer · Rule: Section 4(2)(b)

Include at least one external member from an NGO or association committed to the cause of women

Actor: Employer · Rule: Section 4(2)(c)

Ensure at least fifty percent of total members are women

Actor: Employer · Rule: Section 4(2)(c) proviso, Section 4(5)(a)

Provide necessary facilities to the IC for dealing with complaints and conducting inquiries

Actor: Employer · Rule: Section 4(7)

Submit annual report to employer and District Officer on cases filed and disposed of

Actor: IC · Rule: Section 4(8)

Timelines

IC member tenure: Up to 3 years

The Presiding Officer and every member hold office for a period not exceeding three years from the date of nomination.

Continuation until replacement: Until successor nominated

Members continue to hold office beyond their term expiry until a new Presiding Officer or Member is nominated.

Annual report: Every calendar year

The IC must make an annual report to the employer and the District Officer regarding cases filed and disposed of.

Common Mistakes

Assuming a company with fewer than ten workers needs an IC — the IC threshold is ten or more workers; smaller workplaces use the Local Committee route.

Treating the external member as optional or substituting an internal HR person in that role.

Nominating only male employee members and arguing the Presiding Officer counts toward the fifty percent women requirement — she does, but the total must still be at least fifty percent women.

Constituting one IC for an organisation with multiple offices spread across different locations — each administrative unit or office needs its own IC or documented coverage arrangement.

Allowing IC member terms to lapse without nominating successors — the statute provides for continuation, but indefinite gaps create legal risk.

Verbal nomination without a written order — the statute requires an order in writing.

Source & Status

This page contains temporary structural and explanatory content, not a verbatim reproduction of the Act.

Source: Ministry of Law and Justice, Government of India

Publication status: Temporary content pending separate legal verification