Whose Voice Defines Justice? Exploring the Applicability of Restorative Justice Principles in Cases of Workplace Sexual Harassment

By Nitya Sriram - Senior Lead Programs, TrustIn.

This paper was presented at the first ever Indian RJ Conference held on 20th to 21st November, Reimagining Justice: Exploring Restorative Approaches in the Indian Context at Christ University, Bangalore in partnership with Unicef, Ashiyana Foundation, Enfold and Counsel to Secure Justice as a part of an exercise for practitioner's to learn from each others' body of work.

Abstract: 

In the closing moments of the film Chithha (2023 Tamil Film) (1), a survivor recounts her experience of sexual assault as a minor to her partner. His immediate reaction is to ask her to name the perpetrator, and promise to kill him. Her response prompts him to reflect on whether his actions would support her, or alleviate his own guilt and anger, raising a critical question: whose voice determines what constitutes justice in cases of sexual violence?

Source: IMDb

India’s law for prevention of sexual harassment at workplace, The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (2), or the POSH Act, going forward, combines restorative and punitive principles, giving focus to prevention and prohibition, along with redressal. At the same time, Indian workplaces mirror the larger cultural landscape, which continues to be deeply patriarchal, placing honour in women’s dignity. 

This paper attempts to explore how restorative justice (RJ) practices can be embedded meaningfully into workplace responses to sexual harassment in India, drawing on five anonymised cases of sexual harassment handled by TrustIn (3) It argues that while RJ cannot replace compliance and due process, it may help repair or minimise the harm reflected in dissatisfaction, lack of closure, and misalignment, often observed in POSH redressals, and shift the voice to prioritise healing of survivors and communities. 

Introduction

Workplace sexual harassment remains one of the most underreported forms of gender-based violence in India(4). Indian workplaces, as microcosms of society, mirror broader cultural norms that link women’s dignity to honour, encourage silence and normalise stigma around experiences of sexual violence(5). This leads to profound impacts on the lives of survivors – physical, psychological, professional and socio-cultural(6). It further impacts their safety, mobility and participation across personal, professional and public spheres(7). These patterns, documented widely in feminist and socio-legal scholarship, are reflected within organisational structures where power, hierarchy, and economic dependence shape survivor experiences and decisions. This paper examines how these dynamics manifest in formal workplaces, based on TrustIn’s case-handling practice. In this paper, the ‘workplace’ is defined as formal workplaces, which have Internal Committee (IC) (8) mechanisms set up. This paper does not examine the power structures, challenges and hierarchies of the informal sector in India. 

The POSH Act (2013) seeks to address sexual harassment through a combination of prevention, prohibition, and redressal. Although prevention is core to the law, TrustIn’s experience as training facilitators and organisational advisors has indicated that conversations gravitate largely towards redressal and punitive outcomes (9). Across our training sessions, concerns related to false complaints indicate heightened fear among cisgender male participants, reflecting anxieties rooted in the broader public narrative.

Such narratives continue to shape the workplace discourse around sexual harassment in a country that continues to rank among the most dangerous countries for women in the world (10). Consequently, we often see what this paper refers to as the “Chittha effect” – a deep-rooted need to respond to cases of sexual violence with calls for naming, shaming and severe punishment. Public outrage is prioritised over individual agency, and in the workplace, this manifests as unquestioned support for “safe and sexual harassment free workplace culture” without extending the principle behind this to examining one’s own behaviours, boundaries and participation in enabling harm. Prevention becomes a procedural obligation, and is even used for humour around reinforcing the binary coded stereotypes around women’s and men’s roles and experiences in the workplace, omitting the fact that workplace sexual misconduct has also been recorded as experienced by men. Meanwhile, in our experience, we find that redressal processes leave all parties dissatisfied: where respondents may view their behaviour as accidental and/or inconsequential, and survivors may pursue escalation as a stand against larger societal injustice, rather than their own healing. In using the term ‘women’, this paper includes individuals who may have been assigned female at birth (AFAB). 

Drawing on five anonymised cases from TrustIn’s practice, this paper outlines how integrating restorative justice (RJ) (11) principles into workplace processes may offer an alternative pathway to addressing sexual harassment, centring reflection, responsibility, repair and survivor agency. The paper does not specifically examine cases of “petty” or “egregious” sexual misconduct. Instead, it assumes that the binary categorisation of sexual harassment incidents as “petty” or “egregious” does not meaningfully capture the lived realities of harm, particularly given intersectional identities and contexts that determine the level of impact on survivors. 

Literature Review: Restorative Justice and its Application in the Indian Context

This paper grounds RJ principles as outlined by Howard Zehr (12). It situates sexual harassment in the workplace context as a form of harm that impacts the survivor, as well as the workplace, which constitutes “community”, and that both aspects are in need of restoration due to the pervasive nature of the issue. The paper uses the term “survivor” for those directly affected by the offense, and “community” for colleagues, witnesses and the organisation itself. In positioning the workplace as “community”, this paper draws on Zehr and Mika’s framing of harm as relational, and acknowledges that the Indian workplace experience is shaped by power of positionality, as well as socio-cultural identities, particularly gender, caste, class, disability, sexuality, and race, among others. Using the Indian Wheel of Power and Powerlessness(13), this paper is cognizant of the fact that socio-cultural identities deeply influence who is harmed and whose harm is recognised and whose is minimised. 

The paper further looks at restoration as a continuum of responses not just in the context of redressal of complaints of sexual harassment, but also preventative actions taken by the organisation to repair culture and build compassion through mindset shifts. Justice in the context of workplace misconduct is defined against Zehr and Mika’s principles by examining not just the “how” of redressal, but also the need for structural reformation of the narrative around sexual harassment. The Indian context is possibly underexplored in this regard: while it is acknowledged that RJ principles are combined with punitive principles of the POSH law, there is need for research and framing on how these principles can be applied within the statutory processes outlined in the law, honouring mandates, while prioritising repair. 

The paper attempts to add to existing literature around RJ principles and gender-based violence in the Indian context, by specifically exploring its applicability to workplace contexts within the framework of the POSH Act. It looks at obligations and liabilities created by violations in the context of the perpetrator and the larger culture of minimising the issue and reducing it to compliance obligations. It is grounded in the belief that the harm caused to the community or the organisation isn’t just limited to business and legal liabilities, but a cultural liability, and examines how RJ principles can move away from the “Chittha effect” – that centers vengeance and revenge as a form of justice, rather than reparation. The use of the terms “cultural liability” and “Chittha effect” is conceptual, and derived from observations in training, adjudication and advisory provided by TrustIn. 

Furthermore, the paper examines the need for shifting cultural norms that can support survivors themselves to come out of the “saviour” trap: an experience of sexual harassment can simply mean protecting and healing of the self, rather than a drive to contribute to the larger feminist discourse. This is grounded in the assumption that survivors are often conditioned due to the culture of shame and stigma around sexual violence (14), to look beyond themselves, and feel the obligation to explain their escalation as a move towards a “greater good” rather than the harm caused to them(15). Feminist trauma literature has discussed this phenomenon(16), and TrustIn’s practice reveals similar patterns. It is to be noted that this paper does not claim universality, rather that these tendencies may shape workplace reporting behaviours. It therefore, acknowledges that while reinforcing the feminist approach to countering sexual violence is critical, it must be a by-product of survivor empowerment and voice, rather than its sole focus. 

The paper recognises and firmly holds on to the principle that by taking accountability, the perpetrator is not being punished, but rather given a chance to examine their own actions and behaviours and re-align them to a future where they uphold values of safety and integrity in society. It moves away from the notion of repair as merely “forgiveness” and grounds itself in the principle that forgiveness itself is a path to recovery for the survivor, rather than a free ticket to the perpetrator. It looks at accountability as neither symbolic, nor purely punitive. Instead, it looks at opportunities for self-examination, behaviour correction and value realignment, aligning itself with RJ principles that emphasise responsibility and repair over blame. 

This paper attempts to embed the above values and philosophy to the workplace context by drawing on five anonymised cases from TrustIn’s practice, and reimagining how alternative pathways within the framework of the POSH Law can be integrated into preventing and addressing workplace sexual harassment. The five cases have been selected in a way that they highlight complexities that organisations must navigate, including power differentials, interpersonal histories, culture, and reputational and emotional repercussions of instances of sexual harassment. The use of case studies is intentional, purely because in TrustIn’s experience, workplace sexual misconduct has been found to be deeply contextual, necessitating deep contextualisation of universal principles, even those of RJ principles that this paper attempts to examine, to organisational contexts. 

The paper does not present RJ as an alternative to the processes outlined in the POSH Act. It recognises that procedural and legal limits of IC mechanisms under the POSH Act are articulated based on years of feminist experience and practice, and shaped to take forward the seminal Vishakha Guidelines of 1997 (17). It only attempts to examine possible gaps in implementing the law in its spirit rather than its wording, and add a layer that enhances understanding of harm and broadens opportunities for repair, encouraging proactivity and enabling meaningful outcomes for all involved parties. 

These gaps highlight the need to test RJ principles in real-world dynamics. The following section applies this conceptual lens to five case studies from TrustIn’s practice to offer potential pathways to meaningfully implement RJ principles in such contexts. 

Case Studies: Applying RJ Principles within POSH Framework

These case studies have been selected from TrustIn’s body of work in addressing workplace sexual harassment cases. Each case study was selected to highlight the range of harms they produced to the individual as well as relationally, to the community or organisation. 

Viewed through the RJ lens, these cases underscore how impact outweighs intent in such cases, and that “severity” of cases can be completely subjective, because harm can be experienced in different ways, particularly in light of how responsibility is negotiated between parties, and institutional responses impact the survivor experience(18). This reinforces RJ’s foundational principle that harm is relational, and centered on the survivor’s experience rather than the perpetrator’s perception of their actions. 

Further, the case studies highlight how survivors’ expectations from redressal are often framed to be broader than individual gains to enabling systemic safety, reflecting socio-cultural pressures, and fear of stigmatisation, shame and being labelled trouble makers. RJ principles ask survivors what they want and more importantly why they want it. Across these cases, the survivors’ requests for broader organisational change reflected their own fear, and also the unmet need for guarantees that similar harm would not be repeated. This has been an existing gap in POSH processes across different institutional contexts. 

It is to be further noted that self-doubt and fear dominated the survivors’ interactions through all five cases, while conviction in innocence and acceptance of responsibility was considered a favour by respondents in most cases. By centering accountability and repairing harm, RJ-informed principles may reduce impact and pave the way for relooking at addressing instances of sexual harassment as necessary ethical obligations, rather than negotiated settlements. 

Case Study 1: Accidental Touch and Ruptured Trust

A female employee alleged that a male respondent brushed against her. The respondent maintained that the touch was accidental due to crowding, but accepted that this may have impacted her due to her own experiences, implying that the burden of interpretation lay with the survivor. The IC lacked jurisdiction over the matter, which angered the survivor, stemming from a lack of clarity, support and procedural pathways. She repeatedly asked why such behaviour occurred in the first place, and why women were constantly exposed to risks in professional spaces. The need for explanation and assurance that harm would not recur was unmet.

This case study highlights how harm can arise because of strict procedural guidelines and the limitations of the POSH process. It also highlights the need for proactively clarifying institutional ambiguities to reduce fear, shame and self doubt. Seen through the RJ lens, it underscores how reframing apologies from a place of guilt to a place of accountability could reduce harm and provide survivor-led options outside strict statutory boundaries.

Case Study 2: Blurred Boundaries from a ‘Too Friendly’ Respondent

A female professional received overly informal communication from a male colleague within the broader work ecosystem. At an in-person gathering, he made an unwelcome physical advance, which left her deeply uncomfortable. She wanted him to take responsibility for his behaviour and ensure that speaking up would not affect her professional opportunities. The IC issued a reprimand and arranged training for the respondent. Although he appeared to understand the implications of his actions, he began taking excessive measures to prevent harm in the future, including ensuring he would never be alone with a woman again.

While the case appeared to be handled procedurally, the complainant’s central question (why a senior leader felt entitled to occupy that level of informality within the ecosystem) remained unanswered. Further, rather than acknowledging his own actions and the harm he created, the Respondent attributed the incident to circumstance, which, seen through an RJ lens, risked further relational harm within the organisational context, reinforcing the misconception that sexual harassment can only occur in binary contexts.

Case Study 3: Prior Labeling of the Complainant and Institutional Apathy

A woman from a religious minority, already seen in the organisation as a “difficult” employee for expressing dissent, felt uncomfortable when she saw two colleagues laughing and discussing something on their phones. From her perspective, they were discussing content of sexual nature. The IC, unable to establish the nature of content, issued a warning to the respondents. Confidentiality was breached by an unidentifiable party, and the complainant faced further ostracism from other colleagues. The complainant was frustrated not by the incident alone, but from wanting to understand why women had to absorb the social and professional backlash of reporting harm, while cultural norms holding such conduct in place remained unchallenged. 

Viewed from an RJ perspective, this case highlights how credibility, social positioning, and systemic exclusion compound relational harm, often leaving survivors more isolated after the process than before it.

Case Study 4: The Role of Positional Power 

A woman raised concerns about a newly appointed male supervisor, for repeated behaviours that made her uncomfortable, including asking colleagues for coffee breaks, offering a ride home, and singing in public. The matter was escalated to the grievance redressal body, which concluded that the behaviour could be reconsidered due to his seniority, but was not deliberately harmful. The woman was instructed to continue reporting to him, unrelated performance issues were raised, and eventually, she resigned. Her ask for a comfortable and safe work environment, specifically for those reporting to her, was unmet, and there was a significant gap in providing her with closure on the matter. Through an RJ lens, this case highlights that relational harm is not just produced by isolated incidents, but power asymmetry, institutional deflection and absence of safe spaces to articulate discomfort, lead to structures becoming punitive for survivors. 

Case Study 5: Late Night Calls and Subsequent Resignation

A female employee received a late night call from an inebriated coworker. When she questioned him, he abruptly hung up. After escalation, at her request, the matter was addressed through conciliation. Ongoing negotiations and an existing culture of hierarchy and fear in the organisation, by the time the conciliation was completed and the Respondent tendered an unconditional apology, she had already decided to resign from the company. 

The procedural outcome addressed the incident, but harm was not repaired. Rather, it laid bare systemic vulnerabilities, and the fact that apologies alone cannot compensate for meaningful individual and community actions to repair harm. 

Rethinking Workplace Sexual Harassment Mitigation and Prevention Measures through RJ Principles

The five case studies, by no means a comprehensive list, nevertheless show us that despite strict statutory guidelines for prevention and redressal in place, the POSH process continues to pose gaps in facilitating justice. This highlights the need for reimagining the definition of justice as viewed through the RJ lens: repair, accountability, survivor support and institutional intent, over simply relying on procedural stipulations and checkbox compliance. While the POSH Act, in its emphasis on prevention, does acknowledge that punitive action is not all that constitutes justice in such a matter, and does ground its framing within the context of larger community contexts and gendered realities of the society; in praxis, there is a need to develop the skill among organisations, employees and redressal bodies to add an RJ lens to minimising harm and creating a culture of care. As a step in this direction, five insights emerge from the case studies:  

1. Need for a shift from mere apology to accountability

While apology notes tend to serve as a warning and preventative measure against repetition of similar behaviours, they do not heal the harm already caused if they are merely performative in nature. In the first two case studies, such apologies and training sessions did not answer the survivors’ need for understanding, accountability and assurance of safety. 

Incorporating RJ principles would require organisations to foster genuine accountability, combining training and counselling to enable respondents to actively acknowledge harm and its impact, on the survivor, as well as the wider organisational community. This reframes the apology as a step toward responsibility rather than an admission of criminal intent. 

For this to take shape, the intent towards minimising such behaviours through cultural shift needs to flow from leadership, moving beyond bottom-line based arguments to true commitment towards creating a culture of safety. It necessitates a fundamental rethinking of how training and preventive measures are designed, moving them from procedural checkboxes to intentional, survivor-centered interventions that reduce relational harm and build trust, and undo the impacts of socialisation and conditioning, without focusing on reducing accountability. 

2. Survivor Support: Prioritising the Self

Across the case studies, a recurring theme is highlighted: survivors feel compelled to act not only for their own safety, but also for a ‘greater good’. On the face of it, this “saviour expectation” can be seen as self-imposed. However, in our practice, we have been able to see that this is a direct consequence of individual conditioning and the larger callousness and dismissal surrounding conversations around sexual harassment claims and the rights of women. 

Organisations must integrate RJ-informed training approaches and policy conversations, to enable survivors to center individual needs. Contributions to wider society, while an important outcome of one’s actions as a survivor or ethical bystander (19), should not become central to individual expectations. As we have seen through the case studies, these expectations often remain unmet, exacerbating trauma and harm, rather than focusing on repair and healing. It is important to acknowledge here, that organisations only form one spoke of the system that can meaningfully enable this, as family, community and society must continue to reinforce this messaging for it to take effect. Yet, as these institutions are deeply interlinked, beginning at organisational level offers a worthy starting point. 

3. Institutional proactive measures 

It is evident from the case studies that one-off training sessions and reactive measures are deeply inadequate in addressing workplace sexual harassment and the relational harm it creates for individuals and community alike. Integration of RJ principles requires organisations to move very intentionally towards embedding survivor centricism, minimisation of harm and building a culture of accountability into every level of organisational practice. 

In our practice, the following strategies have worked and can be further developed to shift towards RJ: 

1. Workshops focused on behaviour change and mindset shifts, rather than definitions and procedures

2. Setting up and following up with anonymised feedback loops

3. Enabling proactive confidential conversations and coffee chats to keep a finger on the pulse of company culture and prevent harm before it arises

4. Allied support in the form of mental health workshops, decentralising power and privilege, and equitable mentorship for growth and self-confidence of individuals

Collective organisational action would require organising prevention measures through rotational task forces to reduce the unfair burden of shifting culture from the IC, and ensuring that proactive measures are sustained rather than episodic.

4. Due process and the spirit of the law

While procedural safeguards are the cornerstone of the principles of natural justice outlined in the POSH Act, these case studies highlight that purely compliance focused approaches towards redressal may not adequately achieve meaningful outcomes for survivors. Purely compliance-focused processes often prioritise documentation, timelines, and jurisdictional boundaries over relational repair, leaving survivors’ needs partially or wholly unmet.

Instead, a shift to a philosophy that prioritises repairing harm rather than pure procedural protocols, can help us move beyond systems where apologies and punitive actions have a one-time effect, to a system that provides the reassurance of continuous action for a culture of compassion and safety. 

5. Recognising the IC as a part of the system

While the POSH Act specifically speaks about the vesting of the IC with powers of a civil court, in practice ICs are still a part of the organisation, and cases 3 and 4 illustrate how biases and assumptions among IC members can influence and exacerbate harm. Survivors are scrutinised, while respondents’ intentions are given the benefit of the doubt, leading to skepticism, delayed action, and even backlash.  

Thus, even with IC mitigation, relational harm can be multiplied and can perpetuate distrust among survivors and the community. Mitigating these prejudices requires ICs to be trained on intersectional power dynamics, and a very solid grounding in feminist principles. For an IC member to begin recognising and addressing their own prejudices, their understanding of the landscape of gender-based violence becomes paramount. And this needs to be done not once, but again and again, to build collective consciousness around the issue and enable the recognition of years of conditioning regarding the role of women and the nature of sexual misconduct. 

Conclusion and Organisational Implications

Read together, these insights suggest that RJ principles can provide a pathway to shift the central voice of experiences of sexual misconduct at the workplace (and possibly elsewhere, although this paper has not attempted to analyse that) remains with the survivor and community that is harmed, rather than focus on revenge, retribution, and punishment. To embed these principles in their culture, organisations can take the following measures: 

1. Demonstrated commitment from leadership towards a survivor-centered, proactive organisational culture, that moves away from compliance mandates and focuses on repair and harm, in specific cases, as well as the multi-generational harm that communities carry, stemming from a long legacy of normalisation of gendered norms and sexual violence 

2. Shifting IC biases through consistent training on the feminist principles of justice to prevent further harm, and to empower ICs to view cases through the RJ lens, rather than intentionality of the behaviour or procedural fulfillment

3. Embody the messaging that survivors are encouraged to care for their own healing and agency, and under no obligation to act for wider community or society. Safe, confidential avenues for expressing fears, and support and mentorship to the community to unlearn conditioning can help address lack of trust in commitment to safety. 

4. Integration and continuous upskilling of leadership and ICs on restorative processes alongside statutory POSH mechanisms to shift focus towards repairing harm and proactive prevention. 

   
   

Conclusion: Whose Voice Should Define Justice?

I started this paper stating that often, the survivor’s voice is left out when we define what justice looks like in the context of sexual harassment and misconduct. Perhaps, given where we are as a society, we need to shift that question to “Whose Voice Should Define Justice?” 

Integrating RJ principles into organisation culture can enable a slow shift that centres survivors and communities, prioritising trust, accountability and healing. While not a comprehensive or universal solution, this paper outlines some pathways that can guide us towards this ideal. 

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Notes

(1)  Kumar, S. U. Arun, dir. Chithha. Etaki Entertainment, 2023.

(2) The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013

(3) At TrustIn, we believe everyone deserves to be safe and empowered in their place of work, where we spend most of our time, and therefore our lives. We serve 120+ companies in setting up compliant and compassionate workplace systems to prevent, prohibit and redress sexual harassment using our award winning 3P (Program, Policy, Product) model.

(4) Social Action Forum for Manav Adhikar (SAFMA). Status and Functioning of Local Complaints Committees under the Sexual Harassment of Women at Workplace Act. National Human Rights Commission, 2019. PDF File. 

(5) “No #MeToo for Women Like Us”: Poor Enforcement of India’s Sexual Harassment Law. https://www.hrw.org/report/2020/10/14/no-metoo-women-us/poor-enforcement-indias-sexual-harassment-law

(6) National Academies of Sciences, Engineering, and Medicine; Policy and Global Affairs; Committee on Women in Science, Engineering, and Medicine; Committee on the Impacts of Sexual Harassment in Academia. Job and Health Outcomes of Sexual Harassment and How Women Respond to Sexual Harassment. National Academies Press, 2018. PDF File.

(7) McDonald, P. (2018). Job and Health Outcomes of Sexual Harassment and How Women Respond to Sexual Harassment. NCBI Bookshelf.

(8) The Internal Committee (IC) is the statutory body mandated under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, to receive, inquire into, and recommend action on complaints of sexual harassment in workplaces with ten or more employees, and is vested with limited civil court powers for the purpose of inquiry.

(9)  Mehta, A. (2017). Organisational Challenges in POSH Compliance in India.

(10) BBC News. “Sexual harassment at work: Indian firms urged to register on SHe‑Box.” BBC News – Asia, 02 Jan 2018. Web.

(11) Restorative justice (RJ), drawing on Howard Zehr’s foundational work, conceptualises harm as a rupture in people and relationships, and defines justice as the process of addressing the needs that arise from that harm, while supporting the person responsible to acknowledge, understand, and take active steps to repair the impact within the wider community.

(12) Zehr, Howard. The Little Book of Restorative Justice. Good Books, 2002. Print

(13)  Nair, Ganga, et al. Indian Wheel of Power & Powerlessness. The Listeners Collective, 11 Jan. 2023. Web.

(14) Nanda, V. (2000). Women, Work, and Culture in India.

(15)Herman, Judith. Trauma and Recovery. 1992.

(16) Herman, J. L. (1997). Trauma and recovery: The aftermath of violence—from domestic abuse to political terror (Rev. ed.). Basic Books.

(17) Supreme Court of India. Vishaka v. State of Rajasthan, Writ Petition (Criminal) No. 202 of 1992, AIR 1997 SC 3011. Web.

(18) Kelly, Liz. “The Continuum of Sexual Violence.” 1988.

(19) Martinez, Katherine, and Erika J. Vivyan. “Active Witnessing: Guiding Kids of All Ages To Do the Right Thing.” Anxiety and Depression Association of America (ADAA), 12 Oct. 2021. Web.

References:

1. Zehr, Howard. The Little Book of Restorative Justice (Revised edition). Good Books, 2015.

2. Social Action Forum for Manav Adhikar (SAFMA). Status and Functioning of Local Complaints Committees under the Sexual Harassment of Women at Workplace Act. National Human Rights Commission, 2019. Retrieved from https://nhrc.nic.in/assets/uploads/training_projects/Status_and_Functioning_of_Local_Complaints_Committees_under_the_Sexual_Harassment.pdf 

3. Government of India. The Sexual Harassment of Women at Workplace (Prevention, Prohibition & Redressal) Act, 2013. Act No. 14 of 2013. Retrieved from https://shebox.wcd.gov.in/assets/uploaded_content/Sexual-Harassment-at-Workplace-Act-_English1.pdf 

4. The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Rules, 2013, G.S.R. 769(E), Ministry of Women & Child Development, India, 9 December 2013. Retrieved from https://shebox.wcd.gov.in/assets/uploaded_content/SH_Rules,_20132.pdf  

5. Vishakha & Ors. v. State of Rajasthan & Ors., (1997) 6 SCC 241 (Supreme Court of India). (Vishakha Guidelines). 

6. Kumar, S. U. Arun (Director). (2023). Chithha [Film]. Etaki Entertainment.

7. Anxiety & Depression Association of America. “Active Witnessing: Guiding Kids of All Ages To Do the Right Thing.” ADAA. Retrieved from https://adaa.org/learn-from-us/from-the-experts/blog-posts/professional/active-witnessing-guiding-kids-all-ages-do

8. BBC News. “Is India really the most dangerous country for women?” BBC, 2018. Retrieved from https://www.bbc.com/news/world-asia-india-42436817

9. National Center for Biotechnology Information. Job and Health Outcomes of Sexual Harassment and How Women Respond to Sexual Harassment. In NCBI Bookshelf. (2018). Retrieved from https://www.ncbi.nlm.nih.gov/books/NBK519461/ 

The Listeners Collective. “The Indian Wheel of Power & Powerlessness.” TheListenersCollective.org. Retrieved from https://thelistenerscollective.org/indian-wheel-of-power-powerlessness/