Monday, March 15, 2010

Labour Amount Recovery Affidavit

In the Court of
In the matter of:
1- _____________

2- _____________
3- ______________
4- ____________

1- M/S _____________, through its
Proprietor Mr. __________________

2- Mr. _________________ contractor
C/o M/S _____________________
Office : ______________________,


It is respectfully submitted as under: -
1- That the respondents No.1 and 2 are a contractor and they have been engaged in the business of taking the contracts of constructing the houses, flats, buildings, bungalows etc.

2- That the claimants have been doing the construction and labour workers with the respondents as per their instructions from time to time for the last several years.

3- That as per the instructions the respondents the claimants did the work at ______________, ______________ and the respondents collected the payment from ________________ and made some amount to the claimants of the work done by them and still an amount of Rs. ___________/- has not been paid by the respondents to the claimant.

4- That the respondents send the claimants to do the construction work at the site of M/s _____________________ and out of the amount collected by the respondents from the said company the respondents gave the less payment of Rs. ___________/- to the claimants. The respondents also sent the claimants to do work at __________________ and an amount of Rs. ____________/- are left out payable by the respondents to the claimants from the payment of work done at _____________.
5- That the total amount to Rs. ______________/- have not been paid by the respondents to the claimant’s up to date for which the claimants have been requesting the respondents to pay the same for the last about _ months.

6- That the claimant requested the respondents to make the balance amount of Rs. _______________/- to them as they are under the financial weakness but the respondents are keeping on avoiding the requests of the claimants on one pretext or the other and finally on_______________ the respondents refused to make the said payment. Now the respondents are threatening to the claimants to face dire consequences if he again approached to the respondents. It seems that the respondents have become dishonest and does not want to make the payment of the outstanding amount/dues to the respondents.

7- That the claimants are entitled to recover from the respondents the above mentioned amount along with interest as prevailing in the market jointly and severally.


It is, therefore, prayed that the application of the applicant may kindly be allowed and amount of outstanding labour charges Rs.____________ may kindly be computed in favour of the applicant and against the respondents in the interest of justice which is fully detailed in attached Annexure “A” and the respondents may kindly be directed to pay the same jointly or severally to the claimant/applicant.


Through A.R.


Verified that the contents of my above application from Para No.1 to 7 are true to best of my knowledge and belief and nothing has been concealed therein.

Verified at _____________ on