TO,DT.: Date of legal notice
M/S. Company name (LLP) LLP
Through its Founder & CEO / Manager
Office at: Company's office address
LEGAL NOTICE
Dear Sir/Madam,
Under the instructions and authority of my client, Mr. Client's name, residing at Client's address, Delhi-1100Client's pin code digits, I hereby serve this legal notice in respect of your company's blatant failure to fulfil its contractual obligations under the terms of the appointment letter issued to my client. This notice also addresses the unlawful and violent assault committed upon my client by your HR personnel when he sought to claim his legitimate dues. The aforesaid actions have caused my client immense physical and mental distress, for which he is presently undergoing medical evaluation and treatment.
1.That my client joined the company of you the addressee on Date of joining the company as Client's designation, pursuant to the appointment letter issued by your company dated Date of appointment letter. As per the terms of the appointment, my client was entitled to a monthly salary of Rs. Monthly salary with sales (Rs.)/- in the event of sales occurring during the month, and Rs. Monthly salary without sales (Rs.)/- if no sales were achieved. My client duly discharged all his duties diligently and maintained an impeccable work record during his tenure with your company.
2.That despite my client performing his duties in good faith and with utmost sincerity, your company has wilfully failed to honour the contractual obligations set forth in the appointment letter. Specifically, the salary of my client for the month of Unpaid salary month remains unpaid, despite multiple requests and follow-ups with your HR Department. The repeated denial of payment constitutes a clear breach of contract, violating both the letter and the spirit of the terms agreed upon. It is unconscionable that a reputed company such as you the addressee would disregard its fundamental responsibility of remunerating an employee for services rendered.
3.That on Date of assault incident, when my client visited your HR Department to request the release of his pending salary, he was met with hostility by your HR personnel, namely HR personnel's name. Instead of addressing the legitimate concerns raised by my client, HR personnel's name not only refused to release the pending dues but also proceeded to physically assault my client. My client was subjected to a brutal and unlawful beating at the hands of HR personnel's name, resulting in physical injuries, particularly to his head and chest. This appalling incident has caused my client extreme pain and suffering, for which he is now undergoing medical investigations, including Medical investigations undergone, to assess the extent of the damage. This violent act not only amounts to criminal assault under the Indian Penal Code but has also inflicted severe mental trauma upon my client. My client reserves his right to pursue appropriate criminal and civil actions against the individuals responsible for this assault and against the company for its gross misconduct.
In light of the above, you the addressee are hereby called upon to:
a.Immediately release the salary for the month of Unpaid salary month as per the terms of the appointment letter; and
b.Clear all pending dues, including salary, benefits and any other entitlements owed to my client, under a full and final settlement; and
c.Withdraw any false allegations or claims made against my client, which have defamed his character and reputation; and
d.Compensate my client for the physical and mental trauma suffered by him as a result of the assault, including reimbursement of all medical expenses incurred towards the ongoing Medical investigations undergone and treatment of his injuries. It is pertinent to note that the injuries sustained have severely impacted my client's ability to work and to maintain his health, causing further distress and financial strain. My client's pain and suffering must be duly compensated.
You the addressee are required to respond to this legal notice within 15 days of its receipt, failing which my client shall have no alternative but to initiate appropriate legal proceedings against you the addressee, including but not limited to civil actions for recovery of dues and damages, as well as criminal complaints for the assault, at your risk, cost and consequences. Please note that this notice serves as a final opportunity for amicable resolution before the matter is taken to the courts.
Advocate's name and signature
Advocate
To,Dt.: Date of complaint to SHO
The Station House Officer,
Police Station,
Police station address
Sub: Complaint against HR personnel's name (HR) and Company name (LLP) LLP, both at Company's address, for assault, criminal intimidation and false allegations.
Respected Sir/Madam,
I, Complainant's name, son of Sh. Complainant's father's name, residing at Complainant's address, Delhi-Complainant's pin code, am filing this complaint against Mr. HR personnel's name (HR personnel) and the management of Company name (LLP) LLP, located at Company's address, for committing acts of physical assault, criminal intimidation and levelling false allegations against me, thereby causing severe harm to my dignity, livelihood and mental health.
1.That on Date of assault incident, I approached the HR Department of the company to request the release of my pending salary, which was overdue as per my employment contract. Despite my polite inquiries, I was deliberately ignored, delayed and subjected to abuse by HR personnel's name, the HR personnel. He asked me to step outside the office where cameras were not present. There, he slapped me, pushed me and verbally assaulted me by saying, "Threatening words used by HR personnel". This was an attempt to intimidate me and make me feel powerless against him and the company's management.
2.That on the next day, during a discussion regarding salary deductions with HR manager's name, the HR once again unjustly accused me of not following the company's protocols. When I defended my position, HR personnel's name physically assaulted me, punching me Number of punches inflicted on my face and head, this time in full view of the CCTV cameras located within the office premises. The assault caused serious physical injuries, for which I am currently undergoing medical treatment, including Medical investigations undergone.
3.That rather than addressing my grievances or taking disciplinary action against the HR personnel for his violent actions, the management of the company, in collusion with Mr. HR personnel's name, has levelled false and malicious allegations against me by email dated Date of false allegation email. They have falsely accused me of inappropriate behaviour in an attempt to discredit my claims and to protect the company's image.
4.That despite my services and a clean record with the company, they are now attempting to damage my professional reputation by making baseless claims and by pressuring me to retract my complaint. This constitutes a clear abuse of power by the company, which is acting in furtherance of a common intention to cover up the assault and to protect its HR personnel from facing the legal consequences of his criminal actions.
5.That this malicious campaign by the HR and the company has caused me severe physical and mental trauma. As an employee who worked diligently to support both the company and my family, this abuse of power has not only affected my health but has also endangered my livelihood. The company's refusal to release my pending salary has created financial strain on my family. The assault and the subsequent false allegations have tarnished my reputation, putting my entire professional career at risk.
I hereby request your good self to register an FIR against Mr. HR personnel's name for the physical assault, and against the company management for their role in criminal conspiracy and common intention, and to conduct a thorough investigation into the assault, including the retrieval of CCTV footage from the office premises on Date of assault incident as evidence.
Please take action against the company management for attempting to defame and intimidate me with false allegations, thereby further compounding my distress, and ensure that justice is served for the physical, emotional and financial harm caused to me owing to this illegal and unethical conduct of HR personnel's name.
I am ready to cooperate fully and to provide any additional information that may be required, including medical records, witness statements, and documentation relating to my employment as well as the false claims made against me by the company.
Yours sincerely,
(Complainant's name)
Complainant's address