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PRABHAT RANJAN MOHANTYDear S Mahadevan
1. Under the Contract Labour Act two parties are existing one is Principal Employer(owner of the establishment) and the other one is the Contractor (who engages workmen or perform the work on contract).
2. To comply with the act, the principal employer takes registration for engagement of labour or work through contractor.
3. On the basis of the registration, the principal employer issues Form V to contractor for obtaining labour license to engage workmen(20 or 50 as the case may be) under him to perform work.
4. To engage contractor the principal employer issued work order( work & cost details with terms & conditions).
5. Therefore, the Principal employer is least concerned from whom you are taking the manpower supply to perform his allotted work. The PE shall held you responsible for violation of the terms of work order. The subcontractor is your baby than of the principal Employer.
In this case the conduct of your client is right and justified to issue Form V to you instead of your subcontractors.
From India, Mumbai