To the Labour Court

Application No. XYZY of 2023

In The Matter of:
XYZ ……..……claimant
Versus
M/s abc Firestone Tyre and Rubber Company
Through its directors .….…..management
Claim under Section 44(7)(b) Industrial Relation Code 2020:
Most Respectfully Showed
1. That I joined employment of Firestone Tyre and Rubber company as machine operator in
2006 on monthly salary of Rs 8500/- P.M..
2. That I did my duty diligently, regularly and with utmost punctuality, sincerity and with full
devotion of job. No negligence on my part was recorded during the period when I was posted
at various posts .
3. That suddenly on 23th march, I was fired form my job without informing me the reason of
my termination.
4. That when I approached the initial stage of management, they claimed that I was fired on the
basis of Domestic Inquiry findings.
5. That I repeatedly requested higher management for proper reason of my termination and if
there is no proper reason than reappointment of me to my post.
6. That I also served a demand notice for informing me the proper reason of my termination and
if there is no proper reason than reappointment of me to my post but the management did not
oblige.
7. That I am entitled to claim following amount from management.
a. Reappointment of I to my post or a proper reason of my termination
b. Compensation of 20,000 for all the trauma I have been through and for the cost of
attorney
c. An Apology for the inconvenience caused due to the management’s negligence
It is therefore, most respectfully prayed that management be directed to pay amount of
Rs. 20,000/- (including attorney cost + expenses), reappointment of I to my post or a proper reason of
my termination and an apology for the inconvenience caused due to the management’s negligence
Claimant
Through
New Delhi
Dated: 23 January 2023
Advocate
Now after the complaint has been filed these steps will be followed :-
1. Service of summons on defendant
2. Appearance of parties
3. Ex-party Decree
4. Interlocutory Proceedings
5. Filing of written statement by defendant
6. Production of documents by parties (plaintiff and defendant)
7. Examination of parties
8. Discovery and inspection
9. Admission
10. Framing of issues by the court
11. Summoning and Attendance of Witnesses
12. Hearing of suits and Examination of Witnesses
13. Argument
14. Judgement
15. Preparation of Decree
16. Appeal, Review, Revision
17. Execution of Decree