The Verdict That Started a National Debate

In September 2026, the Federal Constitutional Court (FCC) of Pakistan decided a workplace harassment case that has reopened one of the most sensitive questions in Pakistani employment law: what actually counts as "harassment" at work? The judgment — in Usman Shahid and Aqeel Abbas v. Nadia Sarwar & others, C.P.L.A. Nos. 1011 and 1113 of 2026 — held that under the workplace-harassment law as it stood before the 2022 amendments, a complaint had to be sexual in origin to be actionable before the Ombudsperson. Behaviour that was merely hostile, unfair, or demeaning did not, in the court's view, meet the legal test.

The detailed written judgment, an 18-page decision authored by Justice Ali Baqar Najafi for a three-member bench headed by Chief Justice Amin-ud-Din Khan (with Justice Syed Arshad Hussain Shah), was announced on 16 September 2026 and released in full in the last week of that month. It set aside an Islamabad High Court judgment and restored a presidential order that had reduced two bank officers' punishment from dismissal to a mere censure.

Within days, the verdict triggered a national debate. The News carried opinion pieces in the first week of October 2026 warning that the ruling narrowed a law that Parliament had deliberately broadened. Women's rights lawyers argued that the court had ignored the 2022 amendment, which expressly added gender-based discrimination — whether sexual or not — to the definition of harassment. The Supreme Court's own 2025 judgment on workplace harassment had taken the opposite direction, calling harassment "less about sexual desire and more about control and domination."

If you are a working woman — or an employer — this debate is not academic. It decides where you can complain, what you can complain about, and what happens next. This article explains, in plain language, what the law says today, what the FCC verdict actually decided, what it did not decide, and how the complaint process works step by step.

The Case Behind the Verdict

To understand the FCC's decision, you need the facts of the case first. They go back more than a decade.

Nadia Sarwar had been working at the National Bank of Pakistan (NBP) since 2008. In 2012, she complained to the bank's President about two senior officials, Usman Shahid and Aqeel Abbas. She alleged that they forced her to stay after office hours, demanded explanations for her domestic and medical leave, entered adverse remarks against her, and used demeaning words toward her. A claim about a demeaning sketch appeared in a later affidavit.

When her own department failed to give her relief, Sarwar approached the Federal Ombudsperson for Protection Against Harassment under the Protection Against Harassment of Women at the Workplace Act, 2010. The Ombudsperson upheld her complaint and imposed a major penalty — compulsory retirement — on the two officials.

The officials filed a representation to the President of Pakistan under Section 9 of the Act. The President set aside the Ombudsperson's order and substituted a far lighter punishment: censure (a formal reprimand). The President's reasoning was that some of the alleged words were not proved, and the allegation about the demeaning sketch had appeared only later in the complainant's affidavit.

Sarwar then went to the Islamabad High Court in its constitutional writ jurisdiction. In a judgment dated 31 December 2024, the High Court set aside the President's order and restored the Ombudsperson's decision — compulsory retirement and all.

The two officials challenged that in the Federal Constitutional Court. The FCC allowed their appeals, annulled the Islamabad High Court's judgment, and restored the President's order. The two bank officers went from dismissal back to a censure — the lightest penalty on the statute book.

Section 2(h): What Counts as "Harassment" Under the 2010 Act

Every argument in this case turned on one provision: Section 2(h) of the Protection Against Harassment of Women at the Workplace Act, 2010. This is the legal definition of "harassment," and everything — the Ombudsperson's jurisdiction, the inquiry committee's powers, the penalties — flows from it.

The original (pre-2022) definition says harassment means:

Any unwelcome sexual advance, request for sexual favours, or other verbal, written, visual or physical conduct of a sexual nature, or sexually demeaning attitudes, which:

  • interferes with work performance, or creates an intimidating, hostile or offensive work environment; or

  • is an attempt to punish the complainant for refusing to comply with such a request; or

  • is made a condition of employment.

In plain words: if someone at work makes an unwanted sexual advance, asks for sexual favours, or behaves toward you in a sexually demeaning way — in words, in writing, or physically — and it messes with your ability to work, poisons your workplace, punishes you for saying no, or is tied to keeping your job, that is harassment under the Act.

The FCC read this definition as exhaustive, not expansive — meaning the list is closed, not open-ended. The court held that the conduct had to be sexual in origin to fall under the Act. Its reasoning, in the court's own words: every sexual harassment is harassment, but every harassment is not sexual harassment. The word "sexual," the court said, relates to physical attraction or intimate physical contact.

The FCC also raised the evidentiary bar. It held that the standard of proof in sexual harassment cases requires impartial, credible material reinforced by convincing or independent evidence — not the complainant's word alone.

This is where the controversy begins, because the law that Parliament actually passed in 2022 says something broader — and the FCC case was about conduct from 2012 and 2013, before that amendment existed.

The 2022 Amendment: What Changed Everything

On 14 January 2022, Parliament passed the Protection Against Harassment of Women at the Workplace (Amendment) Act, 2022 (Act V of 2022). Human Rights Watch called it a significant strengthening of the "far weaker 2010 law," drafted with extensive input from women's rights groups and lawyers. It made several fundamental changes:

1. A second, entirely new definition of harassment. The amendment added what lawyers call the gender-discrimination limb — Section 2(h)(ii). It defines harassment to include "discrimination on the basis of gender, which may or may not be sexual in nature, but which may embody a discriminatory and prejudicial mind-set or notion, resulting in discriminatory behaviour on basis of gender against the complainant."

Read that carefully. Under the amended Act, harassment no longer has to be sexual at all. Biased treatment because of gender is itself harassment. Denying a woman opportunities because she is a woman, criticising her abilities on gender grounds, demeaning remarks driven by gender prejudice, exclusion from meetings, or a hostile attitude rooted in a discriminatory mindset — all of this falls within the amended definition.

2. New forms of sexual conduct written into the definition. The 2022 amendment added "stalking or cyber stalking" and "visual" conduct to the sexual-harassment limb. Online harassment — threatening messages, stalking on social media, sharing images — is now squarely covered.

3. The single-incident rule. A single incident that makes a person uncomfortable or creates a sense of fear or panic at the workplace is itself harassment. You do not need to prove a repeated pattern. One severe incident is enough.

4. A vastly expanded definition of "employee." The amended Act covers regular, contractual, piece-rate, gig, temporary, part-time, and freelance workers — plus students, performers, artists, sportspersons, interns, trainees, domestic workers, home-based workers, and apprentices — whether working for pay or not, voluntarily or otherwise. A private home employing a single domestic worker now carries employer obligations under this Act.

5. A vastly expanded definition of "workplace." It is no longer just the office or factory. The workplace now includes any place where services are rendered — educational institutions, studios, concert venues, courts, highways, sporting facilities, gymnasiums — and any situation linked to work or activity outside the office, including virtual and remote work and unofficial work gatherings.

6. "Complainant" now means "any person." The 2022 amendment substituted the expression "a woman or man" with "any person", extending the Act's protection to transgender persons as well.

7. New penalties and anti-retaliation protections. The amendment added suspension or cancellation of a professional licence as a major penalty, streamlined the complaints process, and built in specific protections against retaliation for complaining.

Pre-2022 vs the 2022-Amended Act: A Side-by-Side Comparison

This is the heart of the matter, so let us lay it out plainly:

  • What counts as harassment (pre-2022): Unwelcome sexual advances, requests for sexual favours, verbal, written or physical conduct of a sexual nature, or sexually demeaning attitudes that interfere with work or create a hostile environment, punish refusal, or become a condition of employment. The FCC has now confirmed: this limb is confined to conduct sexual in origin.

  • What counts as harassment (post-2022): Everything above, plus discrimination on the basis of gender — whether sexual or not — that reflects a discriminatory, prejudicial mindset and results in discriminatory behaviour. Also stalking and cyberstalking, visual conduct, and a single severe incident.

  • Who is an employee (pre-2022): Regular or contractual employees, including interns and apprentices.

  • Who is an employee (post-2022): All of the above, plus gig workers, freelancers, part-timers, students, performers, sportspersons, trainees, domestic workers, and home-based workers — paid or unpaid.

  • Who can complain (pre-2022): A woman or man.

  • Who can complain (post-2022): Any person, including transgender persons.

  • Penalties (pre-2022): Minor (censure, withholding promotion/increment, stoppage at efficiency bar, recovery of compensation from pay) and major (reduction to lower post, compulsory retirement, removal, dismissal, fine).

  • Penalties (post-2022): All of the above, plus suspension or cancellation of a professional licence as a major penalty.

What the FCC Actually Held — and What It Did NOT Decide

Because this verdict is being quoted in offices and WhatsApp groups all over Pakistan, it is important to be precise about what the court actually said — and, equally, what it did not say.

What the FCC held:

  1. The pre-2022 definition is sexual in origin. For conduct arising under the original 2010 Act (the Nadia Sarwar case involved 2012–2013 allegations), harassment had to carry a sexual character to be actionable before the Ombudsperson. Mere inappropriate, undesirable, or harsh workplace behaviour did not meet the test.

  1. The definition is exhaustive. The court treated Section 2(h)'s list as closed — courts and the Ombudsperson cannot stretch it to cover every hostile-workplace complaint.

  1. Proof needs independent reinforcement. Sexual harassment allegations must be backed by impartial, credible material reinforced by convincing or independent evidence.

  1. Non-sexual misconduct is not without remedy. The court expressly said that where conduct lacks a sexual element, organisations can still take disciplinary action under their own service rules. The complaint simply does not belong before the Ombudsperson under this Act.

  1. The President's Section 9 power stands. The President is empowered to hear representations against the Ombudsperson's decisions, and the High Court, in writ jurisdiction, can interfere with such orders only on limited grounds — abuse of authority, violation of law, or breach of natural justice — not by substituting its own view of the facts.

  1. The FCC is not bound by Supreme Court precedent. The court relied on Article 189 of the Constitution to depart from earlier Supreme Court interpretations and lay down its own reading of the law.

What the FCC did NOT decide:

  • It did not strike down or reinterpret the 2022 amendment. The case was decided on the law as it stood in 2012–2013, before the amendment existed. The gender-discrimination limb, the expanded employee definition, and the single-incident rule remain on the statute book and were not declared invalid.

  • It did not rule on complaints arising after January 2022. For any harassment that happened after the 2022 amendment came into force, the amended — broader — definition applies. The FCC's "sexual in origin" reading was tied to the pre-2022 text.

  • It did not say non-sexual gender discrimination is not harassment today. Critics of the judgment — including the October 2026 op-eds in The News — argue precisely this point: the court's reasoning ignored the amendment that Parliament passed to cover exactly this ground.

  • It did not close the door to employer discipline. The court was explicit that employers can still punish inappropriate conduct under their own rules. A complaint rejected by the Ombudsperson as "not sexual" can still be misconduct under the organisation's service regulations.

  • It did not bar criminal complaints. Harassment that amounts to a criminal offence — under Section 509 of the Pakistan Penal Code (punishable with up to three years' imprisonment or a fine of up to five hundred thousand rupees, or both), or under cybercrime law — can still be taken to the police and the courts independently of this Act.

Why the Debate Exploded: The Other Side of the Argument

The FCC's verdict did not land in a vacuum. It landed against two powerful counter-weights, and both explain the fierce reaction.

The Supreme Court's 2025 judgment. In a February 2025 judgment authored by Justice Syed Mansoor Ali Shah (in the case of Muhammad Din v. Dr Sidra Zafar), the Supreme Court took the opposite view of harassment's nature. The Court declared that sexual harassment at the workplace is "less about sexual desire and more about control and domination" — a tool used to police and punish women who enter male-dominated spaces. The same line of Supreme Court authority recognised that gender-based discrimination and the creation of a hostile work environment — including denial of equal opportunities and criticism of abilities on gender grounds — fall within the amended Act. Justice Shah wrote that workplace harassment is "a systemic problem that perpetuates gender inequality by restricting women's economic and professional growth."

The FCC, relying on Article 189, declined to follow that approach — a move legal commentators have called a serious institutional concern, since it means two constitutional courts are now reading the same social problem in opposite ways.

The October 2026 op-eds. The News carried critical opinion pieces in the first week of October 2026 — one titled "Regression" — arguing that the FCC's interpretation departs from both the 2022 amendment and the Supreme Court's gender-justice framework. Their core argument: a woman facing intimidation, discrimination, or a hostile work environment because of her gender is not merely having "an unpleasant workplace experience." Such treatment restricts her ability to work, advance, and achieve economic independence. Reducing harassment to the question of whether conduct was "explicitly sexual" — the op-eds argued — misses the point of the law entirely.

The numbers tell their own story. The Federal Ombudsperson Secretariat for Protection Against Harassment (FOSPAH) reported in its 2024–25 annual report that it received 1,119 workplace harassment complaints and decided 1,047 of them — a roughly 375 per cent increase over the previous year. Punjab recorded the most cases (569), followed by Islamabad (303) and Sindh (254). The surge reflects both rising awareness and the 2022 amendment's expansion of who can complain. Whatever the FCC has said about pre-2022 cases, working women are using this law in record numbers today.

How to File a Complaint: Your Two Routes

Under the Act, you have two routes to file a harassment complaint. You do not have to go through your employer's committee first — the law gives you the choice, and many complainants go straight to the Ombudsperson.

Route 1: The employer's Inquiry Committee

  1. Write your complaint. Put it in writing, addressed to the Inquiry Committee of your organisation. Include dates, times, places, what exactly was said or done, and the names of any witnesses.

  2. Submit it to the committee. Every organisation covered by the Act is legally required to have one. Hand it in and keep a stamped copy or other proof of submission.

  3. The committee investigates. The committee communicates the charges to the accused within 3 days of receiving your complaint. The accused must file a written defence within 7 days of being notified.

  4. Findings within 30 days. The committee must complete its inquiry and submit findings and recommendations within 30 days of starting.

  5. Penalty imposed within a week. The competent authority implements the recommended penalty within one week of receiving the findings.

  6. Appeal if dissatisfied. Either side can appeal the committee's decision to the relevant Ombudsperson within 30 days.

Route 2: The Ombudsperson (FOSPAH or provincial)

  1. File directly with the Ombudsperson. Under Section 8 of the Act, you may file your complaint directly with the Federal Ombudsperson (FOSPAH — for federal government employees and federal territories) or the provincial ombudsperson (Punjab, Sindh, Khyber Pakhtunkhwa, or Balochistan, depending on where you work). FOSPAH's website is fospah.gov.pk, where complaints can be filed online, or you can file in person or by post.

  2. Show-cause notice. The Ombudsperson issues a show-cause notice to the accused, setting out the allegations with a copy of the complaint.

  3. Defence and hearing. The accused files a written defence. If the Ombudsperson cannot reach conclusions on the papers, both parties are summoned with their documents and evidence. Witnesses and records can be called.

  4. Findings and recommendations. After reviewing the evidence and hearing the parties, the Ombudsperson formulates findings and recommends a penalty.

  5. Representation to the President or Governor. A party dissatisfied with the Ombudsperson's decision may file a representation to the President of Pakistan (federal cases) or the Governor (provincial cases) under Section 9, generally within 30 days.

  6. Further review. Beyond that, the High Court can be approached in writ jurisdiction (on limited grounds, as the FCC has now emphasised), and then the constitutional courts above.

A note on the FCC's effect here: the FCC's ruling about "sexual in origin" was tied to the pre-2022 definition. If your complaint concerns conduct from 2022 onward, the amended Act — including the gender-discrimination limb — is the applicable law, and the Ombudsperson's jurisdiction is correspondingly wider.

The Inquiry Committee: What Your Employer Must Have

Section 3 of the Act obliges every organisation to constitute an Inquiry Committee. This is not optional, and it is not just for big companies — after the 2022 amendment, it extends across the formal and informal economy. The requirements are:

  • The committee must have at least three members.

  • At least one member must be a woman.

  • It receives complaints, investigates them, and recommends penalties to the competent authority.

If your employer has no inquiry committee, that is itself a violation of the Act. You can still file directly with the Ombudsperson — and the absence of a committee is a fact worth mentioning in your complaint, because it shows the employer is not complying with the law.

The statutory timeline for the committee process is strict: charges communicated within 3 days of the written complaint, defence within 7 days of notification, findings within 30 days of the inquiry's start, and penalty implementation within one week of the findings.

Penalties the Law Allows

If the accused is found guilty, Section 4 of the Act provides a graduated scale of penalties. The inquiry committee or the Ombudsperson recommends; the competent authority imposes.

Minor penalties:

  • Censure — a formal reprimand on record;

  • Withholding, for a specific period, of promotion or increment;

  • Stoppage, for a specific period, at an efficiency bar in the time-scale;

  • Recovery of compensation payable to the complainant from the pay or any other source of the accused.

Major penalties:

  • Reduction to a lower post or time-scale, or to a lower stage in a time-scale;

  • Compulsory retirement;

  • Removal from service;

  • Dismissal from service;

  • Suspension or cancellation of a professional licence (added by the 2022 amendment);

  • Fine — and a part of the fine may be paid as compensation to the complainant. Where the accused is the owner of the establishment, the fine is payable directly to the complainant.

Note the range: it runs from a written reprimand all the way to dismissal and licence cancellation. The severity should match the gravity of the conduct — which is why the FCC case, where compulsory retirement was reduced to censure on review, remains so contested.

Practical Tips: Documenting Harassment (For Working Women)

Winning a harassment complaint is, in practice, about evidence. The FCC's insistence on "impartial, credible material reinforced by convincing or independent evidence" makes documentation more important than ever. Here is how to protect yourself:

  • Keep a dated diary. The moment something happens, write it down: date, time, place, exactly what was said or done, who was present. A contemporaneous note — written the same day — carries far more weight than a memory recalled months later.

  • Save everything in writing. Keep screenshots of messages, emails, and any written communication. Do not delete chat histories. If harassment happens on a phone call, note the time and duration and follow up with a message summarising what was said ("As discussed on the call today...").

  • Tell someone you trust, promptly. Confiding in a colleague, friend, or family member at the time creates a witness who can confirm you reported the behaviour when it happened. Silence is often used against complainants later.

  • Use the internal channel in writing. Even an email to HR or the inquiry committee saying "I want to place on record that..." creates a paper trail that cannot be denied later.

  • Do not wait for a pattern. After the 2022 amendment, a single severe incident is enough. You do not need to endure months of behaviour to have a valid complaint.

  • Know the difference between the forums. If the conduct is sexual, stalking, or gender-based discrimination, the Ombudsperson and the inquiry committee are your forums under this Act. If it is also a crime — assault, threats, blackmail, sharing private images — file an FIR with the police as well. The two routes are not mutually exclusive.

  • Beware retaliation — and record it. The 2022 amendment specifically protects against retaliation. If you are punished for complaining — transferred, demoted, given adverse remarks, or dismissed — document that too. It strengthens, not weakens, your case.

  • Get advice early. A lawyer experienced in harassment cases can tell you which forum suits your facts and how to frame the complaint. Many women's rights organisations and legal aid cells offer free initial guidance.

What Employers Must Do: Code of Conduct and Committees

The Act places clear, positive duties on employers — duties that exist whether or not anyone has complained yet:

  • Display the Code of Conduct. The Act comes with a Code of Conduct (in its Schedule) that every organisation must display prominently at the workplace. It sets the expected standard of behaviour and the complaint procedure. If your office has never displayed it, that is a compliance failure.

  • Constitute the Inquiry Committee. A three-member committee with at least one woman, constituted in advance — not scrambled together after a complaint arrives. Its members should be trained and its contact details known to all staff.

  • Maintain a safe environment. The employer's overarching duty is to ensure a workplace free of harassment, abuse, and intimidation — the objective the Supreme Court has linked to Article 34 of the Constitution, which requires the state to ensure women's full participation in national life.

  • Do not punish complainants. Retaliation against a complainant — or against witnesses — is itself actionable. Transfers, adverse appraisals, or termination following a complaint will be read as retaliation unless the employer can prove otherwise.

  • Understand the FCC's "service rules" point. The FCC expressly preserved employers' power to discipline non-sexual misconduct under their own service rules. That means your internal disciplinary code should clearly cover bullying, intimidation, abuse of authority, and gender-based unfair treatment — even where the Ombudsperson might now decline jurisdiction over pre-2022-style complaints.

  • Take the 2022 expansion seriously. With domestic workers, interns, gig workers, students, and volunteers all covered, and with "workplace" extending to off-site and virtual settings, the old assumption that "this law is only for office staff" is dead. Review your policies accordingly.

Common Myths — Busted

Myth 1: "After the FCC verdict, the Ombudsperson cannot hear any harassment complaint unless it is explicitly sexual." Reality: The FCC's "sexual in origin" reading applied the pre-2022 definition to 2012–2013 conduct. For anything that happened after the 2022 amendment, the amended Act — including the gender-discrimination limb, which expressly covers non-sexual gender-based discrimination — remains the law. The amendment was not struck down.

Myth 2: "Harassment has to happen repeatedly — one incident does not count." Reality: Wrong since 2022. A single incident that makes a person uncomfortable or creates fear or panic at the workplace is harassment under the amended Act.

Myth 3: "Only women can complain." Reality: Also outdated. The 2022 amendment changed "a woman or man" to "any person", so men and transgender persons are protected too.

Myth 4: "I must complain to my office committee before going to the Ombudsperson." Reality: No. Section 8 gives you the option to file directly with the Federal or provincial Ombudsperson. Going to the internal committee first is a choice, not a requirement.

Myth 5: "The FCC said harsh or unfair bosses cannot be punished at all." Reality: The court said the opposite. It expressly held that organisations can take disciplinary action against inappropriate, non-sexual conduct under their own service rules — the remedy just lies with the employer rather than the Ombudsperson under this Act.

Myth 6: "If the Ombudsperson or the President decides, that is the end — no court can touch it." Reality: The President's and Governor's orders under Section 9 are subject to judicial review by the High Court — though, after the FCC verdict, only on limited grounds: abuse of authority, violation of law, or breach of natural justice. The High Court cannot simply substitute its own view of the facts.

Myth 7: "Filing a harassment complaint means I cannot also go to the police." Reality: You can do both. If the conduct is also a criminal offence — assault, criminal intimidation, stalking, sharing private images — file an FIR alongside (or instead of) the workplace complaint. Under Section 509 of the Pakistan Penal Code, harassment is a crime punishable with up to three years' imprisonment or a fine of up to five hundred thousand rupees, or both.

Frequently Asked Questions

Q: What exactly did the Federal Constitutional Court decide in September 2026? A: In Usman Shahid and Aqeel Abbas v. Nadia Sarwar & others, the FCC held that under the pre-2022 version of the 2010 Act, harassment had to be "sexual in origin" to be actionable before the Ombudsperson. It set aside the Islamabad High Court's judgment, restored the President's order reducing the two NBP officers' penalty from compulsory retirement to censure, and limited the High Court's power to interfere with presidential orders under Section 9 to cases of abuse of authority, legal error, or breach of natural justice.

Q: Does the FCC verdict mean non-sexual gender discrimination at work is now legal? A: No. The verdict interpreted the law as it stood before the 2022 amendment, for conduct from 2012–2013. The 2022 amendment expressly defines gender-based discrimination — "which may or may not be sexual in nature" — as harassment, and that provision remains in force. For conduct after January 2022, the broader amended definition applies.

Q: Where do I file a workplace harassment complaint in Pakistan? A: You have two options under Section 8 of the Act: file a written complaint with your employer's Inquiry Committee (three members, at least one woman), or file directly with the Federal Ombudsperson (FOSPAH, at fospah.gov.pk) or your provincial ombudsperson. You do not have to go through the committee first. If the conduct is also a criminal offence, you can additionally file an FIR with the police.

Q: How long does the complaint process take? A: The law sets strict timelines for the internal route: charges to the accused within 3 days of the written complaint, the accused's defence within 7 days, the committee's findings within 30 days of starting the inquiry, and penalty implementation within one week of the findings. Appeals to the Ombudsperson must be filed within 30 days, as must representations to the President or Governor under Section 9.

Q: What punishments can be given for workplace harassment? A: Minor penalties include censure, withholding of promotion or increment, stoppage at an efficiency bar, and recovery of compensation from the accused's pay. Major penalties include reduction to a lower post, compulsory retirement, removal or dismissal from service, suspension or cancellation of a professional licence (added in 2022), and a fine — part of which can be paid as compensation to the complainant.

Q: My employer has no inquiry committee and no displayed code of conduct. What does that mean? A: It means your employer is violating the Act. Section 3 requires every organisation to constitute a three-member inquiry committee with at least one woman, and the Code of Conduct must be displayed at the workplace. You can still file directly with the Ombudsperson — and you should mention the employer's non-compliance in your complaint, since it reflects on the organisation's failure to provide a safe workplace.

The Bottom Line

The September 2026 FCC verdict is a significant but narrow decision: it read the pre-2022 definition of harassment as confined to conduct sexual in origin, overturned the Islamabad High Court, and restored a presidential censure in a 2012 National Bank case. It did not repeal the 2022 amendment, did not legalise gender discrimination at work, and did not shut the Ombudsperson's door to complaints arising under the amended law. For anything that happened after January 2022, Parliament's broader Act — covering gender-based discrimination whether sexual or not, stalking and cyberstalking, single incidents, domestic workers, gig workers, students, and transgender persons — is still the law of the land.

That said, the verdict is a warning. The FCC's demand for "impartial, credible material reinforced by convincing or independent evidence" means complainants must document meticulously from day one. And the open tension between the FCC's narrow reading and the Supreme Court's 2025 "control and domination" framework means this area of law is still unsettled at the very top — expect further litigation, and possibly legislative clarification, before the dust settles.

For working women, the practical message is unchanged: know your two complaint routes, document everything in writing, and do not wait for a pattern before acting. For employers, the message is equally clear: constitute your inquiry committee, display the code of conduct, train your people, and make your internal disciplinary rules cover the bullying and gender-based unfairness the courts are now arguing about. A safe workplace was never just about avoiding lawsuits — it is, as the Supreme Court put it, about women's equal right to earn a livelihood with dignity.

This article provides general legal information for readers in Pakistan and is not legal advice. Workplace harassment law involves a recent, actively debated court verdict and a 2022 statutory amendment whose interaction is still being litigated; every workplace situation is different. For your specific case, please consult a qualified advocate.