The Telangana High Court has ruled that the Telangana State Human Rights Commission (TSHRC) cannot entertain complaints arising solely out of disputes between a private employer and its employees when no public servant is involved. Setting aside the Commission's order, the Court held that its jurisdiction under the Protection of Human Rights Act, 1993 is limited and cannot be expanded merely because allegations relate to workplace harassment or human dignity.
Background of the Case
The writ petitions were filed by Wells Fargo International Solutions Private Limited after the Telangana State Human Rights Commission rejected the company's preliminary objection to the maintainability of two complaints filed by one of its employees in 2020.
According to the record, the employee had joined the company in 2011 and later complained internally about alleged workplace harassment, dissatisfaction with performance appraisals and the conduct of certain colleagues. The company's Human Resources (HR) Department and later its Employee Relations (ER) Department conducted separate inquiries. Both inquiries concluded that the allegations were not substantiated.
Even before the second inquiry concluded, the employee approached the Telangana State Human Rights Commission alleging violation of her human rights. The Commission later held that it had jurisdiction because the complaints related to alleged harassment of a woman employee rather than service benefits alone.
Challenging that decision, the company moved the High Court under Article 226 of the Constitution.
Court's Observations
A Division Bench comprising Chief Justice Aparesh Kumar Singh and Justice G.M. Mohiuddin examined the scope of Section 12 of the Protection of Human Rights Act, 1993.
The Bench observed that the Act authorises the Human Rights Commission to inquire into complaints alleging violation of human rights by a public servant or negligence by a public servant in preventing such violations. It noted that this statutory requirement is the foundation of the Commission's jurisdiction.
The Court said:
“The existence of an allegation against a public servant, or negligence attributable to a public servant in preventing such violation, constitutes the foundational jurisdictional fact for invoking the Commission's jurisdiction under the Act.”
The Bench further held that the Human Rights Commission is a statutory body and cannot enlarge its own powers beyond what Parliament has expressly provided.
It observed:
“The Commission... has no inherent or plenary jurisdiction. Therefore, its authority to entertain complaints must be exercised strictly within the four corners of the Act.”
Private Employer Not a Public Servant
The High Court found that Wells Fargo International Solutions Private Limited is a private company and neither the company nor its employees fall within the statutory definition of a "public servant."
Since the complaints were directed only against the company and its employees, and contained no allegation against any public servant or negligence by one, the essential condition for invoking the Commission's jurisdiction was absent.
The Court also relied on earlier decisions of the Madras High Court and its own previous judgment to conclude that Human Rights Commissions cannot adjudicate disputes involving purely private entities where the statutory requirements are not met.
Workplace Harassment Allegations Do Not Expand Jurisdiction
While considering the employee's allegations, including claims of workplace harassment and the impact on her health, the High Court clarified that it was not examining whether those allegations were true or false.
Instead, it confined itself to the jurisdictional issue.
The Bench observed that allegations concerning workplace harassment deserve serious consideration and should be addressed under the appropriate legal framework. However, it held that the seriousness of such allegations cannot by itself confer jurisdiction on the Human Rights Commission where the statute does not permit it.
The Court noted that any available remedies under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013 or any other applicable law remained open before the competent forum.
Court's Decision
Allowing both writ petitions, the Telangana High Court quashed the Telangana State Human Rights Commission's common order dated 14 October 2025 as well as the pending human rights proceedings.
The Bench held that the Commission had exceeded the jurisdiction conferred upon it under the Protection of Human Rights Act, 1993 by entertaining complaints against a private company in the absence of any allegation involving a public servant.
At the same time, the Court clarified that the employee would remain free to pursue any remedy available under law before the competent forum, and any such proceedings would be decided independently and on their own merits without being influenced by the High Court's observations.
Case Details
Case Title: Wells Fargo International Solutions Private Limited v. Telangana State Human Rights Commission & Another (Connected Matters)
Case Number: Writ Petition Nos. 36488 and 36486 of 2025
Judge: Chief Justice Aparesh Kumar Singh and Justice G.M. Mohiuddin
Decision Date: 13 July 2026
