In a significant judgment on workplace harassment, the Supreme Court on Friday dismissed a plea by Vaneeta Patnaik, a faculty member of West Bengal National University of Juridical Sciences (NUJS), who had accused Vice Chancellor Dr. Nirmal Kanti Chakrabarti of sexual harassment. The bench of Justices Pankaj Mithal and Prasanna B. Varale ruled that her complaint, filed months after the last alleged incident, was barred by limitation.
Background
Patnaik alleged that the Vice Chancellor made unwelcome advances starting in 2019, including an incident in April 2023 when he allegedly pressured her to accompany him to a resort. She claimed that after rejecting him, she was removed from a key directorial post and faced a funding inquiry. Her formal complaint, however, was lodged only on 26 December 2023-well beyond the three-month period (and six-month extended window) permitted under the Sexual Harassment of Women at Workplace Act (POSH).
Initially, a Local Complaint Committee dismissed her case as time-barred. A single judge of the Calcutta High Court revived it, reasoning that a hostile work environment continued beyond April 2023. But a division bench reversed that order, concluding the later administrative actions were collective decisions unrelated to sexual harassment.
Court’s Observations
“The alleged act of harassment of April 2023 was a complete act in itself and had not continued thereafter,” the bench observed, stressing that removal from a post or a financial probe “are administrative in nature and do not create a gender-based hostile environment.”
The Court clarified that while limitation issues often involve mixed questions of fact and law, a complaint that is “patently barred by limitation” can be rejected at the outset. It drew a clear line between a “continuing wrong” and a “recurring wrong,” noting that subsequent events in August 2023 lacked any direct link to the earlier sexual misconduct claims.
Decision
Dismissing the appeal, the Supreme Court upheld the Division Bench’s view that the complaint was filed too late.
Yet it added a striking coda: “It is advisable to forgive the wrongdoer, but not to forget the wrongdoing.” The Court directed that details of the alleged harassment be incorporated into Dr. Chakrabarti’s professional résumé, ensuring the allegations “haunt the wrongdoer forever,” even though no further legal action will follow.
Case Title: Vaneeta Patnaik vs. Nirmal Kanti Chakrabarti & Others
Appeal No.: Civil Appeal (Arising out of SLP (C) No. 17936 of 2025)
Decision Date: 12 September 2025
