Grievance Redressal Committee at 20 Workers: Members, Women's Share and the 30-Day Clock Under the IR Code
Every industrial establishment with 20 or more workers must have a grievance redressal committee under section 4 of the Industrial Relations Code. It has equal employer and worker members, no more than 10 in all, with women at least in proportion to the workforce. A worker can apply within one year; the committee may decide within 30 days.
The grievance redressal committee is the labour code requirement smaller employers most often miss, because it starts at just 20 workers. It is not an HR helpdesk. It is a statutory body with fixed composition, a voting rule that protects the workers' side, and a route onward to conciliation. Here is how to set it up and run it.
Who needs one
Section 4(1) of the Industrial Relations Code, 2020 requires every industrial establishment employing 20 or more workers to have one or more grievance redressal committees (GRCs) to resolve disputes arising from individual grievances.
- ✓Count workers, not managers and supervisors outside the Code's definition.
- ✓A large site can have more than one GRC, for example one per plant or shift group.
- ✓The GRC is separate from the Internal Committee under the POSH Act. Sexual harassment complaints still go to the Internal Committee.
Composition
| Requirement | Rule |
|---|---|
| Members | Equal numbers from employer and workers (section 4(2)) |
| Total size | Not more than 10 (section 4(4)) |
| Women | At least in proportion to women in the workforce (proviso to section 4(4)) |
| Chairperson | Rotates every year between the employer side and the worker side (section 4(3)) |
| Worker members, central sphere | Nominated by the negotiating union or council; if none, chosen by workers from among themselves (Industrial Relations (Central) Rules, 2026) |
PRS Legislative Research notes that the Central Rules do not fully spell out how workers choose representatives where there is no union. Use a simple, recorded election and keep the minutes. State-sphere establishments should check their state's IR rules.
How a grievance moves
- Filing. An aggrieved worker files an application within one year of the cause of action (section 4(5)).
- Hearing. The GRC may complete proceedings within 30 days of receiving it (section 4(6)). The word is "may", but the 30 days also starts the worker's next clock, so treat it as a deadline.
- Decision. By majority, provided more than half of the worker members agree. If they do not, the committee is deemed to have reached no decision (section 4(7)).
- Conciliation. A worker unhappy with the decision, or whose grievance is not resolved in 30 days, may apply to the conciliation officer through their trade union within 60 days of the decision or of the 30-day period ending (section 4(8)).
- Tribunal. For a dispute about discharge, dismissal, retrenchment or termination, the worker may go directly to the Industrial Tribunal once 45 days have passed after applying for conciliation (section 4(10)). Such individual termination disputes are industrial disputes even without union backing (section 4(9)).
Setting it up in practice
- ✓Fix the size first (4, 6, 8 or 10), then work out the minimum number of women.
- ✓Issue an office order naming members, the chairperson for the year, and the date of rotation.
- ✓Publish a one-page procedure: how to file, the one-year limit, the 30-day target, and the conciliation route.
- ✓Keep a register of applications with the date received, hearing dates, decision and the votes on each side.
- ✓Review membership when people leave and when the women's share of the workforce changes.
A worked example
A Coimbatore pump maker has 140 workers, of whom 35 are women. Its 12 shift supervisors each draw ₹32,000 a month. Supervisors earning more than ₹18,000 a month fall outside the Code's definition of "worker" (section 2(zr)), so they are not counted in the 140.
Composition
- Women's share: 35 ÷ 140 = 25%
- Committee size chosen: 8 (4 employer, 4 worker)
- Minimum women members: 25% × 8 = 2
- Voting: more than half of the 4 worker members means at least 3 worker members must back any decision.
Timeline for one grievance about wrongly cut overtime
| Event | Date |
|---|---|
| Application received | 5 November 2026 |
| 30-day period ends | 5 December 2026 |
| Last day to apply for conciliation (60 days) | 3 February 2027 |
Working: from 5 December, 26 days take you to 31 December, 31 more to 31 January (57), and 3 more to 3 February 2027 (60).
If the grievance had been about a dismissal and the worker applied for conciliation on 10 December 2026, the 45-day wait ends on 24 January 2027 (21 days to 31 December, plus 24 in January), after which he can approach the Tribunal directly.
Common mistakes
- ✓An all-management committee, or more employer than worker members.
- ✓No women members, or fewer than the workforce share requires.
- ✓Counting a decision carried by employer votes plus one worker vote.
- ✓No register, so there is no proof of when the 30 days started.
Frequently asked questions
Can our HR manager alone act as the grievance committee?
No. Section 4 requires a committee with equal employer and worker members, up to 10 in total.
Is the 30-day limit binding on the committee?
The Code says the committee "may" finish within 30 days. If it does not, the worker can move to conciliation, so delay only shifts the matter out of your hands.
Can a worker who is not a union member go to conciliation?
Section 4(8) routes the conciliation application through the worker's trade union. Termination disputes are industrial disputes even without a union under section 4(9), and can reach the Tribunal under section 4(10).
Do we need a separate committee for each site?
The Code allows one or more committees. Separate sites with their own workforce usually work better with their own GRC.
Sources
- ✓Industrial Relations Code, 2020 (Gazette text, sections 2 and 4), Ministry of Labour and Employment
- ✓Industrial Relations (Central) Rules, 2026, G.S.R. 342(E), Ministry of Labour and Employment
- ✓Industrial Relations Code, 2020, section 4, PRS India
- ✓Industrial Relations (Central) Rules, 2026: analysis, PRS Legislative Research
- ✓Industrial Relations (Central) Rules, 2026 explained, SCC Online
This is a summary, not legal advice. Confirm your state's IR rules on selecting worker members with the state labour department or a labour lawyer.
Written by
HR Manager, Airwix Technologies (Sleet)
Nihit Dobariya is the HR Manager at Airwix Technologies in Ahmedabad, where he runs HR and payroll for the team behind Sleet. He writes about payroll, PF and ESIC, professional tax, the labour codes and everyday HR practice for Indian employers, and checks each rule against the official notification before it is published.
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