SALARY NOT PAID BY MINISTRY OF STATISTICS & P.I -I say that in pursuant to an advertisement dated 01.07.2010, published by the Defendant, for filling the posts of Consultants, I applied for the same. In response to the same, I received an offer/letter dated 06.10.2010, along with ‘Terms of Reference for the Consultant’/Agreement’ and ‘Agreement for Engagement as Consultant on Contract Basis’, for joining as Consultant in Infrastructure and Project Monitoring Division (IPMD) of the Defendant. After completing necessary formalities, including signing of the Agreement, I was appointed as Consultant by the Defendant with effect from 07.10.2010, initially for a period of six months, extendable to one year, depending upon my performance and need of the Ministry/Defendant. I was to be paid remuneration @ Rs.45,000.00 per month plus T.A./D.A. and other allowance and benefits as per norms /rules applicable to serving officers in Ministries/Departments. I was also issued an Identity Card, bearing No. 126299. It is pertinent to mention here that as per advertisement dated 01.07.2010, the term of employment was to be initially for the period of one year and this term could be further extended depending upon the performance of the candidate / Plaintiff and need of the Ministry/Defendant.Copies of the said letter dated 06.10.2010 , I say that I performed the duties assigned to me with utmost sincerity, devotion, dedication and efficiency. However, despite all this I was not paid my remuneration in time. My salary for the month of October, 2010 was paid after 08.12.2010 and that too after making a representation/complaint to the Director, Finance, of the Ministry of Statistics & Programme Implementation, New Delhi. However, once again I was not paid salary for the months of December, 2010 and January, 2011 in time. Accordingly, I was once again compelled to make representation dated 31.01.2011 to the Secretary, Ministry of Statistics & Programme Implementation for payment of my salary for the aforesaid months. Because of the aforesaid representations/complaints, I was began to be misbehaved, harassed and humiliated by my Seniors/officials of the Ministry on one pretext or the other and for no fault on my part. All the work done by me was rejected/ cancelled and my Work Reports were also not accepted. I was also subjected to casteist remark and abuses and filthy languages. As I was/is in dire need of work and livelihood to nurture my family and look after my old ailing father, I even tendered an apology to my seniors, though there was no need for the same. All this was done so that I might perform his work smoothly as per the Agreement.That as on the date of filing of an amount of Rs.77,900.00 was due and outstanding against the Defendant. The break up of the said amount is as follows:
Short Payment Rs. 29,191.00
Salary of Notice Period Rs. 45,000.00
Interest @ 10% p.a. from
February , 2011 from till date of filing of suit Rs. 3,709.00

Total Rs. 77,900.00
I say that I have been subjected to harassment, humiliation, mental agony and loss of my valuable time and money on account of non-cooperative behaviour, illegal and unjustified conduct and high handedness on the part of the Defendant and its officials for no fault on the part of the Plaintiff