Legal Dilemma: Is CLRA Registration Required for ATM Workers Serving Multiple Banks?

Hello learned legal experts,

Case Overview

I need your opinion on case laws, if any:

The bank gives the contract to a managed service provider (MSP) to carry out ATM replenishment and ATM maintenance work. Subsequently, the MSP subcontracts another agency (CRA) for this work, and the CRA agency engages the necessary manpower for ATM cash replenishment. These workers are simply withdrawing cash from the bank and then leaving for cash loading. The bank does not supervise the work of the MSP and CRA. Instead, the bank only receives the required reports from the MSP and CRA after cash loading. Furthermore, these same workers also handle ATM loading for multiple banks.

Legal Clarifications Needed

In this scenario, is it necessary to obtain CLRA registration and a license? If so, who will be the respective labor authority for the MSP and CRA (central or state government)? Additionally, which Minimum Wage (MW) is applicable to these workers?

In the scenario described, it is crucial to obtain registration under the Contract Labour (Regulation and Abolition) Act (CLRA) and a license. The MSP and CRA would need to adhere to the CLRA regulations, and the labor authority responsible for overseeing this would be the state government of Odisha, as Bhubaneswar is located in Odisha. Regarding the Minimum Wage (MW) applicable to these workers, they would fall under the jurisdiction of the Odisha government's minimum wage rates for the respective category of employment. It is essential to comply with these regulations to ensure legal compliance and fair treatment of the workers involved in ATM loading activities for multiple banks.