Legal notice can be served to the employer in case the dues of employees are not cleared when the employee resigned or terminated from the services. If the employer acknowledges the amount payable to the employee you can file a Summary recovery suit under Order XXXVII of Code of Civil Procedure for recovery of money. Court fee is applicable in case of summary suit. If the employer does not acknowledge the amount a normal recovery suit can be filed to recover the amount. Format of legal notice demanding amount of dues payable to the employee at the time of resignation or retirement is giving below:
Dated :
REGISTERED AD
To
M/s ___________________ Pvt. Ltd.
Having Registered Office at:
________________
New Delhi
Through its Directors.
SUBJECT : LEGAL NOTICE FOR DEMAND OF A SUM OF Rs. _________/- ONLY ALONG WITH
INTEREST @ 18% P.A. FROM __________ TILL ITS FINAL REALIZATION.
Sir(s)/Madam(s),
Under instructions of my client Shri __________________, S/o ______________, R/o
_______________ and for and on behalf of my said client, I do hereby serve upon
you the following legal notice of demand to the following effects:
1. That my aforesaid client was appointed w.e.f. _____________ as Manager with
Employee ______________ with you the Noticee No. 1 and on annual package (CTC)
of Rs. ______________/-(Twelve _________________ only).
2. That my client was working for and under overall supervision of you the
Noticee No. _ to _, from time to time, who happens to be the Directors of the
Noticee No. 1.
3. That my client has performed all his duties as per the satisfactions to his
superiors and as per responsibilities assigned to him time to time. My client's upto mark performance has earned him recognition in your eyes that you noticees
from time to time awarded my client various promotions and increments and
treated him as a valued manpower asset and at lastly he held the post of AVP
Marketing.
4. That my client remained associated under employment till ____________ and
resigned serving the notice period for he was not being paid his salary
regularly since __________.
5. That my client has also informed for the same and resignation of my client's
service by official email ID dated on __________ to his reporting superior
__________ and Noticee No. 2. Finding it impractical to continue with as you all
noticees were not paying heed to the concerns of my client as he remained unpaid
for the services performed by him. You all noticees kept on minting money from
the hard work of your employees like my client being one of such person and you
all noticees remained defiant and delinquent towards your contractual
obligations to pay to the employees who had been working for you all the
noticees.
6. That my client did his duty diligently, regularly and with utmost
punctuality, sincerity, and with full devotion.
7. It is pertinent to mention here that in terms of appointment letter and
regular appraisal letters my client has not been paid his dues and hence this
legal notice is being served upon to you all the noticees as a ramification
apart from other legal measures that my client may opt for to recover pending
dues standing to his credit.
8. That on _______ a total amount of RS. __________/-was payable by you all
above named noticees but despite __________ being the last working day of my
aforesaid client, you the above named noticee did not clear all the dues of my
client as committed by you all noticees at the time of, but despite repeated
requests made by my aforesaid client you all noticees did not clear the dues
standing to the credit of my client and to the debit of you all noticees being
amount of RS.________/-outstanding and to be recovered from you all noticees.
The break-up of the said amount is as follows:
Salary Arrears for last __ months Rs._______
Special Allowances for last ___ months Rs._______
TDS deducted from Salary, not deposited with Income Tax Rs._______
Bonus & Arrears Rs._______
Gratuity Rs._______
PF Deducted from employee but not deposited with PF Department Rs._______
Leave Encashment Rs._______
Total Amount Rs. ______
9. That my client again and again requested you all above named noticees to
clear all his dues but till date nothing is being paid to him which includes the
amount under the head of salary, gratuity, epf, leave encashment, appraisals,
salary arrears and other heads total of which comes to the tune of RS.
___________/-(_______________ only), hence you all above noticees are liable to
pay the aforesaid amount of RS. __________________/-(__________________ only) to
my aforesaid client along with interest @ 18% per annum w.e.f. ____________ till
its realization.
10. That it is pertinent to mention here that my aforesaid client despite his
numerous follow-ups on emails to collect all his dues but all the staff
including you the Noticee No. _ to _ never bothered to listen to his grievance.
It is further pertinent to mention here that my client again and again requested
you the above named Noticee No. _ to _ to clear all his dues and despite
promises you all above named noticees failed to clear all dues of my aforesaid
client.
11. That despite your assurance, no payment has been made by you to my client
till date.
12. That the said act of illegally withholding the above mentioned amount of RS.
____________/-(Thirty ____________ only) of my aforesaid client had not only
caused the mental pain and agony to my client but also caused a grave financial
loss to him.
Now by virtue of the present legal notice, you are hereby called upon to pay to
my client a sum of RS. _____/- (__________ only) plus interest computed at the
rate of 18% per annum from __________ till its final payment plus Rs.
_________/- towards the cost of the present Legal Notice within 15 days of the
receipt of the notice, failing which I have been clearly instructed by my
aforesaid client to initiate Criminal, Civil and also under provisions of The
Companies Act, 2013 for winding up of Noticee No. 1 proceedings before the
competent court of law against you solely at your costs /risks/consequences
without any further communication to you.
A copy of this Notice is kept intact in my office for record and further
necessary action and you are also advised to keep the copy of the same as safe
as you would be asked to produce in the court.
Thanking you,
Advocate
ENR NO. ________________
Section 138 of Negotiable Instruments Act
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