Section 4 explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
Section 4 of the Industrial Relations Code, 2020 requires every industrial establishment employing twenty or more workers to have a Grievance Redressal Committee for individual grievances, and it sets a ladder of time limits: one year to apply, thirty days for the committee, sixty days to move to conciliation, and forty-five days before a worker can go straight to the Tribunal. This article takes the eleven sub-sections in order.
Every industrial establishment employing twenty or more workers shall have one or more Grievance Redressal Committees (s.4(1)). It has equal employer and worker members, at most ten, with the chair rotating yearly. A worker applies within one year of the cause of action; the committee may finish in thirty days; an aggrieved worker has sixty days to apply for conciliation through his Trade Union; and he may go directly to the Tribunal after forty-five days from his conciliation application, within two years of a termination.
Who must have one and how it is built
Threshold and duty (s.4(1))
An industrial establishment employing twenty or more workers must have one or more Grievance Redressal Committees for resolution of disputes arising out of individual grievances. Unlike the Works Committee in section 3, this committee needs no Government order: the duty is in the Code itself. "Workers" is as defined in s.2(zr); see the definition of worker.
Employers can get help designing the forum through our employment and labour law advisory service.
Composition (s.4(2) to (4))
| Sub-section | Rule |
|---|---|
| 4(2) | Equal number of members representing the employer and the workers, chosen in the prescribed manner |
| 4(3) | The chairperson is selected from employer and worker representatives alternately, on a rotational basis every year |
| 4(4) | Total members not more than ten; adequate representation of women workers, not less than their proportion to total workers |
The Central Rules, 2026 (Central-sphere establishments)
Rule 6 of the Industrial Relations (Central) Rules, 2026 (G.S.R. 342(E), 8 May 2026) fills in the prescribed manner for establishments where the Central Government is the appropriate Government. State Governments make their own rules where the State is the appropriate Government.
- Employer representatives are nominated by the employer, as far as possible officials in direct touch with the establishment, preferably heads of major departments (rule 6(2)).
- Worker representatives: nominated by the negotiating union (s.14(2) or (3)); or in proportion to membership by the registered Trade Unions in a negotiating council (s.14(4)); or, where there is neither, chosen by the workers among themselves, with an option for the employer to use an electronic platform (rule 6(3)).
- The term of members is three years (rule 6(4)).
- A dispute about choosing worker representatives, where there is no recognised negotiating union or council, may be referred to the Regional Labour Commissioner (Central), whose decision is final (rule 6(5)).
The procedure and the time limits
Step 1: application to the committee (s.4(5))
An aggrieved worker may file an application before the committee, in the prescribed manner, within one year from the date the cause of action arises. Rule 7 of the Central Rules says the application states the worker's name, designation, worker code or token number, department, length of service in years, category of worker, address, contact number, details of the grievance and the relief sought. It may be sent electronically or otherwise and must be filed within one year of the cause of action.
Step 2: the committee decides (s.4(6) and (7))
- The committee may complete its proceedings within thirty days of receipt of the application (s.4(6)). The word is "may": the text does not make thirty days a hard deadline, though it starts the next clock.
- A decision is made on the majority view, provided more than half of the worker-side members agree; otherwise it is deemed that no decision could be arrived at (s.4(7)).
Step 3: conciliation (s.4(8))
A worker aggrieved by the decision, or whose grievance is not resolved within the thirty-day period, may within sixty days from the date of the decision, or from the date the thirty-day period expires, file an application for conciliation with the conciliation officer through the Trade Union of which he is a member, in the prescribed manner. Rule 8 of the Central Rules allows the application online on the designated portal of the Ministry of Labour and Employment, by speed post or in person, and the conciliation officer digitises manually received applications and informs the Trade Union and worker.
Step 4: direct access to the Tribunal (s.4(10) and (11))
Notwithstanding s.4 or s.53, a worker may apply directly to the Tribunal for adjudication after the expiry of forty-five days from the date he applied to the conciliation officer of the appropriate Government. The Tribunal then has the powers and jurisdiction it has for an application under s.53(6). Under s.4(11) that application must be made before the expiry of two years from the date of discharge, dismissal, retrenchment or termination.
| Stage | Time limit | Source |
|---|---|---|
| Apply to Grievance Redressal Committee | Within 1 year of cause of action | s.4(5) |
| Committee completes proceedings | May complete within 30 days of receipt | s.4(6) |
| Apply to conciliation officer | Within 60 days of decision or of end of the 30 days | s.4(8) |
| Apply directly to Tribunal | After 45 days from conciliation application | s.4(10) |
| Outer limit for termination cases | Within 2 years from termination | s.4(11) |
Terminations and industrial disputes (s.4(9))
Where an employer discharges, dismisses, retrenches or otherwise terminates the services of an individual worker, any dispute or difference between the worker and the employer connected with or arising out of the termination is deemed to be an industrial dispute, even if no other worker and no Trade Union is a party. This mirrors the individual-dispute limb in the definition; see industrial dispute under s.2(q).
Points the text leaves open
- The section does not say what happens if the employer fails to constitute the committee; look to the penalty provisions and s.86(20) for residual penalties and take advice.
- The committee deals with individual grievances; collective disputes go through the other chapters.
- The Code says the conciliation application goes "through the Trade Union, of which he is a member". It does not say how a worker with no union membership proceeds under s.4(8); the direct route in s.4(10) and the Rules should be read together for that case.
Example. A worker at a 60-worker unit is refused a leave encashment he claims on 10 April. He files with the committee on 20 April. The committee meets but the worker-side members do not agree on a decision by 20 May. On 20 May the thirty days expire; he has sixty days from then, to 19 July, to apply for conciliation through his union. If he files on 1 July, the forty-five days expire on 15 August, so he may apply to the Tribunal after that, from 16 August (on the usual way of counting days; confirm the counting for your case).
Need help setting up or using the committee?
Setting up the committee, choosing representatives and recording decisions is routine for HR but easy to get wrong. Our employment and labour law advisory team can help you design the forum and the record-keeping, or advise a worker or union on the next step. Bring your worker list and any grievance policy you currently follow.
Key takeaways
- Twenty or more workers means at least one Grievance Redressal Committee, with no Government order needed.
- Equal employer and worker members, at most ten, chair rotating yearly, women adequately represented.
- One year to apply, thirty days for the committee, sixty days to seek conciliation, forty-five days before going to the Tribunal.
- A termination dispute is deemed an industrial dispute even if no union is a party.
- The Central Rules, 2026 cover Central-sphere establishments; State rules apply elsewhere.
Read next
- Section 3: the Works Committee
- Section 14: negotiating union and negotiating council
- Rules 6 to 8: Grievance Redressal Committee under the Central Rules
- Industrial disputes under the new labour codes
Disclaimer: Based on the Industrial Relations Code, 2020 (as enacted) and, where noted, the Industrial Relations (Central) Rules, 2026 (G.S.R. 342(E), 8 May 2026), as on 30 September 2026. The Code is in force from 21 November 2025; some provisions may be notified later, and State Governments make their own rules for establishments where the State is the appropriate Government. Verify the current position before acting.