Respected Sir,

I wish to submit a formal complaint regarding an incident of sexual harassment that I have experienced at Competition Commission of India on 04.10.2023. The conduct of Yogesh Kumar Dubey has caused mental distress and has adversely affected my dignity and work environment.

I submitted a formal complaint regarding sexual harassment at CCI on 09.10.2023. However, the Internal Complaints Committee (ICC) that examined the matter appeared biased and did not conduct the proceedings in a fair and impartial manner. The process caused me significant mental distress and failed to ensure a just inquiry.

Despite bringing the matter to the notice of the appropriate authority/department mentioned below:

1.       Ministry of Women and child development- filed complaint dated 25.01.2024

2.       District Labour Office (South-West District), Labour Department, Government of NCT   of Delhi. – Filed complaint dated 29.01.2024

3.       Delhi Commission for Women, Govt of Delhi- filed complaint dated 31.01.2024

4.       Ministry of Minority affairs- Complaint/ Registration No.- M/DL/00011/2024

5.       National commission for women- 23.01.2025 – Receipt number – 2014111440478

6.       NCWRegistration / File No.: 8/C240001743/2024/NCW/MEM/ND- 01.02.2024

7.       SAMADHAN Portal, Ministry of Labour and employment – Application id-300061050(24-01-2024)

No adequate action has been taken so far except the National Commission of Women. Sexual and mental harassment frequently occurs with contractual staff such as interns, Young Professionals, and consultants in CCI. I was the first person to file a written complaint against such misconduct, and as a consequence of raising this issue, I was removed from my job.

Statement of Complaint under the POSH Act, 2013

This complaint is being submitted under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013.

 1.      Incident dated 29.09.2023 (Around 4:00 PM)

I was called to the cabin of Yogesh Kumar Dubeywhere K.P. Anand was present. In the presence of colleagues (MTS Harpal and D/O Sudha), K.P. Anand publicly humiliated and verbally abused me, calling me “useless” and stating that I should be given zero and removed from service.  K.P. Anand had also previously subjected me to verbal abuse over phone calls, including late evening calls, causing sustained mental trauma.

This conduct amounts to creating an intimidating, hostile and humiliating work environment under Section 3(2)(iii) of the POSH Act.

When I objected, I was directed to leave the cabin. Despite being visibly distressed, I was forced by Yogesh Kumar Dubey to return to his cabin causing further mental harassment.

2. Incident dated 03.10.2023 (Around 10:00 AM)

Yogesh Kumar Dubey assigned urgent work with an extremely short deadline and repeatedly summoned me to his cabin for minor clarifications that could have been addressed otherwise. He is habitual of mentally harassing me by calling again and again for unnecessary reasons. He used to stare at me in a very bad way and I always felt uncomfortable in his presence and just wanted to get away from his cabin as soon as possible. His repeated unnecessary calls and uncomfortable conduct created a hostile and intimidating work environment, violating Section 3(1) of the POSH Act.

3. Incident dated 04.10.2023 (Around 4:00 PM)

He was calling me again and again, I entered his cabin and informed Yogesh Kumar Dubey that I was suffering from high fever,“he pulled his chair and come closer to me and asked me to come close and give me your hand I will touch you and see how much fever do you have?”. This statement constitutes sexually colored conduct and unwelcome physical proximity under Section 2(n)(i) and Section 2(n)(iii) of the POSH Act.

I clearly refused and immediately left the cabin. The same day, I reported the matter to Shri Anurag Pandey (Assistant Director, HR) and Ms. Savita Mishra (Office Manager, HR).

Legal Grounds

The above conduct amounts to:

• Creation of a hostile, humiliating and unsafe work environment (Section 3(2))
• Unwelcome sexually coloured remarks and conduct (Section 2(n))
• Abuse of authority and misuse of supervisory position

The actions complained of violate my right to a safe working environment guaranteed under Section 3(1) of the POSH Act, 2013, as well as Articles 14, 15 and 21 of the Constitution of India.

The chronological sequence of events is stated below:

09.10.2023 – I filed a formal complaint before the Internal Complaints Committee (ICC) of the Competition Commission of India (CCI) under the provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 (POSH Act).

18.10.2023 and 31.10.2023 – I sent reminder emails requesting urgent action. However, the ICC failed to initiate proceedings in accordance with the procedure prescribed under the POSH Act, 2013. Instead of commencing a lawful inquiry, I was merely shifted from my previous seating location. Following the complaint, several colleagues stopped communicating with me and began treating me in a discriminatory and socially isolating manner.

The matter was deliberately delayed. At the relevant time, I was serving as a Young Professional at the Competition Commission of India (CCI), and my contract extension was due in January 2024. No substantive action was taken until December 2023. Suddenly, in January 2024, the ICC initiated proceedings; however, the inquiry appeared biased in favour of the Charged Officer. The questions posed to me were intimidating and framed in a manner that attempted to put words into my mouth. The conduct of the Committee members was adversarial and prejudiced, as though I was being subjected to a criminal trial rather than a fact-finding inquiry under the POSH Act.

01.02.2024 – This was the last date of my one-year contractual tenure. Until the final date, I repeatedly requested consideration for extension based on my performance and work record. However, Mr. Anurag Pandey, Assistant Director (HR), informed me that “the competent authority had decided not to extend my contract because I had filed a sexual harassment complaint against their officer” (voice recording attached as evidence).

I have also attached the Contract Renewal Application Form duly signed and recommended by Advisor Jyoti Jindgar of my Division, which clearly reflects that my performance was assessed as excellent, efficient, and diligent. Despite this documented record, my services were discontinued solely because I filed a complaint of sexual harassment against their officer.

 Further, the organization initially refused to issue my experience certificate, compelling me to send multiple emails, including to the Secretary of CCI, before it was eventually issued.

October 2023 – January 2026 :  The ICC of CCI failed to conclude or meaningfully proceed with the inquiry. The National Commission for Women sent multiple reminders to CCI on 01.02.2024, 06.02.2024, 09.04.2024, 29.05.2024, 25.07.2024, 16.09.2024, 10.10.2024, and 11.10.2024. Despite these repeated communications, no reply was furnished by the ICC to the National Commission for Women. The delay from 09.10.2023 till date appears deliberate and amounts to denial of timely justice.

03.02.2026 – The ICC sent an email directing me to join a video conference where the Charged Officer would cross-examine me. This direction reflects a biased approach favoring the Charged Officer. On the same day, I replied seeking clarification and requested the legal provision under the POSH Act and the Central Civil Services (Classification, Control and Appeal) Rules, 1965 that permits a Charged Officer to cross-examine the complainant in a POSH inquiry.

I further expressed apprehension that I was being pressured to physically appear at the CCI office in order to subject me to humiliation, intimidation, and irrelevant questioning, contrary to the victim-centric framework of the POSH Act.

06.02.2026 – The ICC responded stating that while the Charged Officer may remain present, his Defence Assistant would conduct the cross-examination. This communication reinforces the perception of bias and procedural irregularity as ICC should cross- examine me instead of a charged officer/ defence assistant.

12.02.2026 – I replied reiterating that the POSH framework, including Rule 14 of the CCS (CCA) Rules, 1965, the Vishaka Guidelines, relevant DoPT Office Memorandums, and judicial interpretations, do not grant the Charged Officer or his Defence Assistant the right to directly cross-examine the complainant. Such a procedure is contrary to the principles of natural justice within the victim-protection framework envisaged under the POSH Act.

19.02.2026- The ICC insisted that the Charged Officer and his defence assistant would remain present during my cross-examination, claiming they were entitled to ask questions, interrupt the proceedings, and even pause the video conference.

In response, I stated that, in light of the Supreme Court’s judgment in Sakshi v. Union of India(2004), direct oral cross-examination of the complainant by the Charged Officer is restricted. Instead, the Charged Officer may submit written questions in advance, which can be put to me by the Committee.

I also requested that a copy of the Charged Officer’s statements, including his examination-in-chief and cross-examination, be provided to me, as these have not been furnished so far.

02.03.2026 – At approximately 12:15 pm, the ICC issued a fresh email directing me to attend the cross-examination via video conferencing at 2:00 pm the same day, instead of responding to my earlier email and pending queries.

The ICC cannot lawfully compel, force or threaten me into participating in the proceedings by making calls from unregistered or unofficial numbers and providing barely one hour’s notice. Such action is arbitrary, unreasonable and violative of the principles of natural justice and fair procedure that govern inquiries under the POSH act 2013.

The repeated change of the email trail and issuance of fresh communications, rather than responding within the existing correspondence, indicates an attempt to evade direct answers to my legitimate concerns. When questioned, the ICC deliberately sent an update on my previous CCI mail, which was closed on 01.02.2024 instead of continuing the conversation of the same email.

Such conduct seriously undermines transparency, due process, and the integrity of the inquiry proceedings.

03.03.2026 – Again they have sent me a new email, instead of replying to previous mail, they responded with a vague and evasive email, avoiding a clear and direct reply to my specific requests and questions.

In their email, the ICC stated that, during the cross-examination proceedings, the “Charged Officer and his Defence Assistant would remain present and would be permitted to submit questions even in the midst of the examination. If ICC needs to discuss any questions in detail, with a charged officer then Video conferencing will be put on hold”. Such a procedure reflects a biased and one-sided approach, compromising the neutrality expected of the Internal Complaints Committee.

The ICC has further refused to “provide the cross-examination statement of the Charged Officer, asserting that no such statement exists on record”. It clearly shows that the ICC is acting in a biased and manipulative manner, without adhering to the rules and regulations prescribed under the POSH act or any other applicable law of the Government of India. It further indicates that the ICC is fully aware that an allegation against the Charged Officer is true. Therefore, making every possible effort to save him.

Other officers, including Savita Mishra (Office Manager) and Jyotsana Yadav (Joint Director) of CCI have clearly stated in their statements about the inappropriate conduct of the Charged Officer and advised me to file a complaint under POSH act, 2013.Evidence attached for your reference.

I request the dissolution of the biased ICC of Competition Commission of India(CCI) and the constitution of a new, independent, and impartial Committee drawn from another organization, ensuring that no member from CCI or the Ministry of Corporate Affairs is involved in any capacity. I further seek urgent examination of the matter and intervention through CPGRAMS.

Additionally, I request protection from any form of retaliation and appropriate corrective action, as officers of CCI have been calling me from different numbers and threatening me to comply with their directions.

Kindly acknowledge receipt of this complaint and inform me of the action taken.