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Critical Analysis Of The Prevention Of Sexual Harassment At Workplace Act {Posh} 2013- The Need For A Shift Towards Gender Neutrality?
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Critical
Analysis Of The Prevention Of Sexual Harassment At Workplace Act {Posh} 2013-
The Need For A Shift Towards Gender Neutrality?
Authored By -
Manvi Kishore
and Arnold
Stanley
ABSTRACT
Sexual harassment at work in India is
handled by the Sexual Harassment of Women at Workplace (Prevention, Prohibition
and Redressal) Act, 2013 (POSH Act), a women-specific law created to prohibit
sexual harassment at work specifically against women. The POSH Act doesn't
protect other genders from sexual harassment; hence this paper advocates for
gender-neutral laws. Industrialization and globalization have boosted women's
workforce participation and contribution, therefore preventing sexual
harassment has become more important in the last 25 years. Sexual harassment
violates women's rights to equality and dignity at work. It stunts her career,
traumatizes her mentally and physically. With sexual harassment complaints
going unreported and investigations not being done, the POSH Act is widely
unknown and rarely followed. This paper analyses the Act's provisions and
shortcomings through a gender-neutral approach where the act is silent on and
poses challenges in is implementations.
KEYWORDS-POSH, Sexual Harassment,
Gender-neutral, Legislation, Apex Court.
INTRODUCTION
Gender-based discrimination in the
workplace has always been a problem for women. Another major issue that
prevented women from entering the workforce of the country was sexual
harassment of women in the workplace. An anti-discrimination law, the POSH Act of
2013, was passed to protect women from harassment and unfair treatment in the
workplace. A major question raised by the POSH Act was whether it was gender
biased, even though the legislation was designed to protect women from sexual
harassment. The POSH Law only protects women, thus other genders have no
recourse if they are harassed in the workplace. The POSH legislation has failed
to develop a free society that adheres to norms of right to equality because of
an increase in malicious POSH complaints, according to recent trends. While
dismissing a bogus sexual harassment allegation in 2018, the Delhi High Court
stated that women cannot be treated as "innocent naive victims"
during investigation. It is still widely accepted that the POSH Act is an
important law to ensure a safe workplace for women. POSH law may have stricter
provisions for dealing with false instances, but it is still an exaggeration to
argue that it has not had a good influence or sparked a debate about the
necessity of gender equality in society. This POSH act's influence on women's
welfare can't be denigrated by the fact that other genders have no recourse for
reporting sexual harassment.
With the onset of the COVID-19
pandemic, which has led to the Ministry of Home Affairs (MHA) issuing orders
prescribing nationwide lockdowns, there have been several questions raised
about the whether it can be put into practice, as well as the process by which
sexual harassment charges are decided. Currently, the Sexual Harassment of
Women at Work Act governs most cases of workplace sexual harassment. Workplace
(Prevention, Prohibition, and Redressal) Act, 2013 legislation aimed at
protecting women from sexual harassment in the workplace was passed
specifically for female employees only. The POSH Act takes a narrow view, as it
does not address or provide protection from. In India, men and women of both
sexes may be subjected to workplace sexual harassment. India's attitude to
gender-neutral laws and its attempts to
define sexual harassment are examined in this paper. A breach of human and
constitutional rights; a critical examination of the concept of gender that
perpetuate the idea of a dichotomy between men and women through this sexual
harassment legislation in India is a glaring omission. As such India's current
workplace sexual harassment regulations should be revised. Males and non-binary
genders need to be adequately safeguarded.
OVERVIEW OF POSH ACT 2013
Women and Child Development Minister,
Krishna Tirath, reportedly said in December 2012 that the government would
launch a study on
“What kind of (sexual) harassment of
males is prevalent at workplaces”[1]
while answering queries on whether or
answering queries on whether the Sexual Harassment of Women at Workplace Bill,
2010 would include male employees.[2] A
reading of its Statement of Purpose clearly demonstrates that the Bill was
drafted with the goal of creating a legislation that would only apply to female
employees. According to SCR of the 239th Parliamentary Standing Committee,[3]
"Sexual harassment in a workplace is deemed violation of women's right to
equality, life, and liberty. It fosters an environment of fear and hostility in
the workplace, which deters women from working and undermines their social and
economic empowerment as well as the goal of inclusive growth.[4] To
ensure that every woman, regardless of her age or employment status (except for
domestic workers working at home), is protected from all forms of sexual
harassment, a comprehensive legislation should be enacted to lay the responsibility
on the employer, the District Magistrate or Additional District Magistrate or
Deputy Collector of every District in the State as a District Officer and to
lay the groundwork for an investigation. The primary issue about the POSH Act's
gender-specific nature were made when addressing concerns about the inclusion
of men in the legislation. To assume that women are solely victims of sexual
harassment is erroneous.
Since it is impossible to say that
only women are subjected to sexual harassment and that harassment of men cannot
be placed on an equal footing in terms of character or frequency, there is no
data to support the Ministry's claim that only women are subjected to it.
Sexual harassment legislation in most nations, such as Denmark, the United
Kingdom, Italy, Ireland, Finland, France, Germany, Portugal, Spain, and the
Netherlands, are gender neutral. This is justified by claiming that women bear
the majority brunt in terms of harassment, and thus, a gender-specific
legislation on sexual harassment at work should be regarded an affirmative
action under Article 15 of the Constitution of India 1950
("Constitution"). A survey or study is required, as well, according
to the SCR; alternatively, a company may be required to disclose incidents of
male sexual harassment as well. According to the SCR, only women are victims of
workplace sexual harassment, which is based on poor and illogical reasoning.
A reading of its Statement of Purpose
clearly demonstrates that the Bill was drafted with the goal of creating
legislation that would only apply to female employees. According to SCR of the
239th Parliamentary Standing Committee, sexual harassment in a workplace is
deemed violation of women's right to equality, life, and liberty. It fosters an
environment of fear and hostility in the workplace, which deters women from
working and undermines their social and economic empowerment as well as the
goal of inclusive growth. To ensure that every woman, regardless of her age or
employment status (except for domestic workers working at home), is protected
from all forms of sexual harassment, a comprehensive legislation should be
enacted to lay the responsibility on the employer. The District
Magistrate/Additional District Magistrate or Deputy Collector of every District
in the State as a District Officer should be empowered to lay the groundwork
for an investigation.[5]
JUDICIAL INTEPRETATION OF POSH ACT
2013
In the case of Vishaka v.
Rajasthan (1997)[6]
for the first time, the Supreme Court acknowledged the idea of workplace sexual
harassment, which is defined by the CEDAW treaty. It outlined principles to be
followed until legislation was enacted to address the issue. The POSH Act now
incorporates these standards; however, its execution has been generally
unsuccessful, which we will address in the following sections to come.
In Apparel Export Promotion
Council v A.K. Chopra (1999)[7]
reported that a secretary was assaulted by another employee who was her
immediate superior. An uninvited sexual act was found to constitute sexual
harassment in this case. A request for sexual favours or other verbal or
non-verbal conduct with a sexual undertones, if the acceptance or rejection of
these overtures has ramifications for the woman's employment. The court also
noted that sexual harassment has the consequence of creating a hostile work
environment, which negatively impacts a woman's performance. Gender equality
and the right to life and liberty are clearly violated by this. the necessity
of international cooperation was also emphasized in the decision coping with
this problem, treaties and agreements are essential.
When the Supreme Court of India ruled
in Medha kotwal lele v Union of India (2012)[8]
that all states and union territories must update their civil service codes to
include sexual harassment, it had a significant influence on workplace sexual
harassment. The Vishaka judgement’s complete implementation was thereafter
mandated by the State and the commercial and public sectors alike and that the
victim will not be forced to work with or under an accused if they are proven
guilty. Disciplinary action was also ordered against the accused in the event
that witnesses, or complainants were intimidated. The court ruled that the
Vishaka guidelines should be implemented in both substance and spirit.
In Punjab and Sind Bank and
Others v Mrs Durgesh Kuwar and Others (2020)[9]
a complaint of sexual harassment filed against another officer resulted to the
victim's transfer after she uncovered corruption and irregularities at her
branch. Her transfer was reversed because the court found that sexual
harassment violated women's equality rights by Articles 14 and 15, as well as
her right to life and liberty guaranteed by Article 21 and her right to engage
in any profession, trade, or business. Commenting on her current circumstances
"This is indicative of a reward and stick approach," the judge who
oversaw the transfer stated. The Supreme Court rulings on sexual harassment in
the workplace have repeatedly emphasized the importance of putting right
systems in place, but things haven't changed much.
REACTIONS IN INDIA TO GENDER
NUTRALITY-EVALUATING IMPORTANT CHANGES
A.
RECENT DEVELOPMENTS
A case involving rape and gender
neutrality was first brought up in Sudesh Jhaku v. KC Jhaku[10],
where it was stated that “men who are sexually abused will have the same
protection as female victims, and women who sexually assault men or other women
should be held to the same standards as conventional rapists," Justice
Jaspal Singh said in an opinion piece in the Indian Express. Raped women's
rights advocates argue that by defining rape as an assault on a woman rather
than a specific offence targeting women, rape law can be put in a healthier
context and mythological components can be reduced.
As a result of the 172nd
Law Commission's recommendations[11],
the Criminal Law Amendment Bill, 2012[12]
advocated the inclusion of a gender-neutral definition of rape in the bill. The
Justice Verma Committee (JVC) [13]
was formed after the Nirbhaya gangrape incident to investigate possible changes
in criminal law provisions that would allow for faster trials and harsher
penalties for those who commit sexual assaults of extreme nature on women. This
legislation, however claiming to follow the Supreme Court ruling in Vishakha
v State of Rajasthan, does not fully reflect its spirit, according to the
JVC's opinion. Despite the JVC's approval of Section 2(n) of the Sexual
Harassment of Women at Workplace Bill, 2012, the JVC advised that the offence
of rape be made gender neutral. UGC sexual harassment laws, published in May
2016, mandate that universities take decisive action against all forms of
gender-based violence. (Hereinafter referred to as the "UGC Sexual
Harassment Regulations").[14]
Any "aggrieved individual"
can file a sexual harassment complaint under the UGC Sexual Harassment
Regulations instead of just an "aggrieved woman" under the POSH Act.
To make a complaint of sexual harassment, students can use the UGC Sexual
Harassment Regulations, which cover students of both genders. Two petitions
were filed in the Supreme Court of India in 2018 arguing that the Indian Penal
Code, 1860's Sections 354, 354A, 354B, 354C, 354D, and 375 are unconstitutional
and should be repealed.[15]
However, both were ruled out because of their incapacity to be maintained.
After issuing a notice, the Delhi High Court dismissed a plea alleging that
Sections 375, 376, 376D, 354A, 354C, and 354D of the IPC breached fundamental
human rights and deprived people's access to gender neutral laws, therefore
violating Articles 20(1), 14 and 21 of the Constitution in violation. As a
result of this, a petition to change certain provisions of India's constitution
was thrown out by the Supreme Court since it did not have any merit.[16]
B. INADEQUATE STATISTICS FOR HARASSMENT OF MALE AND OTHER
GENDERS
There are no official statistics on
male harassment or gender-based stereotypes. A study by Centre for Civil
Society indicated that out of ninety-six nations, six had partially
gender-neutral legislation on rape or sexual assault and sixty-three had laws
stated in gender neutral terminology. Eighteen percent of men surveyed by the
Delhi-based Centre for Civil Society reported being compelled or forced to
engage in sex.[17] Whereas
Sixteen percent of the victims identified a female attacker, whereas just two
percent identified a male perpetrator.[18] When sexual harassment is defined in terms of
the male or female paradigm, it not only assigns a certain gender to the victim
and perpetrator, but also the various prejudices that go with it. One theory
holds that men are or should be masculine, while women are or should be
feminine, and that these concepts are inextricably related.[19] By eliminating sexist assumptions about men
and women, gender neutrality may help us move past the idea that women are
always the weaker party. Secondly, the absence of statistical data does not
mean that such incidents do not take place.[20]
Due to the hegemonic masculinity and non-gender neutrality of the POSH Act, no
official statistics exist. Although forcible sexual assaults by females upon
males are undoubtedly less common than those by males onto females this
numerical disparity cannot by itself make it permissible for the state to
punish.[21]
C. TRANSGENDERS AND POSH
People who identify as transgender,
or "TG," are often referred to as those who have gender
identification issues. There is a discrepancy between how they present
themselves and their biological sex. Persons with TG can also be included.
Hijras and eunuchs who do not identify with the gender they were assigned at
birth. None of these people identify with either male or female. There are a
few hijras that don't believe in God. A group of men who have been castration
(aka nirvana) or akva/akka castrated (non-emasculated men) (hermaphrodites).
Sex Re-Assignment patients are also included in TG.[22]
As a result of their gender identification, these individuals have undergone
surgery (SRS) or are currently undergoing SRS to change one's sex Transsexuals
are commonly referred to as such. In addition, there are individuals.
transvestites are those who enjoy dressing in attire of the opposite sex. This
led to a change in the name of the phrase today, "transgender" is
used as an umbrella term to represent a wide range of people. A wide range of
identities and experiences, including but not limited to transsexual people who
strongly identify with the gender opposite to their biological sex; masculine
and both male and female are included.[23]
In the NALSA judgement[24],
the Supreme Court in support of transgender/third-gender individuals' rights,
laid down the rules stating that Articles 14, 15, 16, 19, and 21 of the Indian
Constitution do not preclude
hijras/transgender people from their scope of application. It was the case that it was also in general, the
Indian legal system is aware of the binary genders of male and female,
according to this statement. The gender is ascribed to a person at birth. The
legal system also reflects the binary conception of gender where adoption,
marriage, and other family-planning practices are all governed by specific
laws. Not being able to accept Hijras/transgenders are denied equal protection
of the law because of their distinct legal status they are subjected to intense
skepticism.[25]
Because of this, it was concluded
that the term discrimination based on sexual orientation or gender identity
encompasses any preference or exclusion based on race, gender, or other
characteristics that has the impact of under our constitution, ensuring equal
protection of the law in order to protect the Constitution.[26]
Members of the Transgender community have constitutional rights the primary
right being the legal right to be recognized as a third gender was in fact
debated by the Supreme Court asserting that a person's gender identity is
fundamental to their "personality".
Self-determination and autonomy are synonyms. Hijras/eunuchs, then,
would be the third group to consider gender, which goes beyond the
constitutional and legal definitions of binary gender.
D.SEXUAL HARASSMENT AGAINST GENDERS
UNDER LGBQA+
There are no explicit provisions in
the Indian sexual harassment legislation to protect those who identify as Gay,
Bisexual, Queer or Asexual, or those who do not identify as heterosexuals from
being harassed by others. In Hiral P. Harsora v. Kusum Narottamdas
Harsora[27],
the Supreme Court noted that while the statute's goal is to safeguard women in
many aspects of life, the term "Respondent" has been defined under
Section 2(m) of the POSH Act to cover all genders. A person can be either a
male or female sexual harasser under the POSH Act and hence the POSH Act may be
considered as addressing the issue of sexual harassment of lesbians as well as
the sexual harassment of other women. Individuals who identify as lesbians,
gays, bisexuals, and transgenders are protected by the Indian Penal Code, 1860 (IPC)[28]
if they do not engage in sexual activity with a person who is not a
heterosexual. Section 377 of the IPC should not be used as a tool for harassing
those who participate in such consenting sexual behaviour, the court opined,
because such rights stem from the Constitution.[29]
To maintain our togetherness as a
cohesive group of free citizens, we must respect the strength of our diversity
and promote tolerance and respect for one another's rights as we work toward a
more harmonic and peaceful coexistence within the universal tie of humanity.
Individuals' distinct identities must be accepted and respected rather than
forced to 'become' something they are not. This requires a shift in mindset and
a change in attitude. All people have the equal right to be who they truly are,
without having to conform to the preconceived dogmatic ideals of a particular
group. It is our responsibility to "stand up and speak out" against
any sort of transgender discrimination that we come across to change the cultural
bias and root out the weed. It is time to move from darkness to light, and from
bigotry to tolerance and from the winter of just surviving to the spring of
life as a herald of a New India.[30]
When everyone of us realizes that the
LGBT community has the same constitutional rights as any other citizen of the
United States, this freedom will be realized in its fullest sense. It is their
monumental "walk to freedom" and journey to a constitutional ethos of
dignity, equality, and liberty. As a result, Section 377 of the Indian Penal
Code cannot be considered constitutional insofar as it penalizes any consenting
sexual intercourse between two adults, be it between a man and a man, a man and
a woman, or a woman and a woman.[31]
Laws against sexual harassment against individuals who identify as Gay,
Bisexual, Queer, Asexual, and other related groups should be enacted since the
Supreme Court has advocated for suitable protections and safeguards for these
individuals.[32]
CONCLUSION AND WAY FORWARD
To keep pace with today's technological
advances, the existing legal framework is woefully inadequate. The requirements
of this act and the ramifications of non-compliance are not well known. There
must be awareness of the POSH Act and a safe environment where women can freely
express their concerns for the act to achieve its stated goals. We need a shift
in how the state deals with workplace sexual harassment. Non-sexual types of
gender-based discrimination should also be recognized as kinds of sexual
harassment. To be clear, it's not just sexual advances that are being made.
Such an environment can be unfriendly to one's job. Here, we're taking on our
society's patriarchal mentality. To ensure that the transgender population can
properly exercise their rights, we need to ensure that the legislations are
more inclusive of transgender people. Gender-neutral rules for dealing with
sexual harassment in the workplace can be implemented by organizations
themselves until such revisions are made by the legislation. Take, for example,
Godrej's policy against sexual harassment or the Taj Hotels, which are open to
all guests regardless of a person’s gender is where we need a radical shift in
the way we think about sexual harassment laws. It must be more than just
another "offences against women" brick in the wall if it is to be
effective. Creating a legislation will not remove the stigma linked to it. A
fear of retaliation prevents victims of sexual harassment from coming forward,
and even when they do, the ICCs (Internal Complaints Committee) are not
properly established, and it is not uncommon for them to engage in unethical
acts. As a result, a shift in perspective is needed. Educating the public about
this issue is essential if victims are to come forward without fear or
reluctance.
With regard to remedies in cases
involving sexual harassment at work for people of all genders, it is generally
accepted that the Constitution's articles 14, 15, 16, 19, and 21 protect the
rights of men as well as women. When it comes to sexual harassment against people
who identify as gay or bisexual or transgender or queer or allied other than
heterosexual people, India has been far less effective than the rest of the
world, even though public awareness is progressively rising. Gender-neutral
sexual harassment rules appear to have taken a step forward with the passage of
the UGC Sexual Harassment Regulations. As the UGC Sexual Harassment
regulations, which recognize that employees and students of all sexes, as well
as male students and those of third gender, are vulnerable to many forms of
sexual harassment and humiliation,
In the interim, organizations and
entities can create gender-neutral rules and codes of conduct to assure
diversity and inclusion and to encourage sensitization, however, in conclusion
it is deemed expedient that the POSH Act be amended or, alternatively,
appropriate legislation be enacted, to provide for the prevention, prohibition,
and rectification of sexual harassment laws.
[1] Men too are victims of sexual
harassment - Times of India,
https://timesofindia.indiatimes.com/life-style/relationships/love-sex/men-too-are-victims-of-sexual-harassment/articleshow/16336627.cms
(last visited Jul 30, 2022)
[2] Sexual harassment at work: The
limits of the law - The Hindu,
https://www.thehindu.com/news/cities/mumbai/sexual-harassment-at-work-the-limits-of-the-law/article59857021.ece
(last visited Jul 30, 2022)
[3]
239th Report on the Protection of Women Against Sexual Harassment at
Workplace Bill, 2010, Department Related Parliamentary Standing Committee on
Human Resource Development (Presented to the Rajya Sabha on 08.12.2011 and Laid
on the Table of Lok Sabha on 08.12.2011), December 2011
[4] Protection of Women from Sexual
Harassment (POSH) Act, 2013,
https://www.drishtiias.com/daily-updates/daily-news-analysis/protection-of-women-from-sexual-harassment-posh-act-2013
(last visited Jul 30, 2022)
[5] Explained: What is POSH, the law
against sexual harassment in India? | Explained News,The Indian Express,
https://indianexpress.com/article/explained/everyday-explainers/explained-posh-law-against-sexual-harassment-in-india-7825733/
(last visited Jul 30, 2022)
[6] Vishakha v. State of Rajasthan,
(1997) 6 SCC 241
[7] Apparel Export Promotion Council v
A.K. Chopra, AIR 1999 SC 625
[8] Medha kotwal lele v Union Of
India, (2013) 1 SCC 297
[9]Punjab and Sind Bank and Others v
Mrs Durgesh Kunwar, Civil Appeal No 1809 of 2020(India).
[10] Sudesh Jhaku v. K.C.J., 1998 Cri
LJ 2428
[11] Role of the Law Commission of India against sexual violence
and rape,
https://blog.ipleaders.in/role-law-commission-india-sexual-violence-rape/ (last
visited Jul 30, 2022)
[12] The Criminal Law (Amendment) Bill, 2012,
https://prsindia.org/billtrack/the-criminal-law-amendment-bill-2012 (last
visited Jul 30, 2022)
[13] Justice Verma Committee
[14] Section 9 (1) POSH Act read with
Regulation 7, UGC (Prevention, Prohibition and Redressal of Sexual harassment
of women employees and students in higher educational institutions)
Regulations, 2015
[15] Rishi Malhotra v. Union of India,
Writ Petition (Criminal) No. 7/2018, Order dated 02.02.2018; Criminal Justice
Society of India v. Union of India, Writ Petition (Civil) No. 1262/2018, Order
dated 12.11.2018;
[16] Sanjiiv Kumar v. Union of India,
W.P. (C) 8745/2019, Judgment dated 17.12.2019
[17] Putting Men at ease with PoSH:
Adopting a gender neutral policy,
https://newskarnataka.com/special/open-space/putting-men-at-ease-with-posh-adopting-a-gender-neutral-policy
(last visited Jul 30, 2022)
[18]Is the PoSH law gender neutral? -
Serein — Serein,
https://www.serein.in/legal-insights/2021/4/14/gender-neutrality-in-prevention-of-sexual-harassment-law
(last visited Jul 30, 2022)
[19] Gender Neutrality and POSH Law
eLearnPOSH Gender Neutral,
https://elearnposh.com/gender-neutrality-and-posh-law/ (last visited Jul 30,
2022)
[20]Deborah Denno, Why the Model Penal
Code’s Sexual Offense Provisions Should Be Pulled and Replaced (2004) I Ohio
State Journal of Criminal Law 207 to 211
[21] People v. Liberta, 64 NY 2d 152
(1984) Liberta
[22] Your gender-neutral IC is in
violation of the PoSH Act 2013,
https://rainmaker.co.in/your-gender-neutral-ic-is-in-violation-of-the-posh-act-2013-heres-why/
(last visited Jul 30, 2022)
[23] With Recent Updates On The LGBTQ+
Community in India,
https://rainmaker.co.in/with-recent-updates-on-the-lgbtq-community-legal-status-in-india-can-transgenders-file-a-complaint-under-the-posh-act/
(last visited Jul 30, 2022)
[24] National Legal Services Authority
v. Union of India & Ors., AIR 2014 SC 1863, Para 13
[25] PoSH Act Decoded: Is Gender
Neutrality a Part of the PoSH Law,
https://muds.co.in/gender-neutrality-a-part-of-the-posh-law/ (last visited Jul
30, 2022)
[26] No proposal to amend workplace
harassment Act to include LGBTQ community: Centre | The News Minute, https://www.thenewsminute.com/article/no-proposal-amend-workplace-harassment-act-include-lgbtq-community-centre-117769
(last visited Jul 30, 2022)
[27]Hiral P. Harsora v. Kusum
Narottamdas Harsora, (2016) 10 SCC 165
[28] Constitutionality of Section 377 IPC - Supreme
Court Observer,
https://www.scobserver.in/cases/navtej-singh-johar-v-union-of-india-constitutionality-of-section-377-ipc-background/
(last visited Jul 30, 2022)
[29] LGBTQIA+ – POSH – Prevention of Sexual Harassment at the
Workplace, https://poshhelp.in/lgbtqia/
(last visited Jul 30, 2022)
[30] Diversity and Inclusion Advisory POSH Act Compliance,
https://www.ungender.in/is-posh-law-applicable-on-transgenders/ (last visited
Jul 30, 2022)
[31] India Code: Section Details,
https://www.indiacode.nic.in/show-data?actid=AC_CEN_5_23_00037_186045_1523266765688&orderno=434
(last visited Jul 30, 2022)
[32] POSH Act?: Discussing Gender Neutrality, Transgender Rights
& Inclusion Of LGBTQ,
https://www.livelaw.in/columns/posh-act-discussing-gender-neutrality-transgender-rights-inclusion-of-lgbtq-157906
(last visited Jul 30, 2022)
Article Information
Critical Analysis Of The Prevention Of Sexual Harassment At Workplace Act {Posh} 2013- The Need For A Shift Towards Gender Neutrality?
Authors: Manvi Kishore, Arnold Stanley
- Journal IJLRA
- ISSN 2582-6433
- Published 2023/04/04
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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