BEFORE THE PRESIDING OFFICER, CGIT CUM LABOUR

COURT-01, ROUSE AVENUE, NEW DELHI

LCA 34 OF 2022

IN THE MATTER OF

MANMOD SHANKAR …Workman/Claimant

VERSUS

LIC OF INDIA …Management/Judgment Debtor

INDEX
S.NO PARTICULARS PAGE NO.
1. Application for Early hearing
on behalf of the Claimant

2. Proof of Service

WORKMAN/ CLAIMANT

THROUGH
NEW DELHI
19.02.2022

Charu Sharma and Tanya Singh

Advocates on behalf of Claimant
Mob. No: +919599515369
Email: Charusharma3637@gmail.com
Tanyasingh8551@gmail.com
 BEFORE THE PRESIDING OFFICER, CGIT CUM LABOUR
COURT-01, ROUSE AVENUE, NEW DELHI

LCA 34 OF 2022

IN THE MATTER OF

MANMOD SHANKAR …Workman/Claimant

VERSUS

LIC OF INDIA …Management/Judgment Debtor

APPLICATION FOR EARLY HEARING ON BEHALF OF THE

CLAIMANT

MOST RESPECTFULLY SHOWETH:

1. That the captioned matter is pending adjudication before

this Hon’ble Court and is next fixed for hearing on
22.04.2022.

2. That the present application is filed by the

Workman/Claimant seeking recovery of the amount due to
him from the Management/ Judgment Debtor. That more
specifically an amount of Rs. 97,000/- along with Pension
and other benefits is due to the Workman/Claimant from
the Management w.e.f. 11.02.2019 to 30.06.2020.

3. That the Workman/Claimant is being unnecessarily

harassed by the Management by not paying him the amount
due to him. That after suffering from the hands of the
management the Workman/Claimant filed an application
 u/s 33C (2) of the industrial Disputes Act, 1947 seeking
recovery of the amount due to him as well as fixed pension
as per the rules of LIC of India.

4. That the contents of the said Application are not repeated

herein for the sake of brevity and prolixity and the same be
treated as part and parcel to the present application.

5. That, however, due to the outbreak of COVID-19 Pandemic

the matter was adjourned en-bloc to 22.04.2022 for filing of
the Written Statement. Furthermore, going by the current
circumstances due to the sudden outbreak of the COVID-19
pandemic, it is absolutely clear that the matter is not likely
to come soon on board.

6. That the Hon’ble Delhi High Court has on various occasions

directed the Management to pay to the Workman/Claimant
his last drawn wages or minimum wages from the date of
passing of the award, however the management has time
and again acted in complete defiance of the order by not
giving the Workman the benefits due to him.

7. That, further it is highlighted that the Workman/Claimant

is a senior citizen and a patient of hernia. The Workman
requires urgent Surgery for the same. However, owing to the
costs related to numerous litigations, financial difficulties in
times of COVID-19 crisis, the Workman is constraint to
delay his surgery which might prove to be fatal to his life.
 Hence, the present application for early hearing is filed by
Petitioner.

8. That the principal of natural justice, equity and good

conscience also dictate that this matter be heard forthwith
since no purpose shall be served in keeping it pending.

9. That keeping in the view above narrated facts and

circumstances, The Workman/Claimant seeks the
indulgence of this Hon’ble Court to dispose of the
Application bearing no. 34 of 2022.

PRAYER

It is, therefore, most respectfully prayed that this Hon’ble Court

may be pleased to: -

(a) allow the said application for early hearing and dispose of
the Application bearing LPA No. 34 of 2022, AND

(b) pass any other or such further order(s) or/and

direction(s) as this Hon’ble Court may deem fit and
proper in the interest of justice.

AND FOR THIS OF KINDNESS THE PETITIONER AS IN DUTY

BOUND SHALL EVER PRAY

WORKMAN/ CLAIMANT

THROUGH
NEW DELHI
19.02.2022

Charu Sharma and Tanya Singh

 Advocates on behalf of Claimant
Mob. No: +919599515369
Email: Charusharma3637@gmail.com
Tanyasingh8551@gmail.com