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Under instructions and on behalf of my client, (Employee Name), full-time permanent employee, residing at (Employee Address), contactable at (Contact), I hereby issue this Legal Notice to you as under:
1. That my client was appointed by your company as (Designation) vide offer letter dated (Offer Letter Date) and joined duties on (Joining Date). The monthly salary of my client was fixed at Rs.(Amount) per month, payable on or before the 7th day of each month.
2. That my client performed his/her duties diligently, regularly and with complete sincerity and devotion throughout the period of employment, fulfilling all obligations as per the terms of the appointment and the applicable laws governing employment.
3. That despite my client's continued and sincere service, you have failed and neglected to pay the salary of my client for the period from (From Month) to (To Month), amounting to Rs.(Amount). This non-payment is in clear violation of Section 5 of the Payment of Wages Act, 1936, which mandates payment of wages within 7 days of the close of the wage period for establishments employing fewer than 1,000 persons.
4. That my client sent multiple oral and written reminders via email and WhatsApp to your management and HR department requesting payment of the outstanding salary. Despite repeated follow-ups, you have willfully ignored my client's legitimate demands and continued to wrongfully withhold the wages, causing my client severe financial hardship and mental distress.
5. That my client is still employed with the Addressee. The current employment status of (Employee Name) makes the illegal withholding of wages all the more egregious, as it deprives my client of their fundamental means of livelihood.
6. That your aforesaid conduct amounts to a clear and wilful breach of the terms of the employment contract and constitutes an illegal withholding of wages under the Payment of Wages Act, 1936. You are further liable under the provisions of the Shops and Establishments Act applicable to your state, the Industrial Disputes Act, 1947, and the Indian Contract Act, 1872 for breach of contractual obligations.
DEMAND: I, on behalf of my client, hereby call upon you to pay the following amounts within 15 (fifteen) days of receipt of this notice:
a) Unpaid salary (period to period): Rs.(Amount)
e) Interest at 18% per annum from date of default
Grand Total: Rs.(Total Amount) plus applicable interest
7. That in the event you fail to comply with the above demand within the stipulated period, my client shall be constrained — without any further notice to you — to initiate the following proceedings, entirely at your risk, cost and consequence:
a) A complaint before the Labour Commissioner under the Payment of Wages Act, 1936 and the applicable Shops and Establishments Act;
b) A civil recovery suit for the full outstanding amount along with interest and costs before the competent Civil Court at (Jurisdiction);
c) Proceedings before the Labour Court / Industrial Tribunal under the Industrial Disputes Act, 1947;
d) Criminal complaint under applicable provisions of law for willful withholding of wages;
e) Any other legal remedy available under law.
This notice is being served upon you by Registered Post Acknowledgement Due (RPAD). A copy of this notice is retained in the office of the undersigned for record and further necessary action.
This is your last and final opportunity to settle this matter without litigation. Please govern yourself accordingly.