Karnataka High Court’s Ruling: Suo Motu Complaint After Clean Chit By Internal Committee

Judgement Given On : 28/01/2019

The Background

In a significant legal precedent set by the Karnataka High Court in the case of Usha Padmini and Ors. vs. State of Karnataka and Ors. on January 28, 2019, the Court ruled on an essential issue concerning the authority of an Internal Committee (IC) in cases of sexual harassment at workplaces. This case underscores the importance of a fair inquiry process and the potential consequences of filing a police complaint following a clean chit by an IC.

The case revolved around accusations of sexual harassment made against two individuals, Sumanta Banerjee (“Accused No. 1”) and Usha Padmini (“Accused No. 2”). The complainant, referred to as “Respondent No. 2,” had initially reported allegations of sexual and workplace harassment against both Accused No. 1 and 2 to the human resource manager of their company. Her accusations included claims such as Accused No. 1 sitting in a suggestive manner and causing discomfort and possible accidents. Additionally, she alleged that Accused No. 2 had harassed her alongside Accused No. 1.

In response to these allegations, an Internal Committee (IC) was formed to conduct an inquiry. After a thorough investigation, the IC cleared both Accused No. 1 and 2 of the charges. Dissatisfied with this outcome, Respondent No. 2 approached a labour court for relief and concurrently filed a police complaint against the accused parties. The police subsequently filed a charge sheet against them under various sections of the Indian Penal Code (IPC).

The Legal Question

The central issue at hand was whether filing a police complaint, after an IC had conducted a proper inquiry and exonerated the accused, amounted to an abuse of legal process. In other words, could the complainant pursue a criminal case based on the same set of allegations and evidence that had been examined by the IC?

The Court’s Verdict

The Karnataka High Court made several crucial observations and arrived at a definitive ruling:

  1. The Court recognized that the allegations made by Respondent No. 2 appeared to have been motivated by a desire to falsely implicate Accused No. 1 in criminal charges.
  2. It emphasized that since the IC had already investigated and found no merit in the allegations, initiating a criminal prosecution against the accused based on the same facts and evidence would be unjust and constitute an abuse of the legal process.
  3. The Court noted that no statutory appeal or pending proceedings existed against the IC’s inquiry report, indicating that the inquiry had reached a final conclusion.
  4. The filing of the police complaint was viewed as a mere reiteration of the same allegations made before the IC, with no additional evidence presented to substantiate the charges.
  5. The Court regarded Respondent No. 2’s mention of specific details like “manhood” as an afterthought, highlighting inconsistencies in her account.

Legal Precedent and Implications

This ruling by the Karnataka High Court aligns with a broader trend in Indian jurisprudence, emphasizing the importance of IC reports in cases of workplace sexual harassment. Notably, the Court emphasized that if the IC conducts a proper inquiry and exonerates the accused, initiating criminal proceedings on the same set of facts and charges is impermissible. This stance safeguards individuals from facing double jeopardy and ensures that the findings of the IC are accorded due weight in subsequent legal proceedings.

In workplaces today, the constitution, inquiry, and findings of an Internal Committee play a pivotal role in addressing complaints of harassment and fostering a safe environment for women. These reports not only influence criminal proceedings but also impact wrongful termination claims, reinstatement petitions, and damage claims initiated by parties aggrieved by the IC’s findings.

In summary, the Karnataka High Court’s decision in Usha Padmini v. State of Karnataka underscores the significance of a fair inquiry process and discourages the misuse of criminal complaints following a clean chit by an Internal Committee. It reinforces the principle that justice must be served within the boundaries of established legal procedures.