Reply to Conciliation Notice — Draft

[Company Letterhead / Name & Address of Employer]

Ref: [HR/CON/____/20__]                              Date: [DD-MM-YYYY]

To,
The Conciliation Officer / Assistant Labour Commissioner,
[Office & Address].

Sub: Reply on behalf of the Management to Conciliation Notice
     No. [____] dated [____] in the dispute between [Union/Workman]
     and [Company] — under Section 12 of the ID Act, 1947.

Ref: Your Notice No. [____] dated [____] fixing conciliation on [Date].

Sir/Madam,

1. The Management is in receipt of the captioned notice initiating
   conciliation proceedings in respect of the demands raised by
   [Name of Union / Shri [Workman]] and submits its reply as under.

2. Preliminary Objections:
   (a) The alleged dispute does not constitute an "industrial dispute"
       within the meaning of Section 2(k) as it is [not espoused by a
       substantial number of workmen / an individual grievance].
   (b) The claimant is [not a "workman" u/s 2(s) being employed in a
       supervisory/managerial capacity drawing wages above the
       threshold].

3. Reply on Merits (demand-wise):
   Demand (i): [state demand] — The Management submits that
       [factual reply and stand].
   Demand (ii): [state demand] — [reply].
   Demand (iii): [state demand] — [reply].

4. The action taken by the Management in respect of [Shri [Workman]]
   was [lawful / bona fide], being [transfer / discharge / disciplinary
   action] carried out after [due enquiry / as per the Standing Orders],
   and no illegality attaches to it.

5. The Management has always been willing to maintain industrial peace
   and is prepared to explore an amicable settlement of genuine grievances
   during conciliation, without prejudice to its rights and contentions.

6. It is therefore prayed that the demands be held to be
   untenable / be resolved amicably as may be assisted by your good office,
   and the Management's authorised representative Shri [Name],
   [Designation] will attend the proceedings on [Date].

Yours faithfully,

For [Company]

____________________
[Name & Designation, Authorised Signatory]

Encl.: (1) Authority letter of representative;
       (2) Copy of Standing Orders / relevant records;
       (3) Copy of enquiry proceedings (if any).