By S&S Co. Advocates & Solicitors · Published 18 June 2026 · Informational content, not legal advice: see our disclaimer
The Starting Rule: One Committee Per Administrative Unit
Section 4 of the POSH Act contemplates an Internal Committee at each office or branch where the employer has ten or more employees, described in the Act as being constituted at "every office or administrative unit." For an organisation with several branches, factories or regional offices, this generally means a separate, properly constituted Internal Committee at each qualifying location, each with its own composition, external member, and record-keeping, rather than one Committee attempting to serve every location from a single head-office base.
Why a Single, Centralised Committee Is Usually the Wrong Approach
A Committee based only at the head office faces practical difficulties in handling a complaint from a distant factory or branch: witnesses, the complainant and the respondent are all local to that unit, and travel for hearings adds delay and cost that works against the ninety-day inquiry timeline. Courts and regulators have generally expected the Committee to be reasonably accessible to the workforce it serves, which supports a location-based structure over a single centralised one for any organisation of meaningful size.
An Apex or Coordinating Structure Above Local Committees
Many larger organisations layer a group-level POSH policy, a central compliance owner, and a standard operating procedure on top of individually constituted, location-level Internal Committees, so that policy, training standards, templates and reporting are consistent across locations even though each Committee remains independently constituted and competent to inquire into complaints arising at its own location. This apex layer coordinates consistency; it does not itself inquire into complaints or substitute for the location-level Committee's jurisdiction.
Smaller Units and the Local Committee
Where a particular office or branch has fewer than ten employees, or where the complaint is against the employer itself, the complaint is instead addressed to the Local Committee constituted by the District Officer for that district, rather than to an Internal Committee. Organisations with a mix of larger and smaller locations should map, location by location, which forum applies, rather than assuming a uniform answer across the whole organisation.
Keeping Consolidated Records
Even with location-level Committees handling inquiries independently, the organisation should maintain a consolidated record of complaints, outcomes and training across all locations, both to support its Section 21 and Companies Act reporting obligations and to allow the organisation to identify patterns, such as a particular location generating a disproportionate share of complaints, that might call for a closer look at that location's culture or management.
Frequently Asked Questions
Can one Internal Committee handle complaints from several different office locations?
Section 4 contemplates a Committee at each qualifying office or administrative unit; a single, centrally based Committee attempting to serve multiple distant locations creates practical difficulties with accessibility and the ninety-day inquiry timeline, and is generally not the preferred structure for an organisation of meaningful size.
What happens at an office with fewer than ten employees?
A workplace with fewer than ten employees is not required to constitute its own Internal Committee; a complaint from that workplace is instead addressed to the Local Committee constituted by the District Officer for that district.
Does an apex or group-level POSH policy replace the need for local Internal Committees?
No. A group-level policy and coordinating structure can standardise training, templates and reporting, but each qualifying location still needs its own validly constituted Internal Committee with jurisdiction to inquire into complaints arising there.
References & Further Reading
This article references the following statutory provisions. Readers should always verify current rules, fees and timelines against the applicable statute and rules as amended, since these are revised from time to time.
- Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, and the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, as amended.