Two developments in August 2026 are a timely reminder that POSH compliance is not a one-time formality. One is about setting up and registering your Internal Committee. The other is about what happens after it gives a decision.
1. Karnataka: Internal Committees must be on the SHE-Box portal
On 11 August 2026, the Government of Karnataka directed District Nodal Officers to ensure that private organisations with more than 10 employees constitute Internal Committees (ICs) under the POSH Act and register them on the SHE-Box portal. Districts were asked to complete the exercise within one month and report back.
The scale of the gap is striking. As reported, of roughly 81,000 organisations in Karnataka with 10 or more employees, only about 26,000 had formed and registered an IC. About 55,000 were still pending.
Even if you are not in Karnataka, take note. Registration on the SHE-Box portal is becoming the way authorities check compliance, and other states can follow the same route.
What to check now
- Do you need an IC? If you have 10 or more employees at a workplace, yes.
- Is it properly constituted? The Presiding Officer must be a senior woman employee, at least half the members must be women, and the committee needs an external member from an NGO or someone familiar with sexual harassment issues.
- Is it registered on SHE-Box? If not, register it.
- Is it trained and active? A committee that exists only on paper will not hold up when a complaint arrives.
2. Bombay High Court: no "in-house" appellate authority
In Ashok Upadhyay v. Union Bank of India, reported on 21 August 2026, the Bombay High Court considered a case where the bank's IC had cleared an officer. The complainant then appealed to an "Appellate Authority" that the bank itself had set up. That body ordered a fresh inquiry, which found the officer guilty, and he was demoted.
The High Court quashed the penalty and the appellate order. It held that the POSH Act and its Rules do not give an employer the power to create its own appellate authority. Because the reinvestigation came from an authority that had no legal power, everything that followed fell with it.
The complainant was allowed to challenge the original decision before a legally valid appellate forum within six weeks.
What this means for you
- Do not invent an appeal process in your POSH policy. Appeals go to the forum the law provides, or one set out in valid service rules.
- Review your POSH policy for any "internal appeal committee" or "management review" step that could reopen an IC decision.
- Follow natural justice. The officer in this case was not heard before the inquiry was reopened, and that weighed against the bank.
A simple POSH checklist for this month
- Confirm whether each of your workplaces needs an IC.
- Check the IC's composition, including the external member.
- Register the IC on the SHE-Box portal.
- Read your POSH policy's appeal clause, and remove any in-house appellate body.
- Train the IC members and display the policy at the workplace.
- Diarise the annual report the IC must prepare.
POSH is about people's safety and dignity first, and legal risk second. Get both right by keeping the process simple, lawful and well understood.
This article is for general information and is not legal advice. Check the current rules for your state and take professional advice for your situation.
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