The Madhya Pradesh High Court has set aside a Single Judge's order directing former Lakshmibai National Institute of Physical Education (LNIPE) Vice-Chancellor Dr. Dilip Kumar Dureha to pay ₹35 lakh as compensation in a workplace sexual harassment case. The Division Bench held that the statutory appeal against the Internal Complaints Committee (ICC) findings should be decided first before any conclusions are drawn.
Background of the Case
The dispute arose from a complaint filed in October 2019 by a Yoga Instructor employed at LNIPE under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013. Following an inquiry, the ICC submitted its report on September 21, 2020. While the committee recorded findings regarding the allegations, it did not recommend any penal action.
The complainant later approached the High Court through a writ petition. On July 15, 2025, the Single Judge awarded ₹35 lakh compensation against Dr. Dureha, ₹5 lakh against State authorities for delay in registering the criminal case, and ₹1 lakh against LNIPE for its alleged casual approach. Challenging that decision, Dr. Dureha filed the present writ appeal.
Court's Observations
The Division Bench noted that the appellant had claimed to have already filed a statutory appeal against the ICC findings under the POSH Act and the UGC Regulations. According to the Court, if that appeal remained undecided, allowing the compensation order to stand could create prejudice by proceeding on an assumption regarding the appellant's guilt before the appellate authority examined the matter.
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The Bench observed,
"The right of appeal is a substantive right"
and said the appellate authority must first examine the factual issues raised by both sides before any final conclusions are reached.
Court's Decision
Allowing the appeal, the High Court set aside the Single Judge's order dated July 15, 2025, and remanded the matter to the appellate authority, identified as the Secretary, Ministry of Youth Affairs and Sports, Government of India.
The Court directed all parties to appear before the appellate authority on July 14, 2026. It further instructed the authority to provide a reasonable opportunity of hearing to all concerned and make every effort to decide the appeal within two months from the parties' first appearance. With these directions, the writ appeal was disposed of.
Case Details:
Case Title: Dr. Dilip Kumar Dureha v. Smt. Anusha Deepak Tyagi & Others
Case Number: Writ Appeal No. 2332 of 2025
Judge: Justice Anand Pathak and Justice Ashish Shroti
Decision Date: June 29, 2026
