If an employee resigns in 24 hours, without serving notice or salary in lieu of it what can HR do to recover the same? Can any legal action be taken?

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KK!HR
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It is not clear whether you are querying for resignation within 24 hours of service. Since no salary is paid, no other dues are created, and the damage done is minimal. Technically and legally, a claim could lie for not serving the notice period, but is it worth it? Getting a decree in your favor and further getting it executed is not all that easy in the Indian scenario.

Maybe treating the matter as a bad dream may be worth it.

From India, Mumbai
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