Subject: – Demand Notice Under Section __ of Industrial Dispute Act 1947.
The following is submitted as under: –
1- That the workman _____________ S/o _____________ R/o ___________________ was appointed to work ______________ aforesaid, designated and posted as _________ on ___________, under the kind control and administration of its proprietor/partnership/private limited namely Shri ______________ above stated, since the appointment till verbal, illegal, unlawful, without assigning any reason and rhyme, arbitraly, against the principal of natural justice, without paying any compensatory amount, notice pay, bonus, gratuity, G.P.F., Salary due from the month _________ as per calculation, without issuing any memo, notice, charge sheet, conducting any enquiry by authorized enquiry officer, any complaint made by any one, on ___________ in evening and in oppose the workman worked continuously with punctuality, honestly as devoted workman towards his duties by discharging and rendering towards the ______________, under the kind control and administration of its proprietor/partnership/private limited .
2- That in starts the salary of workman was fixed to the tune of Rupees ____/- per month and over time extra but increased form time to time hence the salary became ____/- per month. The workman is availing benefit of ______.
3- That in salary register the aforesaid proprietor/partnership/private limited of _____________. has wrongly and illegally recorded Rupees ___________/- per month under pressure, coercion, undue influence to avoid from industrial problems while the salary of the workman is ________/- per month and duly paid till ___________ and further stated financial problem hence not paid the salary from ___________ to ________ and this became a basic reason for the termination of the services of the workman when demanded the total salary amount from _______ to _______ and at this point became angry with the workman by loosing his temperature and verbally stated the services of the workman have been terminated by the order on __________ without issuing any termination letter.
4- That the workman has been threatened for involving in some criminal cases by imposing false allegations and for facing dire consequences if tried to take any action against the proprietor/partnership/private limited before police, authority and court and stated obtaining signature over some blank and written papers at the time of appointment and occasionally without reading over them.
5- That being no notice, memo, charge sheet issued and no enquiry of any sort conducted by any authorized enquiry officer, no complaint never made by any one hence the carrier and character of the workman remained quite satisfactory without any stigma or scar but a devoted, honest and punctual workman by discharging his duties and rendering towards the firm i.e. industry.
6- That you have appointed other workman in place of the workman ____________ hence violated the provision and law of industrial dispute Act.
7- That the services of the work man has been terminated illegally, unlawfully and arbitrary, against the principles of natural justice, without assigning any reason and rhyme hence the workman has full right to be re-instated on his duty with continuity of service and with all benefits of back wages etc. from the date of termination till its re-instate.
It is therefore requested that the workman be re-instated on his duty with continuity of service, with full back wages, with other all benefits from the date of termination i.e. ___________ till its re-instate, in actual previous position like before, in the interest of law and justice.
Otherwise the workman shall be compelled to initiate proceeding against you before the authority i.e. labour-cum-conciallation officer and labour court or court of commissioner which may be competent under the jurisdiction.