Draft a Settlement between an Employer and Employees for Grant of Interim relief to the Employees

MEMORANDUM OF SETTLEMENT

Names of Parties:

Representing of Company :	Representative of Employee :	
1)	1)	
2)	2)	

SHORT RECITAL OF THE CASE

The employees have raised several demands mentioned in their letter dated …….. (Annexed A is the copy of the said letter). 

WHEREAS negotiations were held between the representatives of the parties from time to time but no settlement could be arrived, AND WHEREAS THE employees through their union initiated conciliation

Proceedings before the Conciliation officer but no settlement could be reached since the offer of the Management about the increase in the wages/allowances was not acceptable to the workers.  Finally on the basis of the failure report by the conciliation officer, the Industrial Dispute was referred to the Industrial Tribunal for adjudication.

AND WHEREAS both the parties realize that in view of the nature of the demands and the preliminary objections raised by the Management, the adjudication will take a considerable time and in order to maintain industrial peace and harmony the parties have negotiated and resolved that without prejudice to the respective contentions of the parties, the management will pay Rs ……………..per month in addition to his usual wages Rs…………… / to every employees w.e.f…………….

The parties also agree to abide by the following :

Terms & Conditions

1. The payment of Rs………….. per month as agreed by the management will be paid as interim relief

2. That the payment of Interim relief will be adjustable in the final relief as awarded by the Industrial Tribunal either in the wages or any other allowance.

3. It is agreed by both the parties to file this settlement before the Industrial Tribunal with a request that the Interim relief as agreed to be given by the management will be adjusted in the increase in wages and/or allowances.

IN WITNESS whereof both the parties append their signatures in having accepted the above terms and conditions.

Dated……………..                                                		For & on behalf of Company
                                                               
For & on behalf of Employee

Witnesses
1. ……………….
2. ……………….