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SBI Employee Gets Relief in Harassment Case as Bombay HC Rules Shared Auto Commute Not Covered Under POSH Law

Friday, July 3, 2026 | 6:31 PM (GMT-04.00) Last Updated 2026-07-03T22:35:48Z
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The Case of Mr. Satpute: A Legal Battle Over Workplace Harassment

For 14 years, Mr. Satpute, an employee at the State Bank of India (SBI), commuted to his office in the Bandra Kurla Complex (BKC) from Navi Mumbai. His daily routine involved taking a local train to Kurla and then a shared auto-rickshaw to BKC. However, on March 24, 2023, this routine took an unexpected turn when he found himself in a conflict with a woman who accused him of inappropriate touching.

The incident escalated quickly when the woman, who worked as a chef, exited the auto and sprayed pepper spray into Mr. Satpute’s eyes. She also filed a police complaint against him. Her company's internal POSH (Prevention of Sexual Harassment) committee received the complaint and forwarded it to SBI. After an inquiry, SBI's POSH committee concluded that Mr. Satpute was guilty and recommended disciplinary action. Feeling wronged, he appealed to the Bombay High Court.

Details of the Incident

On March 24, 2023, Mr. Satpute took a shared auto from Kurla to BKC as part of his usual commute. The auto had three passengers, including the woman in question. She sat at the entrance of the back seat, and Mr. Satpute was seated next to her, with a third passenger to his right. During the bumpy ride, several times Mr. Satpute’s left hand touched her bag, which she was carrying on her right arm.

The woman interpreted this as inappropriate behavior and made the auto stop near the American Embassy. She began abusing Mr. Satpute, accusing him of touching her chest. She then sprayed pepper spray into his eyes and started shouting, drawing a crowd. She continued to make accusations and used abusive language.

Fearing for his safety, Mr. Satpute got off the auto and stood near IDFC Bank. There, he claimed to be the son-in-law of an Ex-Assistant Commissioner of Police, Mumbai, and called his father-in-law and the Mumbai police. A police van arrived, and Mr. Satpute was taken to the BKC police station, where a case was registered under Section 354A of the Indian Penal Code, 1860.

Legal Proceedings and SBI’s Response

The woman also lodged a complaint with her company's Internal Complaint Committee (ICC), alleging sexual assault. This complaint was forwarded to SBI, which referred the matter to its own Internal Complaint Committee (SBI ICC). After an inquiry, SBI's internal committee found Mr. Satpute guilty of sexual harassment and recommended disciplinary action.

On November 28, 2023, Mr. Satpute filed an appeal against the August 2023 internal committee order. He also approached the Bombay High Court, which issued an interim order directing SBI not to pass any final order without the court’s permission.

The Bombay High Court’s Judgment

On June 16, 2026, the Bombay High Court canceled SBI's internal committee order against Mr. Satpute, stating that a shared auto is not considered a workplace. The court emphasized that for an incident to fall under the definition of "workplace" as per Section 2(o)(v) of the Sexual Harassment Act, the transportation must be provided by the employer. In this case, the shared auto was not provided by either party’s employer.

The court clarified that since the alleged incident did not occur at a workplace, SBI's internal committee had no jurisdiction to entertain the complaint. Therefore, the August 29, 2023, order was deemed unsustainable in law and was set aside.

Key Points from the Judgment

  • Workplace Definition: The court held that a shared auto does not qualify as a workplace unless it is provided by the employer.
  • Jurisdiction of Internal Committees: According to Section 9 of the Sexual Harassment Act, internal committees can only handle complaints if the incident occurs at a workplace. Since this condition was not met, SBI’s committee had no authority.
  • No Merits Review: The court explicitly stated that it did not review the merits of the case but focused solely on jurisdictional issues.

Conclusion

The Bombay High Court's ruling has significant implications for how workplace harassment is defined and addressed. It clarifies that internal committees cannot act on complaints that do not meet the strict criteria of a workplace. While the court left the issue of whether Mr. Satpute committed harassment open for further legal proceedings, it emphasized the importance of adhering to the legal definitions of "workplace" in such cases.

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