BEFORE THE ASSISTANT LABOUR COMMISSIONER , AT NOIDA.

C.P. Case No. 11/2009

In !e "ae# o$%&
S!. Nas!'##())'n, S/0& S!. S')'*' A!"e) ++++++++..++++++..,o#*"an/A--.'/an.
0/s.
M/s Han(n1 To2s 3 Te4'.es L). +.+++++++++++++++++O.P./ Mana1e"en.
,RITTEN STATEMENT ON BEHALF OF MANA5EMENT/O.P.
Sir,
It is respectfully submitted as under:-
PRELIMINAR6 OB7ECTION %&
1. That there was no relationship of master and servant or employer and employees between
the applicant and management. The worman was neither employed nor any wor was taen by
the answering management. !ence the instant claim application is not tenable and deserves to
be dismissed out rightly.
ON MERIT%&
"ithout pre#udice to the preliminary ob#ections raised above but fully relying upon the same.
The statements on merit as under:-
1.8a9 That the contents of Pa#a no.18a9 of the statement of claim are wrong, baseless,
misconceived, false hence denied. It is submitted that the worman was not employed
by the aforesaid management nor any wor was ever taen by the answering
management from worman. The worman be put to strict proofs.
1.8:9 That the contents of Pa#a no.18:9 of the statement of claim are wrong, baseless,
misconceived, false hence denied. It is submitted that there was no relationship of
master and servant or employer and employees between the aforesaid parties.
Therefore, the $uestion of terminating the services of the worman on %&.'(.)''( does
not arise. The worman be put to strict proofs.
1.8/9 That the contents of Pa#a no.18/9 of the statement of claim are wrong, baseless,
misconceived, false hence denied. The worman be put to strict proofs.
2. That the contents of Pa#a no.2 of the statement of claim are wrong, baseless,
misconceived, false hence denied. The management had not received any demand
notice alleged to be dated )).'*.)''(. The worman has not come before the +sstt.
,abour -ommissioner with clean hands. The worman has suppressed the material
facts of filling a ..".+. case no./%%(0'( against the answering management.The
worman be put to strict proofs.
;. That the contents of Pa#a no.; of the statement of claim are wrong, baseless,
misconceived, false hence denied for want of nowledge. The worman be put to strict
proofs.
<. That the contents of Pa#a no.< of the statement of claim are wrong, baseless,
misconceived, false hence denied. 1o cause of action arose on )'.'(.)''( as alleged.
The worman be put to strict proofs.
=. That the contents of Pa#a no.= of the statement of claim are wrong, baseless,
misconceived, false hence denied. The worman be put to strict proofs.
>. That the contents of Pa#a no.> of the statement of claim are wrong, baseless,
misconceived, false hence denied. The worman be put to strict proofs.
?. That the contents of Pa#a no.? 3 @ of the statement of claim are wrong, baseless,
misconceived, false hence denied for want nowledge. The worman be put to strict
proofs.
@. That the contents of Pa#a no.@ under the heading prayer clause in the statement of
claim are wrong, baseless, misconceived, false hence denied. Since there was neither
relationship of master and servant or employer and employee nor the services have been
terminated by the answering management on %&.'(.)''( as alleged. The worman is
not entitled to any relief from the answering management and the claim deserves to be
dismissed.
Fo#% M/S Han(n1 To2s 3 Te4'.e L)
Mana1'n1 D'#e/o#
AERIFICATION%&
2erified on this3334ay of3333,)''* that the contents of .ara 5%6 to 5(6 of the written statement are true to
the best of my nowledge and beliefs. The contents of .ara 5%6 under the heading preliminary ob#ection are
believed to be true on the basis of advice tendered to me. 1othing material has been concealed there from.
Fo#% M/S Han(n1 To2s 3 Te4'.e L)
Mana1'n1 D'#e/o#