The Telangana High Court rules that the State Human Rights Commission lacks jurisdiction to entertain complaints against private entities unless they involve public servants, citing the Protection of Human Rights Act, 1993.
In a significant ruling, the Telangana High Court has set aside the Telangana State Human Rights Commission’s (TGHRC) order, which had asserted jurisdiction over complaints of workplace harassment filed against Wells Fargo International Solutions Private Limited, a private entity. The Court emphasized that the Human Rights Commission’s jurisdiction is confined to complaints involving public servants, as defined under the Protection of Human Rights Act, 1993.
The case stems from complaints filed by an employee of Wells Fargo, alleging harassment and violation of her human rights by her superiors. The complaints were initially lodged with the company’s HR department and later escalated to the Employee Relations department. However, the employee was dissatisfied with the internal inquiries, leading her to file complaints with the TGHRC in 2020.
The TGHRC, in its order dated October 14, 2025, had rejected the preliminary objections raised by Wells Fargo regarding the maintainability of the complaints, asserting that the allegations pertained to human rights violations. The Commission’s decision was based on the view that the complaints involved harassment of a woman employee, which could potentially infringe upon her dignity and fundamental rights.
Wells Fargo, represented by senior counsel, challenged this order through writ petitions, arguing that the TGHRC lacked jurisdiction under Section 12 of the Protection of Human Rights Act, 1993, which limits the Commission’s scope to acts committed by public servants. The company contended that as a private entity, neither it nor its employees fall under the definition of a "public servant," thereby making the Commission’s jurisdictional claims untenable.
The High Court, in its detailed judgment, concurred with Wells Fargo’s submissions. The Court noted that the statutory jurisdiction of the Human Rights Commission is explicitly confined to cases involving public servants. It further highlighted that the language of the Act is clear and does not allow for an expansive interpretation that could include private entities within its ambit.
The judgment also referenced several precedents, including decisions from the Madras High Court and the Supreme Court, which consistently underscored the jurisdictional limits of Human Rights Commissions. The Court reiterated that serious allegations of workplace harassment should be addressed through appropriate legal remedies but not through the Human Rights Commission unless statutory conditions are met.
The Court’s decision underscores the importance of adhering to statutory limits while exercising jurisdiction and ensures that private employment disputes are resolved through suitable forums. While allowing the writ petitions, the Court clarified that the complainant is free to pursue other legal remedies available under the law.
Bottom line:-
Human Rights Commission lacks jurisdiction to entertain complaints against private entities or individuals unless the foundational jurisdictional requirements under Section 12 of the Protection of Human Rights Act, 1993, are met.
Statutory provision(s): Protection of Human Rights Act, 1993 - Section 12, Constitution of India - Article 14, Bharatiya Nyaya Sanhita, 2023 - Section 2(28).
