Consequences of not obtaining or not correctly obtaining Registration Certificate under Section 7 of CLRA and Licences by Contractors under Section 12 of CLRA

Question 1. What are the possible actions by Labour Commissioner on a principle employer who has not obtained Registration Certificate under Section 7 of Contract Labour Act?
Question 2. What are the possible actions by Labour Commissioner on a Contractor for not obtaining license under section 12 of CLRA but are deploying more than 20 Contract Labours?
Question 3. What are the possible actions by Labour Commissioner on a Principle Employer for obtaining a Registration Certificate for 200 CL but engaging 400 CL on a regular basis?

The Principal Employer is 100% liable for Penalties/Penal Actions in respect of Non-Complaince by the or Any Contractor engaged by the Principal Employer under CL ( R& A) Act, beside the Contractor for blatant breach of Legal Provisions.
Kritarth Consulting Pvt Ltd, Bengaluru Office, 26.7.20

The effect of non-compliance of the provisions of registration by the principal employer is of two-fold - first he can be prosecuted u/s 24 of the CLRA Act,1970 by the enforcement officers under the labor commissionerate which may include imprisonment or levy of penalty or with both and the second and the most important consequence is that the entire contract labor would be deemed as the direct employees of the establishment in respect of all employment benefits and all other statutory purposes.
The poster can go through section 23 of the Act regarding the punishment for violation of any licence conditions by the contractor which is also the same like under section 24.

The earlier legal position on the engagement of CL without licence/registration was that the engagement was sham and the contract labour should be regularised. But now only the penalties are attracted.Still it is advised to take registration by PE and engage CL only through contractors with licence.
Varghese Mathew .Tvm
9961266966