The follow-up response of our learned brother Mr.Nataraajhan and his arguments advanced therein favouring a single contractor's licence by means of amendments to an existing licence in respect of multiple contract works subsequently undertaken by the same contractor under the same principal employer within the same premises add piquancy to the discussion. His personal experience in this regard as a contractor under the CLRA Act,1970 across the Southern States is taken due notice of. Of course, perceptions differ among the authorities who enforce the Act and so do procedures to the extent accordingly. Yet, what is more appropriate has to be decided based on the principle underlying every such rule relating to procedure only rather than surmises based on the ease of compliance.
Amendment of an existing licence is provided for u/s 14(2) of the Act r.w rule 28 of the Central Rules,1971 as observed by our friend. In this context, I think, what could be an amendment to an existing licence is a pertinent issue. Since the licence is non-transferable, there can not be an amendment in regard to the licencee or the PE. Since, renewal of the licence is also provided for in case of extension of the contract work beyond the period already stipulated, no possibility of any amendment in this regard too. Therefore, what could be amended in respect of a contractor's licence already granted, if at all, are (1) any additional work similar to or in extension of the work already mentioned or (2) any upward revision in the total no. of contract labor to be employed or (3) any change in the name and address of the Agent or Manager of the Contractor.
Therefore, my own experience as a Licensing Officer for about 8 years and a Registering Officer for about 12 years under the CLRA Act,1970 prompts me to state with due respect to a seasoned contractor like Mr.Nataraajhan and the learned officers mentioned by him in his reply that a single licence for the already licensed contractor in respect of subsequent different nature of contract works with similar or different duration under the same principal employer by means of time-to-time amendments is not a correct procedure either on the part of the contractor or the licensing officer.