Dear friend,
You have no option or exemption but to follow the Act. While you can reorder the declared paid holidays based on the notified list issued by the NCT Govt., you have no power to curtail types of leave and days from the eligibility criteria prescribed in the Delhi Shops & Estt. Act. Please see the extract on 'Leave':
"22. Leave
(1) Every person employed in an establishment shall be entitled to:
(a) after every twelve months' continuous employment, to privilege leave for a total period of not less than fifteen days;
(b) in every year, to sickness or casual leave for a total period of not less than twelve days;
Provided that
(i) an employee who has completed a period of four months in continuous employment shall be entitled to not less than five days privilege leave for every such completed period; and
(ii) an employee who has completed a period of one month in continuous employment shall be entitled to not less than one day's casual leave for every month.
Provided further that a watchman or caretaker who has completed a period of twelve months in continuous employment and to whom the provisions of Section 8, 10, 11, 13, and 17 do not apply by virtue of an exemption granted under Section 4 shall be entitled to not less than thirty days' privilege leave.
(1A) (i) Privilege leave to which an employee is entitled under clause (a) of sub-section (1) or under any such law, contract, custom, or usage, award, settlement, or agreement as is referred to in section 3, or any part of such leave, if not availed of by such employee, shall be added to the privilege leave in respect of any succeeding period to which he is so entitled. However, the total period of such privilege leave, which may be accumulated by such employee, shall not at any one time exceed three times the period of privilege leave to which he is entitled after every twelve months' employment under that clause or under such law, contract, custom, or usage, award, settlement, or agreement.
(ii) Leave admissible under clause (b) of sub-section (1) shall not be accumulated.
(2) If an employee entitled to leave under clause (a) of sub-section (1) of this section is discharged by his employer before he has been allowed the leave, or if, having applied for and having been refused the leave, he quits his employment before he has been allowed the leave, the employer shall pay him full wages for the period of leave due to him."
Also, read the full Act as attached.......