No. The POSH Act defines the respondent as a person against whom an aggrieved woman makes a complaint. It does not say that the respondent must be a man. Ask the committee to assess the alleged conduct and workplace connection, rather than reject the complaint solely because the senior colleague is a woman. The complainant still needs to fall within the Act's statutory scope.
Which words in the Act answer HR's objection?
Section 2(m) defines respondent as a person against whom the aggrieved woman has made a complaint under section 9. Section 2(n) then describes the unwelcome acts that can constitute sexual harassment, including physical contact and advances, demands for sexual favours, sexually coloured remarks, showing pornography and other unwelcome conduct of a sexual nature. The respondent's sex is not substituted for that conduct test.
Send HR the two provisions with a direct request: "Please place my written complaint before the competent committee. Section 2(m) does not restrict respondents to men. I request assessment of the incidents set out in the complaint under sections 2(n) and 3." That keeps the objection narrow and verifiable.
Does every dispute between female colleagues become a POSH case?
No. Describe the sexual nature of the conduct or its connection to sexual harassment. General bullying, an unfair roster, disagreement over performance or an insulting comment is not automatically brought within POSH because both parties are women or because the conduct was humiliating.
For a remark, give the actual words as accurately as you can. For touching, describe the contact and circumstances. If promotion, appraisal or job security was used as pressure, identify the promised benefit or threat and its connection to the unwelcome conduct. Section 3(2) addresses those circumstances when related to sexual harassment. It is not a free-standing rule turning every employment grievance into a POSH allegation.
Keep a separate section for ordinary management issues if they matter to context. This lets the committee identify its own remit and prevents a legitimate workplace grievance from being lost because part of the file belongs in a different process.
Which committee should receive the complaint?
Normally use the competent Internal Committee for the workplace. If the senior woman is herself the employer within section 2(g), the Local Committee route under section 6 needs examination. Seniority alone does not make her the employer, and being the complainant's manager does not automatically move the case out of the Internal Committee.
If she is a committee member, disclose that conflict and ask for an impartial arrangement through the appropriate authority. Request the constitution order and membership details. Do not assume the entire workplace is exempt or that her committee position permits her to decide a complaint about herself.
What if HR refuses even to acknowledge it?
Send the complaint through a channel that creates a reliable receipt and ask for the refusal and reasons in writing. Keep the original submission. The issue is not whether HR approves your interpretation of the law before you can place facts before the statutory committee.
Watch section 9's filing period. The ordinary limit is three months from the incident or last incident in a series, with a possible further extension of up to three months for recorded reasons where circumstances prevented filing. An ongoing argument with HR about gender does not itself guarantee that the committee will extend time. If necessary, include a separate explanation of the obstruction and request the extension.
How should I preserve evidence without spreading the complaint?
Keep relevant messages, your chronology, the names of witnesses and the policy correspondence. Ask the custodian to retain CCTV or workplace chat identified by date and location. Avoid a public discussion framed as whether women can harass women. Your evidence concerns particular conduct by a particular person, not a claim about a group.
Do not infer sexual orientation from the conduct or treat it as an element you must prove. A complaint should describe the unwelcome act, its context and the impact relevant to the workplace issue. Speculation about private identity distracts from that assessment and risks unnecessary disclosure.
The next step is a dated request for registration and a reasoned jurisdiction decision, accompanied by the actual incident account. If a report or adverse recommendation later issues, obtain it and take advice on the appropriate challenge and time limit. An initial HR email is not necessarily the statutory committee's final decision.
For the general route, see our POSH complaint guide. The employment and labour practice page covers the related employment issues.