MEMORANDUM OF SETTLEMENT UNDER SECTION 2 (P) READ

WITH SECTION 18 (1) OF THE INDUSTRIAL DISPUTES ACT, 1947,

READ WITH RULE 62 OF THE INDUSTRIAL DISPUTES (BOMBAY)
RULES, 1957.
NAMES OF THE PARTIES: M/s A & L Apparels Pvt. Ltd.
AND
Mr._____________
(Full name and address)

REPRESENTING THE
COMPANY

Mr. Suresh Pant, Director

REPRESENTING THE
WORKMAN :

Mr. _______________, the Workman himself.

BRIEF BACKGROUND:

The Akhil Bharatiya Kamgar Sanghatana (referred to herein after as

the Union) filed a Complaint (ULP) No. 213 OF 2013 (referred to
herein after as the Complaint) against M/s Sel Print India Private
Limited (referred to herein after as the Company) before the Honble
Industrial Court, Mumbai on alleged behalf of Mr. _______________
(referred to herein after as the Workman). The Workman also raised
a Reference (IDA) No._____of ______ (herein after referred to as the said
Reference) before the Honble 9th Labour Court, Mumbai.
While the said matters were pending adjudication, the workman
approached the Management of the Company and requested the
Company to settle the matter on a monetary basis since the said
workman is not interested in continuing his employment with the
Company.

The

Company,

without

prejudice

to

its

rights

and

contentions and with a view to buy Industrial peace, adopted a

bonafide humanitarian outlook and agreed to settle the matter on a
monetary basis and hence, the parties mutually arrived at an

amicable settlement on the terms and conditions mentioned herein

below:
TERMS AND CONDITIONS

1.

It is expressly agreed by and between the Parties that pursuant

to this Settlement, the said workman shall forthwith tender his
resignation

from

the

Company

without

any

reservation

whatsoever.
2.

It is expressly agreed by and between the Parties that the

Company shall accept the said resignations forthwith and pay
to the workman by way of the present Settlement an amount of
Rs. ________/- (Rupees____________________________) in full and
final settlement of all his legal dues and the said workman shall
accept the same without any reservations whatsoever by way of
full and final settlement of all his claims arising from and/or
incidental to the said Reference as well as the said Complaint
as also in respect of his employment with the Company.

3.

It is expressly agreed by and between the Parties that the

Workman shall simultaneous to this Settlement immediately
present an Application before the Honble Industrial Court,
Mumbai

and

withdrawing

the
his

Honble
name

9th

from

Labour
the

said

Court,

Mumbai

Complaint

and

withdrawing the said Reference.

4.

It is also expressly agreed by and between the parties that in

view of this Settlement reached between the parties, each and
every claim raised by the said workman in the said Complaint

as well as the claim of the said workman pertaining to backwages, leave wages, reinstatement, gratuity etc. or any and
every other claim of any nature whatsoever are wholly and
completely settled, extinguished and abated in toto and are
settled in full and final and no further moneys or amounts of
whatsoever nature are liable to be received by the said workman
from the Company or liable to be paid by the Company to the
said workman.

5.

It is expressly agreed by and between the parties that in view of

this Settlement between the parties, the Workman will not raise
any further dispute or claim of any nature whatsoever against
the Company and/or any of its Officials as regards the said
Reference/the said Complaint or in respect of his employment
with the Company or any other matter whatsoever, before any
Court or Forum or any Authority, whether Judicial, QuasiJudicial or otherwise at any point of time.

MUMBAI
DATED:

MR. _____________
(THE WORKMAN)

WITNESSES:
1.

2.

M/S SEL PRINT INDIA PRIVATE LTD.

(Mr. SURESH PANT, DIRECTOR)

C.C.: 1.

The Secretary,
Industries, Energy and Labour Department,
Mantralaya, Mumbai 400 032.

2.

The Commissioner of Labour,

Kamgar Bhavan, C-20, E Block, BKC,
Bandra (E), Mumbai-400 051

3.

The Deputy Commissioner of Labour, Thane,

Kamgar Bhavan, C-20, E Block, BKC,
Bandra (E), Mumbai-400 051

4.

The Conciliation Officer, Tarapur,

Kamgar Bhavan, C-20, E Block, BKC,