Changes In the Leave Policies - combined all the leaves and make it as an Annual Leave - is it OKAY as per the Labour Law or not?

Hi Team, In my current organisation we have made few changes in the Leave. Earlier the leave was segregated in EL, CL and SL.
Now we have combined all the leaves and make it as an Annual Leave (32 Leaves Per Year), apart from the Maternity and Paternity Leave, also we do have separate Holidays (Public and Festival). Out of this 32 leaves, 18 leaves are subjected to carry forward. The only motive is to design the leave in that way to give the freedom to the employees to use the leaves as per their need.
I just wanted to know whether we are following the Indian Labour Law or Not.
Would like your suggestion and recommendation on this, please share the link which justifies that the new policies are acceptable under the Indian Labour Law.
Thank You!

You are on the right track. The move will reduce the clerical work in the organisation. Pass a reasoned order stating that the existing multiple varieties of leave are merged in the annual leave. Hoping that in merging the leaves you have protected the aggregate leave on different counts.

Dear Anjali,
It seems you are from Delhi and to you Delhi Shops and Establishment Act is applicable.
As per this Act you are liable to give 15 days privilege leave and 12 days sickness / casual leave. Total 27 days other than festival holidays.
You are giving more than the Law applicable to you. Therefore there is no issue in merging both the kind of leave in to one. But you have to take care of accumulation limit up to three times of the privilege leave.
It suggested have understanding signed with the employees and then incorporate the change in the policy manual. This is because, matters relating Leave with wages and holidays falls under schedule IV of ID Act for which notice of change is required to be given under section 9A.

I may add,
Consider these also-
1.Whether your estt. & employees are covered under ESI act- study the impact from the applicable provisions of the act point of view.
2.If leave encashment-while in service and/or as a F&F settlement is in vogue, merging CL & SL will have some impact. This is so because CL & SL are not encashable. The upper limit for accumulation may pose some issues as might curtail max days of accumulation.
3.Similarly CL, wherever separately in vogue, generally is not allowed to be combined with when EL/SL is availed.
4.CL is open for credit in advance at the entry level for newly joined. Whereas EL/SL accrues after one year/service rendered. If so, inconvenience to be faced by them has to be addressed.
5.CL is meant for availing at short notice, whereas EL/SL required approval in advance as a rule.
6.Is this proposal welcomed by all. How about amending the SO of your firm?