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 23rd June 2022.
2-
It
is noticeable that respected predecessor of the Learned Counsel for plaintiff
have made objection regarding representation dated 23rd June 2022 of
the defendant on 9th 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 9th February 2023 and 11th January
2024 Is a part of the paper book of the proceeding.
7-
The
defendant had made the representation dated 16th 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
