I, Mukul Khandelwal, hereby give my reply to the alleged accusation,

allegation, and remark leveled against me dated __. __. __ as received on mail
under the POSH Act.

PRELIMINARY OBJECTIONS
1. It is submitted that the complaints under reply of the complainants
(Ms. Bishakha, Ms. Angelina Pather, and Ms. Swati Singh) are not
appropriate and the same is made by the Complainants with a sole
objective to defame me and accomplish evil motive for the only reason
which is that the complainants do not like the gesture of my work and
because I am their team leader, and I do not accept any direct or
unnecessary requests, so to get rid of me, these complaints are filed.
2. That by the perusal of complaints made by the all the complaints, it can
be observed that same are made with collective and joint approach
motivated by same planning, i.e., to remove me from the company with
serious allegations so I may not be able to work in future even in some
other company.
3. The allegations made against me are preposterous, incorrect, and
illogical. That same is the concocted and well-thought-out trick that has
nothing to do with real circumstances. I have been wrongly framed by the
complainants because of the very reason that I was not allowing them to
work casually during office hours, that I have told them to follow all
work ethic related mandatory standards, but time and again they all were
failing to meet those, so as per my duty towards the company had to be
stricter and more careful so that the management and the affair of the
company had not to suffer.
4. It is further submitted that the contents and averments of the complaint
made by all the three complaints are a strategic and in collusion approach,
therefore, in many contents and averments, there is a repetition of the
 same alleged allegation which is not at all possible in any given possible
scenario.
5. That I will be responding to each allegation leveled against me
specifically in para wise reply, otherwise also I would like to take the
attention of the governing Committee to one instant wherein
6. Under point 3.4 of the company’s policy for the Prevention, Prohibition,
and Redressal of Sexual Harassment of Women at the Workplace, it has
been specifically mentioned that the following things will not attract
sexual harassment i.e.; -
 Interactions between an individual that is mutual, consensual,
welcome, appreciated, and/or reciprocated.
 Following up on work absences.
 Requiring performance to meet job standards and giving feedback
about work-related mistakes.
 Work-related stress i.e., meeting the deadline or quality standards.
That the whole centric issue is related to the above-mentioned points
only. As per the policy of the company, everyone has to do work up to an
expectation wherein the company can progressively grow, hence, there
often comes a time wherein certain people have to take strict methods to
maintain the discipline in the company. But, giving such discipline and a
strict approach to job standards as sexual harassment is nothing but a
frivolous approach to degrade the person or authority.
7. That I have been in this profession/work for last 17 years, here in this
company for last 2 years and it is submitted that besides this complaint, I
have never been a respondent to any such complaints under the POSH or
any other laws, rules, regulations set-up for the protection of women. The
sole purpose of all these complaints is to remove me from my positions
with such serious allegations, so I may not be able to get a job anywhere
else for the very reason that all the complainants were unhappy with my
 strict job standard approach which includes coming on time, no instant
leave is allowed, compliance to the job and industry standards, etc.

Para wise Reply: -

Ms. Bishakha

1. That para under reply is wrong and denied. It is vehemently denied that I,
Mukul Khandelwal, have ever made any body shaming, or derogatory
remarks on any of my colleagues, seniors, or juniors. This averment is
false and incorrect and the same is leveled against me for some hidden
malafide intention best known to her. It is further submitted that the
conversation related to the “modeling” was started and initiated by Ms.
Bishkha only. She, one day told me that she was into some modeling
projects in her college days and was also involved in other tasks related to
modeling only. That it was only her comments wherein she mentioned
that due to her being a little chubby, she had left modeling. I, myself,
have never put on any conversation related to modeling at all or given
anyone body-shaming, or derogatory remarks. Further, there were other
incidents also wherein Bishakha herself mentioned issues related to her
body weight.
2. The contents of Para 2 are wrong and denied. It is denied that due to my
behavior of being frank, as alleged by Ms. Bishakha, had become
intolerable for her. It is submitted that be it Ms. Bishakha or any other
person, irrespective of gender and designation, I never indulged with
anyone apart from work-related causes. That allegation of me being over-
friendly to seek conversation with her or anyone is incorrect, illogical,
and wrong.
3. That the averments made in para 3 are wrong and denied. It is denied that
I have ever asked Ms. Bishakha to accompany me for drinks or OYO
 rooms or anywhere else. That these averments are marked against me to
take out personal grudges from me by filing a false and baseless
complaint by a collective approach of all the three complainants. It is
submitted that I being senior of Ms. Bishakha and other alleged
complainants, was never professionally accepted by the complainants. In
a routine task of corporate affairs, I have had to be very particular related
to my designation and work ethic and on the other side, Ms. Bishakha and
other complainants were very causal as per their work profile. So, to
protect the affairs and management of the company, I had to be a little
strict towards them. There were many instants wherein all of the three
complainants were irresponsible related to office timings, they were
continuously taking unscheduled leaves, collectively were affecting the
performance of my team, hence, I got summoned by higher designation
people of the company and was asked to work ethically concerning the
performance of the company. From this day, I had become more
responsible related to the working performance of my team and therefore,
asked all my team members to strictly follow the office schedule and
leave applications. It was thereafter only when I started to reject
unnecessary leave applications or late office timings of Ms. Bishakha and
other complainants, they took it otherwise and started developing an
aggressive and deceptive approach against me. It is further submitted that
all the remarks, allegations, and complaints marked against me are the
result of this aggressive and deceptive approach to me i.e., to achieve the
evil motive reasons which are best known to them only.
4. The contents of para under reply are wrong and denied. It is denied that I
belong to any specific group, or if I associate with such people who talk
about other colleagues or members of the company. I have been in this
profession for the last 17 years, and have always followed the work ethics
as required by a professional. Further, I employed by this company since
 May 2018 and within this period, I can tell that I have not been part of
any illicit or unethical group or association.
5. That the contents of para under reply are wrong and denied. It denied
vehemently that I have ever used any abusive language against
Ms. Bishakha or anyone else. Further contents of the para under reply are
also wrong and denied. In response to it, it is submitted to me that Ms.
Bishakha and other complainants together have written a creative piece of
the concocted story which has neither head nor legs and this whole story
is not even close to the reality.
6. That the last part of the complaint is simply an observation made by
Ms. Bishakha and the same needs to reply.

Para wise Reply: -

Ms. Angelina Pather
1. That the whole contents of para 1 are wrong and hence denied. It is
denied that I have ever made any contact physically or virtually with
Ms. Angelina apart from routine office work. It is submitted if any video
call is being made by me to Ms. Angelina, the same is always related to
office work. I have never made any calls to Ms. Angelina which has
nothing to do with work or routine appreciated colleague conversations.
It is denied that I have ever given any compliment to Ms. Angelina
regarding her outfit or physical attributes. All the pointers made in the
para under reply are specifically denied, as such the same are misused to
glorify the concocted story of the complainants. It is submitted that any
conversation which is done between me or any other person of staff is
strictly related to work or is related to routine colleagues’ conversation
which includes gesture of asking about how well the life is going on,
what are the expectation from life ahead, etc. That nothing irrelevant or
improper have been asked by me to any of my colleague in this office or
 anywhere else. That the last pointer in para under reply denied that I
have got her sister’s number from the emergency contact list to reach out
to her. It is submitted that Ms. Angelina was remaining absent from work
without taking any prior leave from the concerned authority, so as a part
of my duty I was trying to call her to know about her whereabouts. That
it was only after her number was also switched off, that I tried calling her
sister to know the reason why is not coming to the office. That such a
task is a duty that is expected to be performed by knowing about the
working culture of my teammates. It has nothing to do with a motive
other than work purpose.
2. It is wrong and hence denied that I have ever said such things regarding
the dress changing part or anything related to suggesting Ms. Angelina
pursue a career in modeling. It is submitted that there happened to be my
unregistered company namely “Deewine Events” which engages in
business related to auditioning and recruitment of models and all the
complainant came to know about this and during a normal conversation,
they are enquired about this company. I further submit that, I have never
asked or given suggestions to any one of them or even anyone else
otherwise, to join in for modeling. These allegations are false and the
same is produced with the intent to defame me by hook or crook. It is
further denied that I have ever asked Ms. Angelina to go on a date. I
would like to submit in this regard that, I am a happily married man and
have kids at my home. Such accusations/allegations against me describe
the desperate attempt made by all the complainants collectively and in
collusion to spare no part of my life wherein I can live afterward. I again
submit that, I only indulged with all the complainants and other staff,
colleagues, juniors, and seniors of this company up to the extent of work-
related affairs, nothing at all more than that. That the contents of para
under reply wherein allegations are made that I used to give head
 massage and unprofessional comments, are delirious and insensible and
same are denied vehemently. All such allegations are being motivated by
the sole intention to gain publicity that may help gain sympathy. Further,
such allegations are baseless and need practical reasoning when the
whole office premises is under the strict surveillance of the camera. That
the complainant Ms. Angelina to hide her incompetency in fulfilling the
standard duty of task assigned to her is making such false allegations. It
was only the order of my senior wherein due to her failure to perform the
task appropriately, she was asked to change the task of attending chat to
outbound calls and the same was compiled by me as per the orders of
seniors. Further, to divert this controversy that describes her incapacity
to discharge her professional duty, she is making a concocted story to
attach with POSH, hence, all the contents of the relevant para are denied.
3. It is wrong and denied that just because Ms. Angelina stopped talking to
me, I went on rude with her. It is submitted that this issue is regarding
the requirement needed for job performance. That Ms. Angelina is
presenting and mixing it up the same to her concocted story of false
allegations. It is submitted that in every working department, there are
many ups and downs related to work energy and efficiency and may
result in getting scolded by the seniors, but to give it a form that is far
away from its true meaning is very inappropriate. I would like to repeat
that, all the remarks, allegations, and accusations leveled against me are
a part of a collective strategy to represent my verbal statement in such a
way that it may look inappropriate. Otherwise, also, all such remarks,
allegations, and accusations are strongly indicating to a well-planned
story of complainants which is being made in collusion.
4. That the last part of the complainant of Ms. Angelina is a matter of
general commutation and same needs to reply. I, strongly believe that
there should be zero tolerance for sexual harassment in any working
 condition, but at the same time, false accusations shall also be given the
same preference to deal with.
Para wise Reply: -
Ms. Swati Singh
1. The contents of para 1 are accepted and need no reply.
2. The contents of para 2 are wrong and hence denied. It is submitted that I
have never asked her to join me in the smoking zone, neither she has
ever smoked with me. The contents of this para are a frivolous, false, and
fabricated story as my mother died on 01 st June 2021, my father died on
01st September 2021, and my conversation with Ms. Swati Singh started
on 20th November 2021. The remarks made that I used to share my
family stories with her are false and fabricated, as I am having a happily
married life, I and my wife has cordial relations and there is no
complaint, etc.
That Ms. Swati Singh had made false allegations and an afterthought
story regarding me sharing my family’s issues/stories with her. I further
submit that, I only have had a routine conversation with her regarding
office work and tasks, nothing more than that we ever talked.
3. I have never asked her to come to the smoking zone, I am working in this
company since May 2018, I smoke 10-12 times every day and go to the
smoking area 10-12 times every day. The same can be verified from the
CCTV footage of the camera nearby. The said smoking area is a
staircase, where there are many people, and I am never alone.
This girl used to work in the shift 07 AM to 4 PM, I used to reach her at
07:30 in the morning at the office, she used to come in the morning shift.
I never asked her, nor did I ever demand any company to smoke with
me, I go there 10-12 times a day and she also used to come there with her
friends. It is not that she used to go with me, she was either already there
 when I used to enter the smoking area or she used to come in between,
but that doesn't mean I've ever asked her to come with me.
The comment “Why are you here. You are so tall, you should join
modeling, and if you want I can help you out”, is a false story, and the
same is mentioned by the other two complainants, in collusion with each
other. All the comments leveled against me by all three complainants
regarding modeling are wrong and are purposely given such a look that
allegations can be put against me. The response mentioned regarding
this controversy above may kindly be read as part and parcel of this
reply which is not repeated here for sake of brevity
4. The contents of this para are denied. The said colleague “Ms. Angelina
Pather” is also a part of this conspiracy, she is also a part of this play.
That Ms. Angelina Pather joined in February and Ms. Swati Singh joined
in August, this comment has no relation to each other.
5. The contents of this para are denied. No such conversation ever
happened and the same is a false story that is vehemently denied. The
content of preliminary objections and para-wise reply may kindly be read
as part and parcel of this reply.
6. The contents of this para are denied. No such conversation ever
happened. It is submitted that I have never used abusive language, I have
been working in this company since May 2018 and there have never
been any complaints about me like this. I lead a team of 21 people and
the same can be verified by them.
7. That the story mentioned by the complainant about me asking her and
other members to join in a meeting to discuss who said what is an
imaginary situation created by the complainant. There have been
instances where we did meetings discussing our performances and goals,
also, there had been meeting where we had a fun conversation, cracked
jokes so that there is a balance in the office and no one works under
 pressure and giving this an angle of false allegation is nothing but a
desperate attempt to defame me and work ethics, hence the relevant is
wrong and denied.
8. That the last part of the complainant is an imaginary conclusion created
by the complainant Ms. Swati Singh which is strongly denied and all
such conclusions and I submit that I have been to many offices,
companies, and working culture, and have never been a part of any
mishappening be it related to women or politics. All these accusations,
allegations, and remarks against me are nothing but an attempt motivated
by a revenge factor for my being an honest and disciplined employee.

Apart from the reply, I further seek the liberty of this committee to allow me to
submit relevant documents/annexures consisting of electronic communication
and emails pertaining to the present case on any other date, as may be required
and allowed by the committee.

Dated:
Gurugram
Mukul Khandelwal