BEFORE THE CONTROLING AUTHORITY UNDER P.G.

ACT,1972- AT NOIDA,
GAUTAM BUDH NAGAR.
PGA case n ! 1" # 2$$9
IN THE MATTER OF %
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M#s C/e*1n I)ea0 P42. L2). ++..+++++++++++++++++O.P.# Mana5e.en2.
,RITTEN &TATEMENT ON BEHALF OF O.P.# MANAGEMENT.
Sir,
It is respectfully submitted as under :-
1. That the contents of /a*a-1 of claim application of the applicant are wrong, baseless,
misconceived, false hence denied. It is submitted that applicant was never employed by the
answering management on alleged date in question of para nor there was any relationship of
master and servant or employer and employee between the aforesaid parties. The applicant be
put to strict proofs.
. That the contents of /a*a-2 of claim application of the applicant are wrong, baseless,
misconceived, false hence denied. The applicant was never employed and nor terminated by
the answering management at any point of time. The applicant be put to strict proofs.
!. That the contents of /a*a-6 of claim application of the applicant are wrong, baseless,
misconceived, false hence denied. It is submitted that it is settled law that those wor"men #he
or she$ completed his %-years service and &' wor"ing days in each year with the management
is entitled to claim (ratuity, but the said applicant was never employed or terminated by the
opposite party and no such application as alleged in the para was ever served upon the
employer)management. *ence the burden of proof is lying on the wor"man to proof his &'
wor"ing days with the management from his date of +oining. The applicant be put to strict
proofs.
&. That the contents of /a*a-7 of claim application of the applicant are totally wrong frivolous
and concocted story. The entire application has been made with ulterior motive to harass and
blac"mail the management ) opposite party. The instant claim application is malicious and
ve,atious and deserves to be dismissed with e,emplary cost.

PRAYER
In view of the above submission, it is prayed that the instant application of the applicant may
"indly be dismissed out rightly and a declaration be made that the applicant is not entitled to any relief
or relief-s as prayed for
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3ERIFICATION%-
.erified on this /ay of ,'1' that the contents of 0ara #1$ to #1$ of the written
statement are true to the best of my "nowledge and beliefs. 2othing material has been concealed there
from.

F*% C/e*1n I)ea0 P42. L2).
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