Written Statement Reply – UNDER PAYMENT OF WAGES ACT

BEFORE _________ THE AUTHORITY UNDER PAYMENT OF WAGES ACT CIRCLE __, _________
_________  VERSUS _________
CLAIM APPLICATION U/s. _________   Of THE PAYMENT OF WAGES ACT ________.
WRITTEN STATEMENT ON BEHALF OF  RESPONDENT
Respectfully Showeth
PRELIMINARY OBJECTIONS:
1-    That there is no relationship between the claimants and the respondent as employer and employee. It is further submitted that _________.
2-    That the present _________.
3-    That the claimants have concealed the actual and true facts as the claimants _________ .
4-    The _________.
5-    That the applicant _________.
6-    That the claimants _________.
7-    That _________.
8-    That the claimants _________.
9-    That the present application _________.
REPLY PARAWISE:
1-    That the contents of the Para NO.1 of the application are _________.
2-    That the contents of Para No.2 of the application are _________.
3-    That the contents of Para No.3 of the application are _________.
4-    That the contents of Para No.3 of the application are _________.
PRAYER:
It is, therefore, prayed that the application of the applicants/claimants may kindly be dismissed awarding suitable costs in favour of the respondent and against the applicants/claimants in the interest of justice.
Respondent
Through A.R.
_________
VERIFICATION:
Verified that the contents of Para No.1 to 8 of the preliminary objection of the written statement are true to best of my knowledge and reply para wise from para No.1 to 4 of the written statement are true to best of my belief.
Verified at _________ on _________
Respondent