Well Argued · Advocate

Sujata Manohar: the advocacy that left a mark

Updated for 2026 · Claw Editorial

Sujata Vasant Manohar is remembered for a career of firsts that ended at the apex of the Indian judiciary, and for a single judgment that changed how Indian workplaces are supposed to treat women. She was the first woman Chief Justice of both the Bombay and the Kerala High Courts, and the second woman ever appointed to the Supreme Court of India. On that court she sat on the bench that laid down the Vishaka Guidelines on sexual harassment at work. This is an editorial profile for readers who admire the craft, not an endorsement, and not a claim that anyone is available for work.

01The jurist and her era

Sujata Manohar was born on 28 August 1934. She entered the law when a woman on the bench, let alone at the head of a court, was close to unheard of in India. She was elevated to the bench of the Bombay High Court in 1978, one of the earliest women to sit there, and spent a decade and a half building the record that would carry her higher.

Her career ran through a period in which the Supreme Court was rewriting large parts of Indian public law: on fundamental rights, on the duties of the State, and on the dignity of individuals. She came to the apex court near the height of that activity, which gave her the chance to sit on cases whose reasoning still governs everyday life in the country.

A word on what this page is. It is an editorial profile written for readers who admire good advocacy, published by Well Argued, Claw's free publication. It is not legal advice. Justice Manohar is a retired judge, and nothing here presents her as available for any kind of work.

02The barriers she broke

The sequence of her firsts is worth stating carefully, because it is often blurred. She sat as a judge of the Bombay High Court from 1978. In January 1994 she became the Chief Justice of the Bombay High Court, the first woman to hold that office. She was then transferred as Chief Justice of the Kerala High Court the same year, again the first woman to lead that court. In November 1994 she was elevated to the Supreme Court of India, the second woman ever to be appointed to it, after Justice M. Fathima Beevi.

To lead two different High Courts and then join the Supreme Court, all as the first or second woman to do so, is not a run of lucky appointments. It is the result of a body of work that administrators and colleagues could not reasonably pass over. She broke those barriers the way they are most durably broken, by making the alternative, overlooking her, indefensible.

She retired from the Supreme Court on 27 August 1999. Her firsts gave the next generation of women lawyers something concrete to point to: not an argument that it could be done, but a record that it had been.

03The judgment she is known for

Her best-known work is Vishaka v. State of Rajasthan, decided by the Supreme Court in 1997. The case arose from a horrifying attack on a social worker in Rajasthan and from the absence of any law in India that squarely addressed sexual harassment at the workplace. The three-judge bench, which included Justice Manohar alongside Chief Justice J. S. Verma and Justice B. N. Kirpal, held that this gap could not be allowed to stand.

The Court read the right to work with dignity into the fundamental rights to equality and life, drew on India's international commitments, and laid down a set of binding guidelines, the Vishaka Guidelines, to govern workplaces until Parliament legislated. Those guidelines required employers to set up complaints mechanisms and to treat harassment as a workplace wrong. They held the field for more than fifteen years, until Parliament passed dedicated legislation on the subject in 2013.

Vishaka is studied today as a model of how a court can fill a legislative vacuum without overstepping, and the bench she sat on is the reason millions of Indian workplaces have a complaints process at all. It is the clearest single example of her contribution to the profession and to the country.

04The wider body of work

It is easy to reduce a long judicial career to one famous case, but Manohar sat on a wide range of matters across civil, constitutional and family law during her years on the Bombay High Court and the Supreme Court. Her reputation on the bench was for clear reasoning and for treating the dignity of the parties before her as a serious part of the law, not an afterthought to it.

After retiring from the Supreme Court she continued in public service, including as a Member of the National Human Rights Commission, carrying the same concern for individual dignity into a different forum. In later years her contribution has been recognised with honours both in India and abroad, including a medal named for Justice Ruth Bader Ginsburg of the United States Supreme Court.

This is a record of a body of work, not a legal opinion on any current matter. For advice on your own situation, consult a qualified advocate.

05What she gave the profession

Her first gift was the plain fact of her firsts. A woman entering the law today can point to a first woman Chief Justice of a major High Court and a woman on the Supreme Court, and know that the ceiling has already been lifted. That changes ambition before a single brief is argued.

Her second gift was Vishaka, and the principle behind it: that the law exists to protect dignity, and that a court faced with a gap and a genuine wrong can and should act. Generations of law students learn the case not only for its guidelines but for its method of reasoning from first principles.

Her third gift was a standard of judicial temperament, careful, humane and unshowy, that younger judges and advocates still hold up as the ideal. That is the truest recognition a jurist can earn, that the profession keeps learning from the work long after the robes are hung up.

06Related profiles

Justice Manohar belongs to a line of advocates and jurists whose work shaped the profession. Two more profiles in the Well Argued series:

• Niren De, a former Attorney General for India and a formidable courtroom advocate.
• P. P. Rao, a senior advocate known for his constitutional work.

07About Well Argued

Well Argued is a free, curated publication by Claw that gives an advocate a hard-won court victory an audience, turning a winning judgement into a short, well-told story that Claw shares across its social channels, its website and the AI answer engines. A judgment like Vishaka is remembered because it was recorded, argued over and taught. Good advocacy still happens in trial courts and High Courts across India every week, and most of it is never seen beyond the cause list. Recording work that deserves to be seen is exactly what Well Argued exists to do.

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