Contractor has applied for a labour license for 100 labours and he has copy of application - can he start the work?

Hi All, We have manufacturing unit in Navi Mumbai, just to know the opinion on my post - If my contractor has applied for a labour license for 100 labours and he has copy of application, and valid license to be granted from the authority, can he start the work with 100 or less than 100 labours since date of application? Is there any rule/provision as per Contract Labour Act?

Dear Amit,
As far as I know that there is no specific provision in the CLRA Act,1970 or the Rules made thereunder making it mandatory to commence the contract work only after issuance of the licence under the Act. If the work allotted on contract is not a prohibited activity u/s 10 of the Act, I am of the opinion that there can be simultaneous commencement of the work and submission of the licence application by the contractor.

Thank you Sir for your advise.

Yes you may go ahead with the work

Dear Amit,
You can start work with less than 20 workmen till obtaining the licence from the authority. In other case workmen can be engaged without licence after the deadline expired, if at all exist under the rule(deemed issue).
But engagement of labour 20 or more without licence is a violation.