Adv.

Nikita Sonavane
Adv. Ameya Bokil

To,

Mr. Umakant Gundecha

Chairperson,

Drupad Sansthan, Bhopal

16.09.2020

Dear Sir,

We are submitting this representation as the legal representatives for several of the complainants in
the sexual harassment case against Mr. Akhilesh Gundecha, Treasurer and Pakhawaj Teacher at
Dhrupad Sansthan (“Sansthan”) as well as Late Mr. Ramakant Gundecha, former member of your
management and a teacher. This representation is being written to bring to your notice my clients’
concerns with the process being undertaken by the Committee constituted to investigate the
allegations against Late Mr. Ramakant Gundecha and Akhilesh Gundecha by Dhrupad Sansthan.

1. We would like to highlight that the Sansthan has been in violation of the provisions of the
Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act,
2013 (“SHWA”) since its coming into force, having never constituted an Internal
Complaints Committee (“ICC”).

2. That given that Drupad Santhan is a trust, where number of persons from across India and
abroad come to work on their skills and form close fiduciary relationship for a number of
years with the teachers at the Sansthan, they must be deemed to be apprentice at the
Sansthan.

3. That we have noted the letter ICC/2020/20 dated September 16 2020 signed by Mr. Anant
Gundecha, Secretary of the Sansthan, by which an ad hoc committee has been constituted.
That our clients have concerns that the same has not been constituted in consonance with
Section 4 of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and
 Redressal) Act, 2013. Given the non-compliance, there are concerns about its competence to
conduct a fair, just and impartial inquiry into the aforesaid matter.

4. We, therefore, ask you to stay the commencement of the inquiry of the said committee
formed until our clients are able to revert with specific concerns about the composition of
the Committee and the process of its composition.

5. We would like to make recommendations in order to ensure compliance with SHWA as well
as our clients’ trust in the proceedings.

As informally, conveyed to my clients, that you value the perception of trust our clients’ have in the
process, we expect you to respect their wishes. Our clients would like to state that they would be
happy to participate and cooperate in proceedings undertaken in compliance with the Act.

Nikita Sonavane and Ameya Bokil

Advocate