Complaint for Unfair Labour Practice

BEFORE THE labour_tribunal, jurisdiction

Complaint No. _____ of year

complainant_name, son/daughter of complainant_father, resident of complainant_address ... Complainant

VERSUS

1. employer_name, employer_status, resident of employer_address ... Respondent 2. official_name, official_designation, Resident of official_address ... Respondent No. 2

COMPLAINT FOR UNFAIR LABOUR PRACTICE

The Complainant respectfully submits:

1. The Complainant is an employee of the Respondent employer, engaged as job_designation.

2. factual_background_of_complaint.

3. unfair_practice_1. detailed_particulars_1 This constitutes unfair_practice_type_1 under statutory_provision_1.

4. unfair_practice_2. detailed_particulars_2 This is unfair_practice_type_2 in violation of statutory_provision_2.

5. The Respondent illegal_conduct_description. Such conduct harmful_impact.

6. unfair_practice_3. detailed_particulars_3 The Respondent's action is wrongfulness_assessment.

7. The Respondent No. 2, in his/her capacity as official_role, involvement_in_unfair_practice.

8. The conduct of the Respondent amounts to unfair_labour_practice_definition as defined under applicable_statute.

9. The Complainant impact_on_complainant. The Complainant has suffered loss_description.

10. The Respondent's conduct is legal_characterization and entitles the Complainant to relief.

That this Honourable Forum has jurisdiction to entertain the present matter under the relevant industrial relations and labour laws applicable to the establishment, and the cause of action has accrued within the territorial jurisdiction of this Honourable Forum.

That the action complained of is in violation of the express and implied terms of employment, the Standing Orders applicable to the establishment, and the relevant Industrial Relations Act framework.

That the Petitioner has approached this Honourable Forum within the period of limitation prescribed by law and at the earliest available opportunity following the accrual of cause of action, and no analogous proceedings are pending before any other forum.

That the action of the Respondent has caused substantial loss, prejudice, and hardship to the Petitioner, and unless the relief sought is granted by this Honourable Forum, the Petitioner shall suffer irreparable injury for which no adequate remedy is available in damages.

PRAYER

It is, therefore, prayed that this Court may be pleased to:

(a) Declare the conduct of the Respondent as unfair labour practice;

(b) Direct the Respondent to cease_or_rectify_conduct;

(c) Award compensation of Rs. compensation_amount for loss_basis;

(d) additional_relief_sought;

(e) Award costs of the proceedings; and

(f) Pass such other order as may be deemed just and proper.

VERIFICATION

Verified on oath at verification_place on this _____ day of _____, year, that the contents of the above complaint are true and correct to the best of my knowledge and belief.

_____________________________ complainant_name Complainnant Date: ______________ Through: _____________________________ counsel_name Advocate