Sudarshan Maurya submits representation before assistant labour commissioner regarding two objections for same representation

 

In the court of Assistant Labour Commissioner 

District-Mirzapur, Uttar Pradesh 

Payment of Wages Act, 1936

Case number-P.W./01/2022

Prayer- Regarding the objection made by plaintiff Yakub Ansari through his learned subsequent advocate Mr R.S. Singh on 11 January 2024. Please consider the submissions of the defendant as counter submission.

Short submissions of the defendant are as follows.

1-    This objection has been made by the Learned Counsel for the plaintiff regarding representation of the defendant dated 23^rd June 2022.

2-    It is noticeable that respected predecessor of the Learned Counsel for plaintiff have made objection regarding representation dated 23^rd June 2022 of the defendant on 9^th February 2023.

3-    In view of defendant, learned counsel for plaintiff is only wasting the precious time of the most respected court by submitting repeated objections regarding the representation of the defendant.

4-    Undoubtedly submitted objection can be rectified/modified/amended by the learned Counsel for the plaintiff, but two objections will only create a state of dilemma therefore most respected learned counsel for the plaintiff must avoid it.

5-    Moreover, if the presiding officer of the court deems fit submitting the response of the objection made by the Learned Counsel by the defendant, then the dependant is ready to submit it.

6-    It is submitted before the most respected sir that the copy of the objections made by the most respected predecessor of Learn Counsel and learned Counsel itself for the plaintiff dated 9^th February 2023 and 11^th January 2024 Is a part of the paper book of the proceeding.

7-    The defendant had made the representation dated 16^th march 2023 which prayer is as follows-Prayer- For the appointment of committee to evaluate the losses occurred to the aggrieved respondent because of the dereliction of the plaintiffs. Which is annexed?

to this representation. Vide attached document.

This is a humble request of the defendant to most respected presiding officer to adopt logistic approach in deciding the representation of the defendant. For this, the defendant shall always pray you, Honourable sir.

Date-08/02/2024                                                       O God help me

 

Sudarshan Maurya S/O Brijlal Maurya Mobile number-9455024500,

Address-Sohta Adda, Jangi Road, District-Mirzapur, PIN Code-231001