Compliance or Compromise: Exploring Organizational Gaps in POSH Act Implementation Through Media and Legal Narratives in India

The Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act) obliges every employer to constitute an Internal Committee (IC), sensitise employees, display prescribed information, and report annually. More than a decade after its enactment, public reports, court judgments, and regulatory notices continue to document organisations that miss these mandates. The present study examines the reasons given for such gaps, the consequences recorded, and the way non-compliance is framed in media and legal narratives in India. A qualitative content analysis was carried out using secondary sources only. A purposive corpus of 200 publicly available articles was assembled in batches covering media reports, legal commentary, court judgments, reports of regulatory and government notices, organisational disclosures, surveys, and expert opinion blogs and articles, published between 2014 and 2026. Each article was recorded with its date, sector, organisation type, source type, epistemic status, and voice, and was then coded under four families: the mandate missed, the reason cited in the source, the consequence cited in the source, and the framing used in the source. Because the corpus is built from reported cases and a single event, the Tata Consultancy Services (TCS) Nashik matter, produces a large cluster of articles, the analysis is interpretive and does not treat article counts as a measure of how often non-compliance occurs. Four patterns stand out. First, the mandate most often reported as missed is the constitution of a legally valid IC, followed by defects in inquiry procedure, board-level disclosure, IC composition, and failure to act on complaints. Second, nearly half of the articles state no reason for non-compliance; where reasons are given, they point to structural and legal-applicability gaps, procedural errors, institutional neglect, and paper-only compliance more often than to awareness or resource constraints. Third, recorded consequences are mostly directives, inspections, court orders, and reputational reaction rather than fines, and the evidence for deterrence is thin. Fourth, the framing in media narratives (like negligence, ignorance, deliberate evasion) is present but is outweighed by systemic, procedural-fairness, and reform-oriented framings, with a visible shift after April 2026 (after the TCS incident’s reporting) towards governance and enforcement language. The report concludes that POSH compliance in India is better understood as a gap between legal form and organisational practice, shaped by legal design and enforcement as much as by employer attitudes. Findings are limited to reported cases and should not be generalised to all organisations.