COMPARATIVE APPROACHES TO WORKPLACE GENDER PROTECTION: A STUDY OF LABOUR LEGISLATION IN INDIA AND THE UNITED KINGDOM

Abstract

This paper examines the evolution and effectiveness of labour legislations aimed at protecting women in the workplace, through a comparative lens of India and the United Kingdom. Despite constitutional guarantees and statutory frameworks in both countries, women continue to face systemic discrimination, harassment, and inequality at work. The study analyses key Indian legislations such as the Maternity Benefit Act, 1961, the Sexual Harassment of Women at Workplace Act, 2013 (PoSH), and recent labour codes, alongside the UK's Equality Act 2010, Employment Rights Act 1996, and associated regulations. By evaluating legal provisions, enforcement mechanisms, and recent case law from both jurisdictions, the research highlights critical differences in legal consolidation, institutional support, and gender-sensitive implementation. While the UK’s legislative structure offers a more integrated and proactive approach, India’s fragmented enforcement and socio-cultural constraints hinder its progress. The paper argues that India can draw valuable lessons from the UK—particularly in areas such as gender pay gap reporting, flexible working rights, and public sector equality duties. It concludes that while both nations have made notable strides, effective enforcement, workplace sensitization, and judicial responsiveness are essential to ensuring real workplace equality for women.