“Dignity does not consist in possessing honours but in deserving them” - Aristotle

Women as the integral part of human kind, their contribution in the work of all sectors are very remarkable in the modern world. Women’s participation in economic sector is crucial for their economic empowerment and their sustainability. Due to globalisation and modernisation, the economic development around the world demand huge labour force which has in turn paved way for women to emerge as one of the important sources of labour force. It is remarkable as women are working on par with men; some issues are excelling in their own field. Women are experienced to exploitation where the nature has created for men through giving the psychological advantage seeming to be more powerful physically than women. This exploitation such as sexual harassment in the workplace discourages women to continue working. It is increasingly being recognized as a violation of human rights and human dignity, which undermines equality of opportunity and treatment between men and women. As women’s participation is growing in economic employment sector, the problem of sexual harassment is necessary to address to ensure safe and healthy working environment for them.

Women have been exploited since age immemorial in different fields in their life, both physically, socially, mentally and economically. With more women are visible and joining at the work force, such exploitation against women, sexual harassment is growing concern and also simultaneously remain unexplored. Because Indian woman bearing the torch of cultured are living through self-sacrifice, physical and mental tolerance. Still the women’s struggle to live life in dignity continues. Sexual harassment at the workplace has been one of the central concerns of the women's movement in India since the '80s. It is not just open violence in the modesty of women but also it violates basic fundamental right to dignity of women under the Constitution. The recognition of the right to protection against sexual harassment is an intrinsic component of the protection of women's dignity at workplace.

Sexual harassment to a woman at workplace is not only the violation of her constitutional rights but also violation of her human rights. It creates an insecure, unsafe and hostile work environment, which discourages women’s participation at work; thereby adversely affect their economic empowerment and the goal of inclusive growth. It hinders the women to reach at an inequitable position as compared to the male employees. Safe working environment is essential for the exercise of the right to work, the right to life with dignity. It is an employer’s responsibility to provide a non-discriminatory and non-violent workplace atmosphere for his/her employee. Employers and employee both are required by law to take steps to prevent and deal with harassment at the workplace. Before 1997, a woman experiencing sexual harassment at workplace had to lodge a complaint under Section 354 IPC that deals with the “criminal assault of women to outrage women’s modesty” and Section 509 IPC that punishes an individual for using “a word, gesture or act intended to insult the modesty of a woman”. These sections left the interpretation of “outraging women’s modesty” to the discretion of the police officer. In the absence of civil and penal laws in India, for providing adequately and specific protection to women from sexual harassment in the work places, in 1997, the Supreme Court passed a landmark judgment in Vishaka vs. State of Rajasthan laying down guidelines to be followed by establishments in dealing with complaints about sexual harassment.

Prevailing reasons for sexual harassment of women at workplace are in the society as a whole but some are very specific to workplace. These are: 1) The fundamental reason behind any type of harassment against women lies in our society’s patriarchal structure of male superiority complex. A male colleague does not like his female co-employee to work with him equally or he does not like her to reach at a higher position in the office. To make a women feel inferior or to make her uncomfortable, they harass her. 2) Sexual perversion of mind among certain individuals is also one of the major reasons of sexual harassment of women at workplace. 3) Jealousy at workplace is also a reason for such crimes against women employees; a male employee would not like to see his female colleague to get success, promotion or incentives by the employer. 4) Feeling of contempt and disrespect for women among male species is also a prominent reason whereby women are considered only as an object to fulfill sexual desires of men. Male colleagues think them as their object of play, vulgar comments and jokes, obscene gestures, gossips of sexual nature.

The Vishaka Guidelines (1997) for the first time in India’s history seek to ensure safe working environment for women, acknowledge the sexual harassments of women at the workplace as a human rights violation. It includes any sexually oriented practices or behaviours that endangers a woman’s continued employment, negatively affects her work performance or undermine her sense of personal dignity. In this backdrop, the article attempts to analyze the guidelines regarding sexual harassment at workplace as protecting women’s dignity, and its pragmatism as per the present changing society.

OBJECTIVES:

· To define the concept of sexual harassment faced women at the work place.

· To explore the vishaka guidelines on sexual harassment of women at workplace in India.

· To understand the perception of women on sexual harassment issues and proper applicability of the guidelines.

· To suggest measures for effective implementation of the guidelines to prevent sexual harassment at work place.

METHODOLOGY:

The research methodology adopted for this paper was doctrinal and sources of information are secondary. The study is based on content analysis. So, it includes various previous researches on sexual harassment of women in the workplace, published as reports, case laws and articles in books, newspapers, websites etc.

Vishaka Guidelines:

The Vishaka Guidelines are a set of procedural guidelines for use in India in cases of sexual harassment of women. The initiative on a discourse on sexual harassment of women at their workplace in India started with Supreme Court’s order on Vishaka guidelines in 1997. These guidelines, directed toward employers, included a definition of sexual harassment, a list of steps for harassment prevention, and a description of complaint procedures to be "strictly observed in all work places for the preservation and enforcement of the right to gender equality." It has been quoted in the landmark Vishaka judgment, “Each such incident results in violation of the fundamental rights of 'Gender Equality' and the 'Right to Life and Liberty'.

Definition of Sexual Harassment:

Sexual harassment of women is all about expression of male power over women that sustain patriarchal relations. It is the expression and activity of men as women into their vulnerability and subjugated status. In a society where violence against women, both subtle and direct, is borne out of the patriarchal values operating in society, force women’s conformity to age old traditional gendered roles. These patriarchal values and attitudes pose the greatest challenge to men and women both in resolution and prevention of sexual harassment.

Catharine Mackinnon (1979) defines sexual harassment as "unwanted imposition of sexual requirements in the context of relationship of unequal power." Likewise, Kathleen Gallivan (1991) defines sexual harassment as "any type of unwanted sexual or gender oriented behaviour that has adverse job-related effects." Sexual harassment is a behaviour for which there are no apparent boundaries or succinct meanings. Academic definitions of sexual harassment focus on a behaviour, which has a sexual connotations, is unwelcome and uninvited, and could consists single or repeated acts (Barr, 1993).

The Vishaka Guidelines clearly states that the definition of sexual harassment is such unwelcome sexually determined behaviour as:

§ Physical contact and advances

§ A demand or request for sexual favours

§ Sexually coloured remarks

§ Showing pornography

§ Any other unwelcome physical verbal or non-verbal conduct of sexual nature

Scope of Workplace:

The periphery of workplace in the Sexual Harassment (Prevention, Prohibition and Redressal) Act, 2013, includes:

(i) Any department, organization, undertaking establishment, enterprise, institution, office, branch or unit which is established, owned, controlled wholly or substantially financed by funds provided by the appropriate government or the local authority or a government company or corporation or a co-operative society.

(ii) It also includes private sector organization or a private venture, undertaking enterprise, institution, establishment, society, trust, non-governmental organization, and unit or service provider carrying on commercial, professional, vocational, educational, entertaining, industrial, health services or financial activities including production, supply, sale, distribution or service.

(iii) Hospitals or nursing homes.

(iv) Any sports institute, stadium, sports complex or competition or games venue, whether residential or not, used for training, sports or other activities relating thereto.

(v) Any place visited by the employee arising out of or during the course of employment including transportation provided by the employer for undertaking such journey.

(vi) In relation to unorganized sector, workplace means an enterprises owned by individuals or self-employed workers and engaged in the production or sale of goods or providing service of any kind whatsoever and where the enterprise employs workers and the number of workers is less than ten.

Preventive steps:

All employers or persons in charge of work place whether in the public or private sector should take appropriate steps to prevent sexual harassment. These are -

· Sexual harassment should be affirmatively discussed at workers' meetings, employer-employee meetings, etc.

· Guidelines should be prominently displayed to create awareness about the rights of female employees.

· The employer should assist persons affected in cases of sexual harassment by outsiders.

· Central and state governments must adopt measures, including legislation, to ensure that private employers also observe the guidelines.

· Names and contact numbers of members of the complaints committee must be prominently displayed.

Complaints Procedures:

The Vishaka judgement had recommended a Complaints Committee at all workplaces, headed by a woman employee, with not less than half of its members being women. All complaints of sexual harassment by any woman employee would be directed to this committee. All women who draw a regular salary, receive an honorarium, or work in a voluntary capacity in the government, private sector or un-organised sector come under the purview of these guidelines. The complaint mechanism should be adequate to provide Complaints Committee, a special counsellor or other support service, including the maintenance of confidentiality. Further, to prevent the possibility of any undue pressure or influence from senior levels, such Complaints Committee should involve a third party, either NGO or other body who is familiar with the issue of sexual harassment. The Complaints Committee must make an annual report to the Government department concerned of the complaints and action taken by them. The complaints procedure must be time-bound. Confidentiality must be maintained.

The said guidelines made it mandatory for employers to protect their female workers from sexual harassment; proper enquiry was made necessary in case of any complaint of such nature; it was directed that every organization must have a Complaint Committee headed by a woman to deal with such misconducts readily; rules prohibiting sexual harassment should be notified and publicized; penalties are to be imposed in case of violation of said rules; also, employers were directed to protect their women employees from third party harassments.

Vishaka Case (A True Incidence) :

The Vishaka guidelines arose out of the case of gang rape of Bhanwari Devi, was a village-level social worker or a member of a group of women called Saathins (friendship group) of a development programme run by the State Government of Rajasthan, fighting against child and multiple marriages in villages. As part of a governmental campaign against child marriage, Bhanwari, with assistance from the local administration, tried to stop the marriage of Ramkaran Gujjar's infant daughter who was less than one year old. Members of the local community retaliated first by harassing Bhanwari Devi with threats and imposing a socio-economic boycott on her family. Then, on 22^nd September, 1992, five men including Ramkaran Gujjar raped Bhanwari Devi in the presence of her husband.

The days that followed were filled with hostility and humiliation for Bhanwari and her husband. Bhanwari Devi faced numerous obstacles when she attempted to seek justice. The police publicly disclaimed her complaint and were reluctant to record her statement or conduct an investigation, and doctors at two government health facilities refused to conduct a proper medical examination. The trial court acquitted the accused, but Bhanwari was determined to fight further and get justice. She said that she had nothing to be ashamed of and that the men should be ashamed due to what they had done. Her fighting spirit inspired fellow saathins and women's groups countrywide. In the months that followed they launched a concerted campaign for justice of Bhanwari.

Naina Kapur, a lawyer who had attended Bhanwari Devi's criminal trial, addressed the issue of sexual harassment of women at work place by initiating a PIL (Public Interest Litigation) in the Supreme Court. A three-judge bench of the Supreme Court delivered the Vishaka judgment on August 13, 1997. The decision, written by then chief justice J. S. Verma, described Bhanwari Devi's gang rape as an illustration of "the hazards to which a working woman may be exposed," "the depravity to which sexual harassment can degenerate," and the urgent need "for safeguards by an alternative mechanism in the absence of legislative measures." On December 1993, the High Court said, "it is a case of gang-rape which was committed out of vengeance". As part of this campaign, the groups had filed a petition in the Supreme Court of India, under the name 'Vishaka', asking the court to give mandatory guidelines regarding the sexual harassment that women face at the workplace. The result is the Supreme Court judgement, which came on 13th August 1997, and gave the Vishaka Guidelines.

Women’s Right to Live with Dignity:

The International Labour Organization (ILO) Committee on Gender Equality (2009) recorded that apart from many other problems that women face at their workplaces, they are also subjected to widespread sexual harassment, often excluded from protections and benefits, and face multiple forms of discrimination, such as race and age. Mostly it is used as a weapon to punish women who deviated from traditional gender roles (Berdahl, 2007).

The preamble of the Constitution of India contemplates that it will secure to all its citizens - “Equality of status and opportunity.” Sexual harassment vitiates this basic motive of the framers of the constitution. The Constitution of India provides that there should be equality in every respect. Women have the right to work in a secure as well as good environment. The regulations for the relief of women were made compulsory to be displayed in all concerned organizations. It imparts dignity to working women. The right of women to protection from sexual harassment and the right to work with dignity are recognized as universal human rights by international instruments such as the Convention on the Elimination of all Forms of Discrimination against Women (CEDAW), which has been ratified by India on the 25th June, 1993. Sexual harassment is a clear violation of woman’s right to gender equality as guaranteed under Articles 14 and 15 (Right to Equality and prohibition of any discriminatory practices), her right to live with dignity under Article 21 (Right to Protection of Life and Personal Liberty) and her right to work with dignity in a safe environment under Article 19 (1) (g) of the Constitution of India. Sexual harassment of women at workplace is also a violation of the right to life and personal liberty as mentioned in Article 21 that no person shall be deprived of his life or personal liberty. Right to livelihood is an integral facet of the right to life. Sexual harassment is also the violation of the right to livelihood. For the meaningful enjoyment of life under Article 21 of the Constitution of India, every woman is entitled to the elimination of obstacles and of discrimination based on gender. Since the ‘Right to Work’ depends on the availability of a safe working environment and the right to life with dignity, the hazards posed by sexual harassment need to be removed for attaining these rights. Dignity is a basic value dealt strictly with the individual. Article 51-A declares that the fundamental duty of every Indian citizen is to renounce practices to respect the dignity of women. Indian Parliament has passed the Protection of Human Rights Act, 1993 for the proper implementation of Article 51-A. Apart from this, in India, National Commission for Women (NCW) had been established in 1990 to look into the women’s problem. NCW have engaged them to deal with the cases relating to the violation of women’s rights. They have the duty to pressurise the government to pass stricter laws to deal with the violation of women’s rights and dignity. Such violations attract the remedy under Article 32 for the enforcement of these fundamental rights of women.

Thus, dignity could have to do with equality, self-fulfilment, the right to be treated as human being and the right to not be degraded or subjected to humiliation. In 2013, the Criminal Law (Amendment) Act, introduced changes to the Indian Penal Code, making sexual harassment an expressed offence under Section 354 A, which is punishable up to three years of imprisonment and or with fine. The Amendment also introduced new sections making acts like disrobing a woman without consent, stalking and sexual acts by person in authority an offence.

Pragmatism of Vishaka Guidelines:

Vishaka had a revolutionary impact. Long sixteen years of sustained efforts by the women’s movement resulted in enactment and enforcement of the Sexual Harassment Act has been legislated by the Supreme Court in its landmark of Vishaka guidelines. It is true that before Vishaka, the language of sexual harassment remained coded, invisible, and frivolous in India. The Sexual harassment at workplace Bill was passed by the Lok Sabha on the 2^nd of September, 2012. The act is named as the Sexual Harassment of women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.The Preamble of the act clearly says that the aim of the act is to prevent women from such harassment which is against the dignity of women at workplace. It recognises that every woman has a right to work with dignity. As per this act no women shall be subjected to harassment at any workplace.

The recently aroused question is that whether the guidelines are being properly used by the victimised women or not. Now it is the time to think about its pragmatic reality. Because in practice, law is very strict about this matter, but still the conditions of working women do not improve. The sexual dimension of harassment was disabling and unspoken (Kapur, 2009). Research suggests that woman’s responses to sexual harassment fall along a continuum of avoidance, diffusion, negotiation, and confrontation (Gruber, 1989). Poor and faulty implementation of the Vishaka guidelines was discussed in articles by Oversier (2010) and Majumdar (2003). Oversier (2010) stated that considering the social taboos still associated with sexual harassment and the long pendency in courts; provisions on sexual harassment have never been successfully invoked. They confirm that the issue of sexual harassment has largely been swept under the carpet in India. These articles reveal that overall awareness among Indian companies about the need for a well defined mechanism to tackle sexual harassment at the workplace is terribly poor. The subsequent official organization under state that deals with the victimised women in India is the Police. Often the crimes against the women go unregistered because of the insensitive nature of the police in handling those issues (Agnes et al, 1999). As per study in industrialized countries, 42-50 percent of female workers have been sexually harassed (Kailash, 2014). An article highlighted that for every 500 instances of harassment, only 50 got reported and only one got registered as an FIR (Ghosh, Puri and Dewan, 2010). Though sexual harassment is rampant in corporate India, as stated by Shukla (2002), it is the most under reported form of gender discrimination. Most of the incidents are un-reported, because, above 80 percent of the participants of the study opined that the key reason for sexual harassment incidents at educational institutions is the result of lack of courage, fear of disgrace and social isolation experienced by the victimised person on filing of a complaint against the abuser (Thomas, 2015).

An eye-opening true incident needs to be reported here, which forms a part of a survey done by Paramita Choudhari (2006), Fellow, Health and Population Innovation Fellowship Program, where a 36 years old nurse narrates - “After an open heart surgery, a patient is kept in the observation room adjacent to the operation theatre. The sister has to stay there with the patient for some time. The doctor is not supposed to visit the patient unless he is called for. One day when I was in the observation room adjusting some equipment fixed on a patient, a senior doctor came in and embraced me from the back. I could not move my hand as then the patient’s life would have been at stake. So I continued doing what I had to till he released me.” This is the true state of affairs today.

Several organizations have carried out the research on sexual harassment at workplace that has been widely disseminated. The Saheli survey (1998) done with sixty-five women conclude that despite the wide prevalence of the problem, sexual harassment at workplace was not recognised as a systemised form of violence. For the majority of women working in small private firms and factories, it was difficult to take direct action due to job insecurity. The frequency and severity of harassment increased as the income levels decreased and that majority of the women had no option but to tolerate harassment. Studies by Sanhita (2000) in Kolkata, Yugantar Education Society (2003) in Maharashtra and multistate study done by Sakshi (2001) reconfirmed that sexual harassment of women (SHW) at workplace was rampant but not reported due to fear of stigma, loss of reputation and widespread blaming and disbelief in the complaints. Studies in India by Lawyers Collective (2002) and Yugantar (2003) mentioned that, most women respondents did not complain to supervisors or the management about their experiences of sexual harassment at work and dealt with it on their own. They did not report due to fear for further harassment, apprehension of adverse effect on their employment, lack of confidence in the complaints mechanism, possible defamation or threats from the perpetrators and other such reasons. Amongst all the twenty-two countries covered by the IPSOS - Reuters survey (2010), India recorded highest incidence of sexual harassment. According to the survey, India topped in 24 countries across the world with a participant size of 12 thousand persons showed that women workers in India were most likely to report sexual harassment at workplace with a rate of 26 percent. Similarly Centre for Transforming India survey (2010) revealed that nearly 88 percent of women witnessed some form of workplace sexual harassment during the course of their work. Additionally, the survey found that there were poor awareness levels among female employees on workplace sexual harassment and therefore majority of them continued with their ordeal of suffering due to fear of professional victimisation. A survey by Sakshi (Delhi) throws up some worrying data: 80 percent of respondents revealed that SHW exists, 49 percent had encountered SHW, 41 percent had experienced SHW, 53 percent women and men did not have equal opportunities, 53 percent were treated unfairly by supervisors, employers and co-workers, 58 percent had not heard of the Supreme Court's directive of 1997, and only 20 percent of organisations had implemented the Vishaka guidelines (Dalal, 2003).

The Workplace Sexual Harassment Survey (2010) carried out by Centre for Transforming India in the Information Technology with 600 women working in IT and BPO industry across all the major IT destinations of India showed that nearly 88 percent of the women witnessed some form of workplace sexual harassment during the course of their work. Additionally there were poor awareness levels among female employees on the issues and workplace sexual harassment. Majority of female employees continued with their ordeal of suffering from the incidents of sexual harassments due to fear of professional victimisation.

A survey done by Oxfam India and the social and rural research institute in 2011-2012 showed a high incidence of sexual harassment taking place in both organized and unorganized sectors and women facing incidents that are non-physical. A November 2012 study by Oxfam India and Social and Rural Research Institute found out that 17 per cent of working women faced sexual harassment at their workplace. The study was done in Delhi, Mumbai, Bangalore, Chennai, Kolkata, Ahmedabad, Lucknow and Durgapur, among working women from the organized and unorganized sectors. Among sectors, the three that emerged as 'unsafe' for women were labourers (29 per cent), domestic help (23 per cent) and small-scale units (16 per cent). The report concluded that while a majority of respondents were aware of such acts, they were reluctant to take any formal action due to "fear of losing the job", "absence of any complaints mechanism at the workplace", "fear of getting stigmatized" and "not aware of redressal mechanism".

In the question of pragmatism, the guidelines are not so effective. Research shows that the incidence of sexual harassment of women at workplace is present at every level of society. In most cases, the harassments are unexposed and unidentified due to victims’ attitude of inertness to come in the forefront. From the perspective of victims, it is being experienced that they are not coming to court due to several reasons such as feeling of shame and facing of extra harassments, the fear of what society would think about them, the fear of losing their job and also the feeling that the culprits would walk away without any punishment.

CONCLUSION:

It can firmly be said that discourse on sexual harassment at workplace in India both in research and practice began largely after the Vishaka guidelines (1997) came into existence. Here, sexual harassment is an issue that largely remained in closet till about the eighties. Also, it is firmly concluded that the incidence of sexual harassment at workplace is increasing day-by-day and the law which is strict enough need to be strictly applied. Women should also be able to work in a secure as well as good environment. Their dignity should be maintained and not harassed by any act of any person. It is desirable that sexual harassment does not occur and, where it occurs, to ensure that adequate procedures are readily available to deal with the problem and prevent its recurrence. The victim or aggrieved women need to come to court without hesitation of any kind. Also the loopholes emerging during practical application of the guidelines need to be sort out. It is important that the guidelines do not remain only in empty words and should be upheld in practice. Here few suggestions are being outlined to make the guidelines effective for providing women the harassment free workplace.

SUGGESTIONS:

Our goal should be to instil a culture that every woman shall have a right to be free from sexual harassment and the right to work in a sexual harassment free environment. In any civilised society, it is the fundamental right of every people to be able to lead their lives with dignity, free from any mental or physical torture. To ensure this, transgressors must pay for their unsolicited sexual advances. At the same time organisations such as Men Against Violence and Abuse, that conduct gender-sensitisation programmes and self-defence classes to combat sexual harassment at the workplace, must be encouraged (Sadani, 2003). There is a need to be the society of gender-sensitised so that the victim does not feel guilty and is encouraged to report against any form of harassment or torture. The persons attached to provide justice must be gender sensitized so that there is no extra consequential harassment of women at their hands. The police and the judiciary, in particular, also need to be gender-sensitised. The victim's privacy must be protected. The victimised women need to come forward to the court without fear of any kind. Women themselves should be aware of their right to a safe and harassment-free work environment. A Sophia Centre for Women's Studies and Development study shows that awareness and implementation of the Supreme Court's guidelines is very low and there is a need to spread awareness about the same. The concept and definition of sexual harassment should be clearly laid down, and the redressal mechanism made known to women in each and every sector of the economy. Clear structures and mechanisms should also be created for women in the unorganised/informal sector to combat the harassment. The apex court must direct the various workplaces to form sexual harassment committees within a stipulated time frame. There should be speedy redressal and not to delay to get justice for the victim.

Following the guidelines, the law making, law interpreting and law enforcing bodies are diligently doing their work. Also, they further need to do is:

· Make some easily reachable bodies in which women from local areas do not hesitate to bring the problem to the front so that a solution could be easily found.

· The executive body has to work very diligently and in unbiased way in this field because normally such type of exploitation takes place inside the four corners of the workplace.

· The judicial system has to work for proper implementation of the law and be so strict that the culprit should not escape through using some loopholes.

· Private bodies who are working in the field of women empowerment should start some helpline numbers etc. so that women could take necessary measures as per their requirement. Also they must reach in remotest corner in every country and make a campaign for awaking women.

· The Law should be implemented for all without any discrimination, irrespective of any caste and power.

Actually, patriarchal attitude and values are biggest challenges in the implementation of this guideline or law regarding changing women position in our society. Till the basic human dignity of women is not recognized and respected by men, no law will be effective. Law alone is not enough to root out this social evil. Society has to change its attitude so that women can come out and participate in public life without feeling threatened. There is the need to be inculcated to make a sense of mutual respect between men and women. There is a divinity in each of us. The recognition of this divinity will automatically bring forth mutual self-respect and that alone will be source of liberation and dignity of women. As the present Prime Minister, Narendra Modi said “Dignity of women is our collective responsibility. There should be no compromise in this matter. There should be no erosion in the law and order situation. We have to retrieve the family culture in which a women is respected and considered equal, her dignity encouraged.” Whatever may be, it is important to keep this in mind that the need to establish a gender-friendly society demands a humanistic and persistent effort, as the saying goes on, ‘Women’s rights are also the human rights to work with dignity.’

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Received on 11.05.2016

Modified on 27.06.2016

Accepted on 10.08.2016

Research J. Humanities and Social Sciences. 7(4): October- December, 2016, 229-237.

DOI: 10.5958/2321-5828.2016.00037.1