Works Committees and Grievance Redressal Committees under the Industrial Relations Code, 2020: Legal Requirements and Employer Compliance

Introduction

The Industrial Relations Code, 2020 (IR Code) consolidates India’s legal framework governing trade unions, conditions of employment and the investigation and settlement of industrial disputes. It recognises two bipartite forums: the Works Committee and the Grievance Redressal Committee (GRC).

The IR Code came into force on November 21, 2025, replacing the corresponding framework under the Industrial Disputes Act, 1947, the Trade Unions Act, 1926 and the Industrial Employment (Standing Orders) Act, 1946.

The Ministry of Labour and Employment subsequently notified the Industrial Relations (Central) Rules, 2026 on May 8, 2026, under Section 99 of the IR Code. These Rules prescribe the operational framework for the constitution and functioning of Works Committees and GRCs in establishments falling within the Central Government’s sphere. Establishments governed by State Governments must also consider the applicable State Rules.

The two committees serve distinct purposes. A Works Committee is intended to promote harmonious industrial relations by addressing matters of common interest between employers and workers. A GRC, on the other hand, provides a statutory internal mechanism for resolving individual worker grievances. For employers, these provisions set specific obligations on workforce thresholds, committee composition, worker representation, grievance filing, decision-making and escalation to conciliation. Meeting them is also how an employer keeps workplace disputes from escalating into formal proceedings.

Statutory Framework: Works Committee and Grievance Redressal Committee

Chapter II of the IR Code governs bipartite forums and provides for the constitution of Works Committees under Section 3 and GRCs under Section 4. Both committees bring employers and workers to the same table, but their applicability and functions differ.

1. Works Committee: A Preventive Industrial Relations Mechanism

Section 3 of the IR Code applies to an industrial establishment in which 100 or more workers are employed, or have been employed on any day during the preceding 12 months. However, crossing this numerical threshold does not automatically make the constitution of a Works Committee compulsory. Section 3(1) empowers the appropriate Government to require an employer, through a general or special order, to constitute a Works Committee.

Once such an order is issued, the employer is required to constitute the committee in accordance with the applicable provisions and rules. Under Section 3(3), the Works Committee is entrusted with the responsibility of promoting measures to secure and preserve amity and good relations between employers and workers. It may examine matters of common interest or concern and endeavour to resolve material differences of opinion relating to such matters.

The Works Committee is therefore a preventive and consultative forum. It keeps management and workers talking before workplace disagreements develop into broader industrial disputes. It does not exercise the adjudicatory powers of an Industrial Tribunal or replace the statutory conciliation mechanism.

2. Grievance Redressal Committee: An Individual Grievance Resolution Mechanism

Section 4 of the IR Code adopts a different approach by requiring every industrial establishment employing 20 or more workers to constitute one or more GRCs for resolving disputes arising out of individual grievances. Unlike the Works Committee, the constitution of a GRC is mandatory once the statutory threshold is met.

The GRC provides workers with an internal forum to raise individual employment-related grievances and seek resolution within the establishment. It also establishes a procedural framework through which unresolved grievances may be taken to the Conciliation Officer. Because the threshold is lower, many mid-sized establishments that never need a Works Committee still need a GRC.

Composition and Representation in the Committees

The IR Code and the Central Rules set out who sits on each committee and how the employer and worker sides are balanced.

1. Composition of the Works Committee

Section 3 requires that the number of worker representatives in a Works Committee must not be less than the number of employer representatives.

Rule 5 of the Industrial Relations (Central) Rules, 2026 further provides that:

• The total membership of the Works Committee cannot exceed 20 members.
• Representation must take into account the various categories, groups and classes of workers and the different sections, shops or departments of the establishment.
• Worker representatives must constitute at least half of the committee’s representation.
• Employer representatives are nominated by the employer and should, as far as possible, be officials directly associated with the functioning of the establishment.

The selection of worker representatives follows a prescribed hierarchy:

• Where a negotiating union exists: The recognised negotiating union nominates the worker representatives.
• Where a negotiating council exists: The registered trade unions represented in the negotiating council receive representation in proportion to the number of workers belonging to each union.
• Where neither exists: The workers elect their representatives from among themselves. The employer may use an electronic platform or information technology application to facilitate the election process.

The Rules also provide for consultation with registered trade unions to ascertain their membership strength. Where the employer has reason to believe that the information supplied by a trade union is incorrect, the matter may be referred to the Regional Labour Commissioner (Central) for determination after hearing the parties.

2. Composition of the Grievance Redressal Committee

Under Section 4(2) and Rule 6 of the Central Rules, a GRC must consist of an equal number of employer and worker representatives, with an overall maximum of 10 members. The employer representatives are nominated by the employer and should, as far as possible, be officials directly associated with the functioning of the establishment, preferably heads of major departments.

The selection of worker representatives follows the same broad hierarchy as the Works Committee:

• A negotiating union nominates the worker representatives.
• Where a negotiating council exists, the registered trade unions represented in it receive proportionate representation.
• Where neither exists, workers choose their representatives from among themselves, with electronic platforms permitted for the selection process.

The Rules also prescribe a three-year tenure for members of the GRC. Where no recognised negotiating union or negotiating council exists and a dispute arises concerning the selection of worker representatives, the matter may be referred to the concerned Regional Labour Commissioner (Central), whose decision is final. The parity requirement ensures that neither the employer nor worker representatives can independently determine the composition of the committee.

Proportional Representation of Women Workers

The IR Code also sets a floor for the representation of women workers in bipartite forums. Section 4(4) expressly provides that the representation of women workers in a GRC must not be less than their proportion in the total workforce of the industrial establishment.

The Industrial Relations (Central) Rules, 2026 extend this requirement to Works Committees under Rule 5. Accordingly, establishments employing women workers must ensure that their representation in the Works Committee is not less than their proportion in the total workforce.

This gives employers a number to check rather than a general principle. Committee membership has to be worked out against the current composition of the workforce, and neither committee is properly constituted until that check is done.

Eligibility and Selection of Worker Representatives

The Central Rules prescribe separate eligibility requirements for candidates contesting elections to the Works Committee and workers participating in the voting process.

Under Rule 5(7), a worker must:

• Be at least 19 years of age; and
• Have completed at least one year of service in the industrial establishment.

The one-year service qualification does not apply to the first election in an industrial establishment that has been in existence for less than one year. Continuous service across two or more industrial establishments belonging to the same employer may also be considered for satisfying the prescribed service qualification. The eligibility requirements for voting are different. Under Rule 5(8), workers who are at least 18 years old and have completed six months of continuous service in the industrial establishment are entitled to vote.

The Rules also prescribe procedures concerning nominations, scrutiny of nomination papers, withdrawal of candidature, notification of elections and voting.

Functioning and Tenure of the Works Committee

The Works Committee is meant to be a standing body that keeps meeting, not a one-time formality. Rule 5 of the Central Rules prescribes its organisational structure and functioning. The committee must have a Chairperson, Vice-Chairperson, Secretary and Joint Secretary.

The Chairperson is nominated by the employer from among the employer representatives and should, as far as possible, be the head of the industrial establishment. The Vice-Chairperson is elected by the worker representatives from among themselves. The Rules provide for a three-year tenure for committee members and prescribe periodic meetings to ensure continued engagement between management and workers.

The committee must ordinarily meet at least once every three months, although additional meetings may be convened as required. Meetings are ordinarily held during the working hours of the establishment, and worker representatives are deemed to be on duty while attending them. The employer is also required to provide the necessary facilities for conducting meetings.

The Central Government or an authorised officer may dissolve the committee after an inquiry and by an order recording reasons where, among other circumstances:

• The committee has not been constituted in accordance with the Rules;
• At least two-thirds of the worker representatives, without reasonable justification, fail to attend three consecutive meetings; or
• The committee has otherwise ceased to function.

The employer may consequently be required to take steps to reconstitute the committee in accordance with the applicable requirements.

Grievance Filing and the 30-Day Resolution Framework

Section 4 establishes a statutory process for raising individual grievances before the GRC. Under Section 4(5), an aggrieved worker may file an application before the GRC within one year from the date on which the cause of action arises. Section 4(6) provides that the GRC may complete its proceedings within 30 days of receiving the application. Because the provision says ‘may’, the 30-day period is a framework for quick resolution rather than an absolute deadline in every case.

1. Particulars Required in a Grievance Application

Rule 7 of the Industrial Relations (Central) Rules, 2026 prescribes the particulars to be included in an application submitted to the GRC.

The application must contain:

• Name of the worker;
• Designation;
• Worker code or token number;
• Department in which the worker is posted;
• Length of service;
• Category of worker;
• Address for correspondence;
• Contact number;
• Details of the grievance; and
• Relief sought.

The application may be submitted electronically or through other means.

Employers should log every application with its date of receipt. That date starts the 30-day resolution framework and, if the grievance is not resolved, the 60-day window for escalation.

Decision-Making and Worker-Side Majority Requirement

Section 4(7) adds a safeguard to how the GRC decides. The decision must be based on the majority view of the committee. However, it must also receive the agreement of more than half of the members representing the workers.

Where this worker-side majority requirement is not satisfied, the Code treats the matter as one in which no decision could be arrived at by the committee. An ordinary majority of the whole committee is not enough on its own without that agreement from the worker representatives.

Employers should ensure that the committee maintains proper records of its proceedings, voting and decisions to demonstrate compliance with this requirement.

Escalation from the GRC to Conciliation

The GRC is intended to provide an internal resolution mechanism without restricting a worker’s access to the statutory conciliation process. Section 4(8) provides that a worker who is aggrieved by the GRC’s decision, or whose grievance remains unresolved within the period specified under Section 4(6), may approach the Conciliation Officer.

The application must be made within 60 days from:

• The date of the GRC’s decision; or
• The date on which the 30-day period under Section 4(6) expires, where the grievance remains unresolved.

The application is required to be made through the trade union of which the worker is a member, in the prescribed manner. Under Rule 8 of the Central Rules, the application may be submitted through the Ministry of Labour and Employment’s designated online portal, personally or through speed post.

Where an application is received manually, the Conciliation Officer is required to digitise it and enter the relevant particulars into the online system, with intimation to the trade union and the worker.

Direct Access to the Industrial Tribunal in Specified Termination Disputes

An additional statutory route is provided under Sections 4(9), 4(10) and 4(11) of the IR Code. Where an employer discharges, dismisses, retrenches or otherwise terminates the services of an individual worker, a dispute arising from such action is deemed to be an industrial dispute even if no other worker or trade union is a party to it.

Further, notwithstanding Section 4 or Section 53, an eligible worker may directly approach the Industrial Tribunal for adjudication of such a dispute after the expiry of 45 days from the date on which the worker applied to the Conciliation Officer for conciliation.

Such an application must be made before the expiry of two years from the date of discharge, dismissal, retrenchment or termination. For discharge, dismissal, retrenchment and termination disputes, the GRC is therefore not the last stop: the worker keeps a direct route to adjudication, subject to these procedural and limitation requirements.

Changes from the Industrial Disputes Act, 1947

The framework under the IR Code introduces certain changes to the earlier grievance redressal mechanism under Section 9C of the Industrial Disputes Act, 1947.

Under the earlier provision:

• A Grievance Redressal Committee was required in industrial establishments employing 20 or more workmen.
• The committee could consist of a maximum of six members.
• The provision prescribed representation of women in the committee.
• An aggrieved workman could appeal to the employer against the committee’s decision.
• The employer was required to dispose of the appeal within one month, following which the worker could approach the Conciliation Officer.

The IR Code retains the 20-worker threshold but increases the maximum permitted membership of the GRC to 10 and expressly provides for equal representation between the employer and worker sides. It also introduces a requirement that more than half of the worker representatives must agree with the committee’s decision. The IR Code also removes the separate statutory appeal to the employer and provides for escalation to the Conciliation Officer within the prescribed 60-day period.

Practical Compliance Obligations for Employers

The constitution of Works Committees and GRCs requires employers to maintain appropriate workforce records, follow prescribed selection procedures and establish mechanisms for monitoring the functioning of these forums. A structured industrial relations compliance framework should address the following areas:

A. Workforce Assessment and Applicability

• Maintain updated workforce records to assess whether the 20-worker and 100-worker thresholds are met.
• Identify whether the Central Government or the State Government is the appropriate Government for the establishment.
• Examine the applicable Central or State Rules.
• Track any general or special order requiring the constitution of a Works Committee.

B. Committee Constitution and Representation

• Maintain committee constitution orders and membership records.
• Ensure that the prescribed employer-worker representation requirements are satisfied.
• Verify proportionate representation of women workers.
• Maintain records of consultations with registered trade unions.
• Preserve nomination and election records, including electronic voting records where applicable.

C. Grievance Redressal Procedures

• Establish a documented process for receiving individual worker grievances.
• Ensure that applications contain the prescribed particulars.
• Maintain records of the date of receipt and the relief sought.
• Monitor the 30-day resolution framework.
• Record GRC proceedings, voting and decisions, including evidence of the requisite worker-side majority.

D. Conciliation and Further Proceedings

• Maintain records of applications escalated to the Conciliation Officer.
• Monitor the 60-day period prescribed under Section 4(8).
• Ensure that relevant trade union communications and supporting documents are preserved.
• Identify disputes involving discharge, dismissal, retrenchment or termination that may attract the additional remedy under Section 4(10).

E. Periodic Review and Reporting

• Conduct periodic reviews of the constitution and functioning of the Works Committee.
• Verify that meetings are conducted at the prescribed intervals.
• Maintain attendance records and minutes of meetings.
• Preserve documentation relating to committee functioning and grievance disposal.
• Incorporate the prescribed details of the Works Committee’s constitution and functioning into the unified annual return under the applicable OSHWC Rules.

Conclusion

Compliance takes more than constituting the committees once the workforce thresholds are crossed. It means ensuring that the correct statutory framework applies, following the prescribed selection procedures, maintaining representative participation and implementing a reliable grievance resolution process.

Employers should now review their industrial relations policies, workforce records and grievance redressal mechanisms against the IR Code and the applicable Central or State Rules.

Last Updated on 6 November, 2026