July 11, 2026
Staff Report
ISLAMABAD
The Supreme Court of Pakistan has issued comprehensive guidelines requiring all government and private educational institutions across the country to adopt internal harassment policies, establish in-house inquiry committees, and display the legally mandated Code of Conduct for Protection against Harassment of Women at the Workplace, directing federal and provincial education ministries to enforce these measures immediately.
A two-member bench comprising Justice Muhammad Ali Mazhar and Justice Musarrat Hilali issued the directives in a 12-page judgment, while simultaneously restoring a five-year service forfeiture penalty against a Faisalabad headmistress who had been found guilty of gross negligence for failing to act on written complaints of sexual harassment lodged by female teachers under her supervision.
The guidelines
The court directed that every educational institution must establish a clear internal harassment policy supported by an effective reporting mechanism accessible to all staff.
Crucially, the bench ruled that departmental inquiries into harassment complaints must be conducted independently and must not be made contingent upon proceedings before the Federal Ombudsperson or provincial ombudsmen, a practice the court indicated had allowed complaints to go unaddressed at the institutional level.
The bench directed federal and all provincial education ministries to issue office orders or circulars requiring heads of all government and private educational institutions to prominently display the Code of Conduct for Protection against Harassment of Women at the Workplace in both English and local vernacular languages.
Every institution was further directed to constitute an in-house inquiry committee under the Protection against Harassment of Women at the Workplace Act, 2010, comprising at least three members of whom at least one must be a woman, so that an aggrieved female teacher may submit her complaint directly to the committee rather than depending solely on the head of institution to act.
“The head of the institution has an onerous duty to create such an environment at the workplace which should openly express and convey unequivocally for all that no sexual harassment would be acceptable at the workplace, rather professionalism with full dedication must be the set standard”, the order said.
The case
The guidelines arose from a case involving Shazia Iqbal, who was serving as Principal and Headmistress at the Government Special Education Centre, Lyalpur Town, Faisalabad. A departmental inquiry established that a male special therapist, Kamran Khan, had been illegally residing on the institution’s premises and had been habitually molesting female teachers, blackmailing them, threatening them with dire consequences and pressuring them into illicit relations. Female teachers had submitted written complaints directly to the headmistress, who took no action.
The competent authority found Shazia Iqbal guilty of grave negligence and inefficiency, awarding the penalty of forfeiture of five years of past service. The Punjab Service Tribunal, however, reduced the penalty further to one year in December 2023, prompting the Punjab government to approach the Supreme Court.
Tribunal’s leniency overturned
The Supreme Court set aside the tribunal’s order, holding that it had failed to appreciate the gravity of the charges and the consistency of witness testimony. Multiple female teachers had appeared before the inquiry, deposed against the headmistress and withstood cross-examination without contradiction.
The court warned that softening punishment in such cases carried serious institutional consequences. “If such gratuitous leniency is shown in obnoxious and repulsive matters, it will amount to lending a license to take up again alike acts in the future without any deterrence or trepidation,” the judgment stated.
The judgment defined the scope of prohibited conduct in explicit terms, holding that sexual harassment of female teachers by male colleagues encompasses “unsolicited comments, remarks, jokes or messages of a sexual nature; catcalling or alike inappropriate behaviour; pressure for illicit favours in exchange for job benefits; attempts of unsolicited physical contact and creating hostile or unsafe work environment,” conduct that “not only violates a person’s dignity and safety but deteriorates the environment of the entire institution.”
The court further observed that an institution tolerating harassment fundamentally contradicts its educational mission, as it teaches students that power excuses misconduct and silence is preferable to truth.
The court held that headmistress was required to act as a “materfamilias” — the responsible head of an institutional family — and “could not shut her eyes or behave quietly being tight-lipped on the complaints filed by the lady teachers for sexual harassment in writing against Kamran Khan.”
The court directed its office to transmit copies of the judgment to the Federal Secretary of the Ministry of Education, Chief Secretaries and School and Higher Education Secretaries of all provinces, and the Federal Ombudsperson and all provincial ombudsmen, with directions to ensure implementation at the grassroots level across all public and private educational institutions.