The Bombay High Court at Goa held that s.14 of the POSH Act penalises a woman (or a person filing on her behalf) for a false and malicious complaint, but provides no punishment for a third party who instigates one. It also held that an Internal Committee cannot record a named instigator as an 'unknown' source where his identity is disclosed in the retraction letter that closed the complaint.
Justice G.S. Patel laid down a detailed code to shield the identities of parties and witnesses in sexual-harassment litigation — anonymised cause-titles, orders delivered in chambers or in-camera, and a bar on media or social-media disclosure without leave. The judgment built the working confidentiality framework for POSH cases under s.16 of the 2013 Act.
The Kerala High Court held that a 'hostile work environment' divorced from any sexual conduct or advance is not sexual harassment under the POSH Act, and that proceedings need a written complaint under Section 9. A purely service or labour grievance falls outside the Act.