Redressing The Imbalance: Legal Gaps In Protecting Men From Workplace Sexual Harassment
Sexual Harassment can be defined as a type of harassment which has sexual
undertones through words, signs, or behavior whereby the victim is put through
unwelcome and hostile requests for sexual favors. Rape, indecent assault, or
verbal abuse are all acts that fall under the broader umbrella of sexual
harassment.
Harassment can happen at various places such as work, home, and educational institutions. Any person of any sex or gender can be a target and perpetrator of harassment. The danger for men is made apparent by the absence of such legal safeguards against sexual harassment at workplace. Sexual Harassment does amount to gender discrimination, but discrimination based on gender, especially for men, is largely unexplored.
One major aspect related to men is that there is, in most legal systems around the globe, no effective means of preventing sexual harassment at the workplace and if it does, it invites punitive measures. In this Article, the primary focus is to emphasize on the much-ignored legal presumption men face at the workplace in terms of sexual harassment. In simplest words, this article looks at the laws and suggests legal remedies available to men and amends using a gender neutral approach.
The research methodology used in this study is primarily doctrinal involving extensive ethnic turnover analysis of relevant primary and secondary materials available. Special emphasis is laid on directives of the government and constitutions along with newspapers, articles, and domestic academic writings. By examining the current legislative and legal framework and its implementation
Introduction
When we hear the term sexual harassment, a disturbing image often comes to mind: a man making unwanted advances or comments towards a woman, creating a sense of unease for her. Nevertheless, the actual scenario differs, and anyone can fall prey to sexual harassment, regardless of age, gender, or sexual orientation. Typically, the instances of harassment or assaults we observe are predominantly linked to females, resulting in women being the primary focus of lawmakers and legislation. Upon examining the actual situation, it becomes evident that many men also experience sexual harassment and are victims of it, despite the lack of a mechanism to address their issue.
The primary question that needs to be addressed is who will safeguard men from sexual harassment? India's legal framework focuses on addressing matters concerning sexual harassment and rape against women. There are currently no legal safeguards or laws in place to shield men from the violent acts of harassment and rape. In India, there is a specific provision in the Indian Penal Code known as Section 377 that deals with 'sodomy'. Except for this part, all other regulations and sections pertain only to women.
It can be argued that there is unequal access to justice. India is recognized for its focus on the rights of its citizens, yet violations of the 'Right to equality' persist. Why is this the case? In India, the legal system, societal norms, and laws highlight the significance of ensuring equal rights and fair treatment for all genders. It is evident that the presence of these loopholes and the lack of laws addressing sexual harassment, sexual assault, or rape indicate a blatant disregard for the 'Right to equality'.
There are many instances covered by surveys and reports of governmental as well as nongovernmental organizations, which revealed numerous cases of men facing incidents of sexual harassment in the workplace.
For instance, a male intern at a Bengaluru-based mobile marketing company accused one of the organization's product managers of sexual harassment at the 'workplace'. In his conversation with the organization, the victim stated that he had been invited by the project manager "to their place after being manipulated and falsely comforted". During this interaction, he attempted to force himself on him, touched him inappropriately, and said unpleasant things
India's most extensive survey conducted on workplace sexual harassment, led by the Indian National Bar Association. The survey took place from April 2016 to October 2016 and involved 6047 participants both male and female and 45 victims both male and female. Approximately 22% of the reported victims were male
Another survey carried out by the Indian Government in 2007 found that among children who reported severe sexual abuse such as rape or sodomy, 57.3% were boys and 42.7% were girls. In a recent study, the Delhi-based Centre for Civil Society discovered that around 18% of Indian adult men surveyed stated that they had been coerced or forced into engaging in conjugal relations. Out of those, 16% reported a female perpetrator and 2% reported a male perpetrator
Furthermore, an editorial in The Hindu reveals accounts of sexual harassment encountered by men in their workplaces. An individual worked as a crime reporter. He frequently received unsuitable messages in his Facebook inbox. He usually ignored couples who received inappropriate sexual comments from female colleagues. One day, he was taken aback when he received a call from an unfamiliar number.
A woman on the other line provided him with clear directions on what she expected him to accomplish. After a few weeks, the frequency of incidents rose, prompting him to eventually go to the police station to lodge a formal complaint against the culprit. He is subjected to extremely inappropriate remarks by a female Superintendent of Police - "Ladki chhed rahi hai toh chhid jaona!"
Legal Frameworks For Addressing Sexual Harassment In India And Its Loopholes:
Suggestive amendments can be made to bring gender neutrality in the above legislation. For example, Section 3[4] of the POSH Act could replace the term 'women' with the term 'person' to make the act gender-neutral. Nonetheless, there are gender-neutral elements in the Act; this approach should be expanded to include other aspects of the legislation as well. For example, Section 18 of the Act, which concerns the protocol for appealing decisions made by the Internal Complaints Committee or Local Complaints Committee, uses the term "any person" who is eligible to appeal. This suggests that the aggrieved party could be a man, a woman, or someone who identifies as any other gender.
Gender and sexuality are no longer regarded to be as black and white as they were when the Act was conceived. Furthermore, such a biased regulation perpetuates the long-standing stereotype of a male harasser and a female victim, undermining the concept of workplace equality. In the case of Hiral P. Harsora v. Kusum Narottamdas Harsora15, The Supreme Court noted that while the primary aim of the statute is to protect women across various aspects of life, Section 2(m) of the POSH Act defines the term "Respondent" to encompass all genders.
Consequently, the POSH Act acknowledges that both males and females can be perpetrators of sexual harassment. As a result, a gender-neutral regulation can be suggested that requires workplaces to have appropriate procedures in place to handle sexual harassment of both men and people who identify as LGBTQ+. Expanding this neutral application to accommodate all victims in the workplace, regardless of gender, would effectively empower them to speak out against detrimental situations and foster an inclusive work environment.
Moreover, In May 2016, the University Grants Commission introduced a set of regulations known as the "UGC Sexual Harassment Regulations," which require higher educational institutions to take strong action against all forms of gender-based violence. According to Regulation 3(1)(d) of the Regulation: "Higher educational institutions must take strong action against all forms of gender-based violence targeting employees and students of all genders, acknowledging the vulnerability of primarily women employees and students, as well as some male students and students of the third gender, to various types of sexual harassment, humiliation, and exploitation."
According to a study, media coverage of sexual assaults against men has no impact on male labor participation. There is no evident link between interpersonal violence and male labor participation. Nevertheless, media reports on sexual assaults against women can lead to feelings of anxiety and fear. There is a tendency for to women perceive a higher risk of becoming victims due to fear, even when the actual risk remains unchanged. It is possible that women reduce their work outside the home due to fear stemming from heightened media coverage of sexual attacks.
This led to arguments that altering gender-sensitive laws such as the POSH Act and the Indian Penal Code to be gender-neutral could potentially compromise their goal of safeguarding and empowering women. On the other hand, some research indicates that men are similarly impacted mentally and physically by sexual harassment, as a study demonstrates that men do experience distress. National Intimate Partner and Sexual Violence Survey (NISVS) in 2010 reports a higher prevalence of various health issues in men who have experienced rape, stalking, or physical violence by an intimate partner.
Also, the above-mentioned study indicates the impact of sexual harassment on the workforce in the economy but our primary concern should be the effect of sexual harassment on victims.
All individuals whether male or female who have faced sexual harassment should receive fair treatment and seek help from legal frameworks such as the POSH Act to ensure equal protection under Article 14 of the Indian Constitution.
Additionally, the POSH Act is not sufficiently inclusive to cover women from all sectors of work. Horizontal inequality is evident in legislation. Inequality between individuals of a group but with different identities is known as Horizontal inequality. Since more than 80% of Indian women workers are employed in the informal sector, the law is generally inaccessible to them.19 Gender is the dominant determinant of labor force participation in the informal economy in India, as 95 percent of the female workforce is engaged in informal sector employment.
Women perform a variety of occupations in the unorganized sector, including street vendors, construction workers, domestic workers, and agricultural laborers. Given the substantial proportion of female workers employed in the informal sector, the matter concerning the efficient enforcement of legislation about sexual harassment in the workplace requires a deeper analysis.
The 2013 Justice J.S. Verma Committee Report stressed the need for a workplace sexual harassment law that covers "every female member of the national workforce". The report stressed the need to include the unorganized sector and ensure that the informal sector was not immune from regulation. The need to amend the POSH Act is further exacerbated by this horizontal inequality.
Furthermore, by ensuring equal protection under the law through Article 14 of the Indian Constitution to amend laws and make them gender-neutral, it does not infringe upon the special provision of Article 15(3) as this approach does not aim to exclude women from the protection provided for them; instead, gender-neutral laws will encompass men and LGBTQ+ individuals who are also at risk of sexual harassment in the workplace.
Conclusion
We have come to a point where ensuring the protection of men's dignity is just as crucial as safeguarding the modesty and dignity of women in the country. The advancements in modernization and culture have not only achieved gender equality but have also resulted in cases of women sexually harassing men in workplaces or educational institutions. The issue has now become more complex as harassment between men was already a challenge to address, and now harassment from women towards men is also a significant concern.
Hence, creating laws to protect potential victims is crucial. Extensive research is being conducted on sexual violence against men worldwide, with many countries implementing legal provisions. Indian Courts need to address sexual violence against men and implement laws to protect them from such crimes.
However, implementing laws is the second priority for our society, with the first being to acknowledge the importance of gender-neutral laws. Due to practical necessities, exceptions to standard rules may need to be made at times, so why can't we accept that there might be an exception to the typical scenario of men sexually harassing women?
This issue is becoming increasingly prominent in addressing gender-neutral laws. Our society seems unprepared to acknowledge the existence of sexual harassment towards men, making finding solutions to such issues seem distant. Like if we do not acknowledge the presence of a disease in our body and seek medical attention for treatment, doctors and medications will not be able to assist us. To address the problem of sexual harassment against men, it is essential to acknowledge that "Men Can Also Be Victims Of Sexual Harassment."
References:
Harassment can happen at various places such as work, home, and educational institutions. Any person of any sex or gender can be a target and perpetrator of harassment. The danger for men is made apparent by the absence of such legal safeguards against sexual harassment at workplace. Sexual Harassment does amount to gender discrimination, but discrimination based on gender, especially for men, is largely unexplored.
One major aspect related to men is that there is, in most legal systems around the globe, no effective means of preventing sexual harassment at the workplace and if it does, it invites punitive measures. In this Article, the primary focus is to emphasize on the much-ignored legal presumption men face at the workplace in terms of sexual harassment. In simplest words, this article looks at the laws and suggests legal remedies available to men and amends using a gender neutral approach.
The research methodology used in this study is primarily doctrinal involving extensive ethnic turnover analysis of relevant primary and secondary materials available. Special emphasis is laid on directives of the government and constitutions along with newspapers, articles, and domestic academic writings. By examining the current legislative and legal framework and its implementation
Introduction
When we hear the term sexual harassment, a disturbing image often comes to mind: a man making unwanted advances or comments towards a woman, creating a sense of unease for her. Nevertheless, the actual scenario differs, and anyone can fall prey to sexual harassment, regardless of age, gender, or sexual orientation. Typically, the instances of harassment or assaults we observe are predominantly linked to females, resulting in women being the primary focus of lawmakers and legislation. Upon examining the actual situation, it becomes evident that many men also experience sexual harassment and are victims of it, despite the lack of a mechanism to address their issue.
The primary question that needs to be addressed is who will safeguard men from sexual harassment? India's legal framework focuses on addressing matters concerning sexual harassment and rape against women. There are currently no legal safeguards or laws in place to shield men from the violent acts of harassment and rape. In India, there is a specific provision in the Indian Penal Code known as Section 377 that deals with 'sodomy'. Except for this part, all other regulations and sections pertain only to women.
It can be argued that there is unequal access to justice. India is recognized for its focus on the rights of its citizens, yet violations of the 'Right to equality' persist. Why is this the case? In India, the legal system, societal norms, and laws highlight the significance of ensuring equal rights and fair treatment for all genders. It is evident that the presence of these loopholes and the lack of laws addressing sexual harassment, sexual assault, or rape indicate a blatant disregard for the 'Right to equality'.
Statistics Of Sexual Harassment Against Men
Sexual Harassment cases are predominantly perceived and documented in relation to women, which explains why legislation is enacted exclusively for the benefit of female victims. However, this does not exempt males from the perils of sexual harassment. Although males and young children who have experienced sexual harassment may share similar emotions with other survivors of sexual assault, they encounter numerous additional obstacles due to "social ridicule" and "stereotypes" regarding the masculinity of men.There are many instances covered by surveys and reports of governmental as well as nongovernmental organizations, which revealed numerous cases of men facing incidents of sexual harassment in the workplace.
For instance, a male intern at a Bengaluru-based mobile marketing company accused one of the organization's product managers of sexual harassment at the 'workplace'. In his conversation with the organization, the victim stated that he had been invited by the project manager "to their place after being manipulated and falsely comforted". During this interaction, he attempted to force himself on him, touched him inappropriately, and said unpleasant things
India's most extensive survey conducted on workplace sexual harassment, led by the Indian National Bar Association. The survey took place from April 2016 to October 2016 and involved 6047 participants both male and female and 45 victims both male and female. Approximately 22% of the reported victims were male
Another survey carried out by the Indian Government in 2007 found that among children who reported severe sexual abuse such as rape or sodomy, 57.3% were boys and 42.7% were girls. In a recent study, the Delhi-based Centre for Civil Society discovered that around 18% of Indian adult men surveyed stated that they had been coerced or forced into engaging in conjugal relations. Out of those, 16% reported a female perpetrator and 2% reported a male perpetrator
Furthermore, an editorial in The Hindu reveals accounts of sexual harassment encountered by men in their workplaces. An individual worked as a crime reporter. He frequently received unsuitable messages in his Facebook inbox. He usually ignored couples who received inappropriate sexual comments from female colleagues. One day, he was taken aback when he received a call from an unfamiliar number.
A woman on the other line provided him with clear directions on what she expected him to accomplish. After a few weeks, the frequency of incidents rose, prompting him to eventually go to the police station to lodge a formal complaint against the culprit. He is subjected to extremely inappropriate remarks by a female Superintendent of Police - "Ladki chhed rahi hai toh chhid jaona!"
Legal Frameworks For Addressing Sexual Harassment In India And Its Loopholes:
- Posh Act
The Sexual Harassment of Women at Workplace (Prevention, Prohibition, and Redressal) Act, 2013 which is also called the Prevention of Sexual Harassment Act ("POSH Act") is the primary legislation that deals with workplace sexual harassment against women. This history of the POSH Act stems from the famous case of Vishakha v. the State of Rajasthan. It was enacted to incorporate the Vishakha Guidelines of 2007 and fulfill international obligations under the Convention on the Elimination of All Forms of Discrimination against Women.
The Act is silent on male or LGBTQ+ employees who may be subjected to workplace sexual harassment. Section 2(a)[3]7 defines an aggrieved woman as one who claims to have been subjected to an act of sexual harassment. Section 3[4]8 specifies that no woman shall be subjected to sexual harassment in the workplace. Thus, by limiting the scope to women, the Act precludes the opportunity to resolve sexual harassment complaints raised by men or other individuals.
- Indian Penal Code
Indian Penal Code (IPC) Sections 354, 509, and 376 address different forms of sexual assault, including outraging modesty, eve-teasing, and rape, specifically focused on women. Although it is positive in its own right, it is disappointing that the IPC only addresses sexual assault on men through section 377, which criminalizes sodomy and is often used to discriminate against the LGBT community. It also fails to distinguish between consensual and non-consensual sexual acts among two adult males. Even the Vishakha guidelines established to prevent and address sexual harassment in workplaces only focus on women.
Suggestions For Amending Existing Provisions On Sexual Harassment
Several countries, such as Denmark, the United Kingdom, and Australia, have put forth and implemented gender-neutral legislation. It's interesting how, despite global changes, the Indian judiciary has continuously refused to adopt gender-neutral laws on sexual harassment. With the increasing number of sexual harassment cases involving men, it is essential to introduce gender-neutral laws in India.Suggestive amendments can be made to bring gender neutrality in the above legislation. For example, Section 3[4] of the POSH Act could replace the term 'women' with the term 'person' to make the act gender-neutral. Nonetheless, there are gender-neutral elements in the Act; this approach should be expanded to include other aspects of the legislation as well. For example, Section 18 of the Act, which concerns the protocol for appealing decisions made by the Internal Complaints Committee or Local Complaints Committee, uses the term "any person" who is eligible to appeal. This suggests that the aggrieved party could be a man, a woman, or someone who identifies as any other gender.
Gender and sexuality are no longer regarded to be as black and white as they were when the Act was conceived. Furthermore, such a biased regulation perpetuates the long-standing stereotype of a male harasser and a female victim, undermining the concept of workplace equality. In the case of Hiral P. Harsora v. Kusum Narottamdas Harsora15, The Supreme Court noted that while the primary aim of the statute is to protect women across various aspects of life, Section 2(m) of the POSH Act defines the term "Respondent" to encompass all genders.
Consequently, the POSH Act acknowledges that both males and females can be perpetrators of sexual harassment. As a result, a gender-neutral regulation can be suggested that requires workplaces to have appropriate procedures in place to handle sexual harassment of both men and people who identify as LGBTQ+. Expanding this neutral application to accommodate all victims in the workplace, regardless of gender, would effectively empower them to speak out against detrimental situations and foster an inclusive work environment.
Moreover, In May 2016, the University Grants Commission introduced a set of regulations known as the "UGC Sexual Harassment Regulations," which require higher educational institutions to take strong action against all forms of gender-based violence. According to Regulation 3(1)(d) of the Regulation: "Higher educational institutions must take strong action against all forms of gender-based violence targeting employees and students of all genders, acknowledging the vulnerability of primarily women employees and students, as well as some male students and students of the third gender, to various types of sexual harassment, humiliation, and exploitation."
According to a study, media coverage of sexual assaults against men has no impact on male labor participation. There is no evident link between interpersonal violence and male labor participation. Nevertheless, media reports on sexual assaults against women can lead to feelings of anxiety and fear. There is a tendency for to women perceive a higher risk of becoming victims due to fear, even when the actual risk remains unchanged. It is possible that women reduce their work outside the home due to fear stemming from heightened media coverage of sexual attacks.
This led to arguments that altering gender-sensitive laws such as the POSH Act and the Indian Penal Code to be gender-neutral could potentially compromise their goal of safeguarding and empowering women. On the other hand, some research indicates that men are similarly impacted mentally and physically by sexual harassment, as a study demonstrates that men do experience distress. National Intimate Partner and Sexual Violence Survey (NISVS) in 2010 reports a higher prevalence of various health issues in men who have experienced rape, stalking, or physical violence by an intimate partner.
Also, the above-mentioned study indicates the impact of sexual harassment on the workforce in the economy but our primary concern should be the effect of sexual harassment on victims.
All individuals whether male or female who have faced sexual harassment should receive fair treatment and seek help from legal frameworks such as the POSH Act to ensure equal protection under Article 14 of the Indian Constitution.
Additionally, the POSH Act is not sufficiently inclusive to cover women from all sectors of work. Horizontal inequality is evident in legislation. Inequality between individuals of a group but with different identities is known as Horizontal inequality. Since more than 80% of Indian women workers are employed in the informal sector, the law is generally inaccessible to them.19 Gender is the dominant determinant of labor force participation in the informal economy in India, as 95 percent of the female workforce is engaged in informal sector employment.
Women perform a variety of occupations in the unorganized sector, including street vendors, construction workers, domestic workers, and agricultural laborers. Given the substantial proportion of female workers employed in the informal sector, the matter concerning the efficient enforcement of legislation about sexual harassment in the workplace requires a deeper analysis.
The 2013 Justice J.S. Verma Committee Report stressed the need for a workplace sexual harassment law that covers "every female member of the national workforce". The report stressed the need to include the unorganized sector and ensure that the informal sector was not immune from regulation. The need to amend the POSH Act is further exacerbated by this horizontal inequality.
Is Gender-Neutrality Detriment To Women's Protection?
Article 15(3) of the Indian Constitution addresses the enforcement of special measures for women. Implementing special provisions for women through protective discrimination can lead to legislation that protects women from sexual harassment in the workplace. The POSH Act was established as a unique provision for women because of their susceptibility to workplace sexual harassment. However, the paper suggests that women are not the sole vulnerable group. Other groups could also encounter comparable risks and find themselves at a disadvantage. This disparity in protection for men and other groups contradicts the equal protection promised in Article 14 of the Constitution.Furthermore, by ensuring equal protection under the law through Article 14 of the Indian Constitution to amend laws and make them gender-neutral, it does not infringe upon the special provision of Article 15(3) as this approach does not aim to exclude women from the protection provided for them; instead, gender-neutral laws will encompass men and LGBTQ+ individuals who are also at risk of sexual harassment in the workplace.
Conclusion
We have come to a point where ensuring the protection of men's dignity is just as crucial as safeguarding the modesty and dignity of women in the country. The advancements in modernization and culture have not only achieved gender equality but have also resulted in cases of women sexually harassing men in workplaces or educational institutions. The issue has now become more complex as harassment between men was already a challenge to address, and now harassment from women towards men is also a significant concern.
Hence, creating laws to protect potential victims is crucial. Extensive research is being conducted on sexual violence against men worldwide, with many countries implementing legal provisions. Indian Courts need to address sexual violence against men and implement laws to protect them from such crimes.
However, implementing laws is the second priority for our society, with the first being to acknowledge the importance of gender-neutral laws. Due to practical necessities, exceptions to standard rules may need to be made at times, so why can't we accept that there might be an exception to the typical scenario of men sexually harassing women?
This issue is becoming increasingly prominent in addressing gender-neutral laws. Our society seems unprepared to acknowledge the existence of sexual harassment towards men, making finding solutions to such issues seem distant. Like if we do not acknowledge the presence of a disease in our body and seek medical attention for treatment, doctors and medications will not be able to assist us. To address the problem of sexual harassment against men, it is essential to acknowledge that "Men Can Also Be Victims Of Sexual Harassment."
References:
- Indian Penal Code, 1860 § 377.
- Sanath Prasad, 'Forced himself on me, touched me inappropriately': male intern of Bengaluru company accuses manager of sexual harassment, The Indian Express (Sept. 20, 2023), https://indianexpress.com/article/cities/bangalore/bengaluru-company-male-intern-sexual-harrassment-complaint-8948217/
- Netrika Consulting and Investigation, INBA, Garima: Sexual Harassment at Workplace (Prabhat Books, 2017).
- Lalit Bhardwaj, Babu Shivnath Agrawal, sexual harassment of men: a crime that is a reality, Volume II, IJIRL, 7 (2022), https://ijirl.com/wp-content/uploads/2022/06/SEXUAL-HARASSMENT-OF-MEN-A-CRIME-THAT-IS-A-REALITY.pdf
- Zara Khan, Adam, what do you mean you were teased?, The Hindu (May 2, 2017), https://www.thehindu.com/thread/reflections/men-too-may-be-sexually-harassed/article18351375.ece
- Vishaka & Ors. vs. State of Rajasthan MANU/SC/0786/1997.
- Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 § 2(a)[3].
- Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 § 3[4].
- Indian Penal Code, 1860 § 354.
- Indian Penal Code, 1860 § 509.
- Indian Penal Code, 1860 § 376.
- India Const. art. 14.
- Shivam Sharma & Aneisha Kaushik, Protection of Men against Sexual Harassment - Need of the Hour, 13 SUPREMO AMICUS 271 (2019).
- Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 § 18.
- Hiral P. Harsora vs. Kusum Narottamdas Harsora MANU/SC/1269/2016.
- Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 § 2(m).
- Adab Singh Kapoor, POSH Act: Discussing Gender Neutrality, Transgender Rights & Inclusion Of LGBTQ, (June 6, 2020).
- Jai Vipra, A case for gender-neutral rape laws in India, (CCS Working Paper # 286, Page No. 15, 2013), https://ccs.in/sites/default/files/202210/A Case for Gender Neutral Rape Laws in%20India.pdf
- Diksha Munjal, Explained | What is the POSH Act and why has the Supreme Court flagged lapses in its implementation?, The Hindu (May 15, 2023), https://www.thehindu.com/news/national/explained-the-indian-law-on-sexual-harassment-in-the-workplace/article66854968.ece
- Avanti Deshpande, Does The POSH Law Protect Women Working In The Unorganised Sector? Ungender (January 6, 2021), https://www.ungender.in/sexual-harassment-against-women-in-the-unorganised-sector/
- India Const. art. 15, cl. 3.
- India Const. art. 15, cl. 3.
- Women Against Workplace Sexual Harassment: Legal Remedies and Rights Under the Bharatiya Nyaya Sanhita (BNS)
- Protection of Women From Sexual Harassment At Workplace
- Sexual Harassment At Workplace Is An Affront to Women's Fundamental Rights: SC
- A Study On Sexual Harassment Of Women At Workplace In India With Special Reference To Protection Of Women From Sexual Harassment Act
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