What does it say about our universities when a legally mandated body meant to address sexual harassment is misnamed—confidently, publicly, and repeatedly—by those who claim expertise? In classrooms and seminar halls, acronyms circulate with authority, but authority without accuracy is a dangerous thing. This reflection emerges from a seemingly casual conversation with a former teacher that exposed a deeper malaise within higher education: a troubling indifference to legal literacy, a casual approach to women-centric laws, and an academic culture more invested in procedural comfort than ethical responsibility. At stake here is not a terminological error, but the hollowing out of justice itself.
This blog is a continuation of my reflection on the Internal Complaints Committee (ICC) and the crucial role of the external member. Since I am relatively new to this digital space—and since thoughtful responses to academic writing are increasingly rare—I did not expect that my previous post would immediately generate a conversation worth turning into a second blog. Yet, here I am, compelled to continue.
The trigger was a brief exchange with one of my former teachers, Prof. N K Vijayan, who taught me during my undergraduate years at Maharaja’s College. He messaged me with what appeared to be a simple clarification: What exactly does ICC stand for?
What followed was anything but simple.
When “Experts” Misname the Law
Prof. Vijayan asked me whether ICC stood for Internal Compliance Committee rather than Internal Complaints Committee. I was initially taken aback. But he went on to explain why the doubt arose. On two separate occasions, when his college organised sessions on ICC, two different “experts”—both employed in Higher Education Institutions in Kerala—had offered troublingly confident explanations.
One categorically stated that ICC meant Internal Compliance Committee and had nothing to do with complaints. The other suggested that ICC could be expanded either way—Compliance or Complaints. To make matters worse, Prof. Vijayan was told that the UGC Regulation uses the term Compliance.
This is not a minor semantic error. It is a profound epistemic failure.
What disturbed me most was not the confusion of a layperson, but the misleading authority of so-called experts who speak on legal mechanisms without verifying the most basic facts. When those entrusted with disseminating knowledge misname the law, they do not merely err—they actively undermine legal consciousness.
This conversation forced me into two realisations. First, it exposed the alarming casualness with which legal frameworks are handled within academia. Second, it revealed a gap in my own earlier engagement with the POSH Act: despite knowing that the UGC mandates ICCs in all Higher Education Institutions, I had not, until then, systematically revisited the UGC’s own documents.
That omission mattered.
The Academic Community and the Comfort of Ignorance
If we were to conduct a serious audit of how ICCs function in Higher Education Institutions across Kerala, I doubt the findings would be reassuring. As someone who teaches courses on Women and Law in India at both postgraduate and undergraduate levels, I have repeatedly encountered a striking pattern: students are largely unaware of laws, even those specifically enacted to protect women.
Legal illiteracy is not accidental. It is cultivated through institutional silence.
Without legal literacy, there can be no legal empowerment. And yet, many teachers conveniently absolve themselves by claiming they lack a legal background. This excuse is deeply problematic. Must one be a legal expert to familiarise students with laws that govern their everyday lives, their safety, and their dignity?
If legal engagement were truly optional, why would the UGC continue to issue circulars, regulations, and reminders on ICCs?
What the UGC Documents Actually Say
Let me ask a direct question: how many of us are familiar with the UGC documents that operationalise the POSH Act within Higher Education Institutions?
Consider the following:
First, the UGC circular D.O. No. F.91-2/2025(GS) dated 13 November 2025, which explicitly seeks a status report on POSH implementation in HEIs—covering ICC constitution, sensitisation efforts, redressal mechanisms, and challenges faced. This circular also announces the Campus Calling Programme, a national initiative aimed at gender sensitisation with special emphasis on the POSH Act.
Second, the Gazette Notification dated 2 May 2016, which carries the University Grants Commission (Prevention, Prohibition and Redressal of Sexual Harassment of Women Employees and Students in Higher Educational Institutions) Regulations, 2015. This document is crucial because it adapts the POSH Act to the specific ecology of campuses. It carefully defines who counts as a student, clarifies their eligibility to file complaints, and introduces the concept of third-party harassment, extending accountability even to outsiders who enter campus spaces.
Third, the UGC’s engagement with POSH did not begin in 2015 or 2016. As early as December 2013, the Commission released the Saksham handbook—a 250-page document offering detailed recommendations on ICC constitution. Notably, Appendix 2 of the book includes a flowchart outlining the procedures ICCs must follow while addressing complaints.
Across all these documents, there is not a single instance where ICC is expanded as Internal Compliance Committee.
Not one.
Why This Misnaming Matters
To rename the Internal Complaints Committee as an Internal Compliance Committee is not an innocent slip. It signals a shift in orientation—from addressing harm to managing institutional liability, from survivor-centric justice to bureaucratic box-ticking.
This is where the irresponsibility of the academic community becomes painfully visible. When educators misinterpret the law, when institutions prioritise compliance over care, and when “expertise” circulates without accountability, the ICC becomes yet another administrative ritual—emptied of its ethical and political intent.
The law, imperfect as it is, demands more from us. The question is whether academia is willing to take that demand seriously.
For now, I leave this here—not as a conclusion, but as an invitation to discomfort, debate, and responsibility.
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