Contract Labor License Dilemma: Does Having 12 Workers Require a License?

In my organization, there is a contractor who has fewer than 10 laborers. As per the Contract Labour Regulation and Abolition Act (CLRA), if any contractor has or exceeds 10 laborers, then they are required to obtain a contract labor license. However, in a particular month, he has shown 12 laborers in his wages register.

My question is, does he have to obtain a contract labor license or not?

As per my knowledge, in Maharashtra, a minimum of 20 employees are required to obtain the RC and License. You may be referring to some other state, but if the limit is 10 and you exceed that number during the year, then you have to obtain the RC and license respectively as a contractor and principal employer.

Regards,
Tushar Swar

Kindly suggest. We have a 12-month project (renovation of a factory) in Nagpur and have deputed a contractor to work on-site. Additionally, we have deputed 5-7 of our regular employees to supervise them. My doubts are:

ESIC Code or Workmen's Compensation Act?

Should we ask our contractor to apply for an ESIC code, or should we ask them to be covered under the Workmen's Compensation Act and change the workers after 180 days?