LEGAL GAPS IN WHISTLEBLOWER PROTECTION WITHIN PRIVATE COMPANIES: A COMPARATIVE STUDY OF INDIA, THE UNITED KINGDOM, AND THE UNITED STATES

AUTHOR – AASHUTOSH AMAN, STUDENT AT AMITY UNIVERSITY

BEST CITATION – AASHUTOSH AMAN, LEGAL GAPS IN WHISTLEBLOWER PROTECTION WITHIN PRIVATE COMPANIES: A COMPARATIVE STUDY OF INDIA, THE UNITED KINGDOM, AND THE UNITED STATES, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 5 (13) OF 2025, PG. 263-267, APIS – 3920 – 0001 & ISSN – 2583-2344.

ABSTRACT

By revealing information about misconduct, corruption, or other unethical practices within companies, whistleblowers contribute significantly to the transparency and accountability of corporate governance. The legal safeguards for whistleblowers, especially those working for private companies, are still insufficient in many jurisdictions. The legal frameworks governing whistleblower protection in the US, UK, and India are compared in this paper, which also identifies important statutory provisions, court rulings, and current legal protection gaps in private companies. The analysis shows that India and the US have serious shortcomings when it comes to providing protection to private sector workers, whereas the UK offers the most comprehensive statutory protection through the Public Interest Disclosure Act 1998. Recommendations for changing whistleblower laws to improve corporate transparency and employee protection worldwide are included in the paper’s conclusion.

KEYWORDS: Whistleblower Protection, Private Sector, Corporate Governance, Public Interest Disclosure Act, Dodd–Frank Act, Corporate Transparency