Mental Health at the Workplace: A Comparative Study of India and the United Kingdom with Special Reference to Women Employees

Rapid technological advancements, changes in flexible work arrangements post-pandemic, and changes in India's work culture, driven by major reforms in labour law, have profoundly impacted the well-being of employees and the contours of industrial relations. The consolidation of labour law through the Safety, Health and Working Conditions Code of 2020 marks a significant moment for the recognition of the rights of all workers, including mental well-being, as an integral part of workplace safety. Despite these progressive advancements, mental health in the workplace continues to receive insufficient political and institutional attention, especially when it comes to female employees, who often navigate the difficult intersection between professional responsibilities and societal expectations. This article provides a critical review of the legislative and regulatory framework governing mental health in the workplace in India, along with the approach adopted in the United Kingdom. Through this comparative perspective, it seeks to assess the effectiveness of the statutory and ethical obligations imposed on employers, the degree of judicial response to mental health issues, and the extent to which international best practices can be harmonized with India's evolving labour law. The study also promotes normative and institutional recommendations to strengthen mental health care in the Indian workplace based on empathy, inclusivity, and sustainable work management.