POSH Act for Schools, Colleges, and Universities in Kerala

Every educational institution in Kerala — school, college, university, coaching centre, or training institute — with 10 or more employees is required to comply with the POSH Act, 2013. The UGC has strengthened POSH requirements specifically for higher education institutions. Non-compliance is increasingly being enforced.

The POSH Act and Educational Institutions

The POSH Act, 2013 applies to all workplaces — and Section 2(o) specifically includes educational institutions in the definition of "workplace." This means:

• Government and aided schools in Kerala

• Private unaided schools

• Government and aided colleges

• Self-financing colleges

• Universities — both state and deemed

• Coaching centres and training institutes with 10+ staff

• Distance education centres and online learning institutions with physical operations

Every institution with 10 or more employees — teaching, non-teaching, administrative, contractual, or part-time — must form an IC, conduct training, and file an Annual Report.

UGC Directives — Higher Education

The University Grants Commission (UGC) has issued multiple circulars and directives requiring all colleges and universities to have a functioning POSH IC. UGC-CARE guidelines and the Saksham framework (2013) specifically address campus safety and POSH compliance for higher education institutions.

Following the Supreme Court's directions in Aureliano Fernandes v. State of Goa (2023), the UGC reinforced compliance requirements across all funded institutions. Universities and colleges receiving UGC grants must demonstrate POSH compliance — IC constitution, training records, and Annual Report filing.

Non-compliance can affect UGC grant eligibility.

Unique Challenges for Educational Institutions

Students are not employees — but the Act still applies The POSH Act protects "aggrieved women" — defined to include any woman who has been subjected to sexual harassment at a workplace, regardless of whether she is employed. A student, research scholar, or intern who faces harassment from a staff member can approach the IC. Schools and colleges must be prepared for this.

The extended workplace For educational institutions, "workplace" includes classrooms, laboratories, sports grounds, hostels, canteens, field trips, and any place connected with institutional activities.

Part-time and visiting faculty Many Kerala colleges employ part-time lecturers, guest faculty, and visiting professors. These individuals are employees under the POSH Act — and their complaints against or by them fall under the IC's jurisdiction.

Management-teacher dynamics in aided schools Kerala has a large aided school sector where management-teacher relationships can be hierarchical and complex. The POSH Act applies equally to aided schools — and complaints against management members are handled by the IC.

What Schools and Colleges Must Do

1. Form an IC — per Section 4, one at each campus or administrative unit

2. Appoint an eligible external member — from an NGO committed to the cause of women

3. Display IC details at a visible location on the campus — staffroom, administrative block, and notice boards

4. Train all staff — teaching, non-teaching, and administrative — annually

5. Train IC members — separately and specifically on inquiry procedure

6. File Annual Report with the District Officer by 31 January

7. Register on Kerala POSH Portal at posh.wcd.kerala.gov.in

FIO Foundation for Educational Institutions

FIO Foundation provides POSH training specifically adapted for educational institutions — covering the unique dynamics of school and college workplaces. Sessions are available in Malayalam and English. We provide IC formation support, external member services, and Annual Report guidance.

📞 +91 99617 71711 | fiofoundation.org | WhatsApp: "School POSH"