We are machine manufacturer , during installation of our machine at customers factory one accident took place due to nigligence of customers machine operator and in this accident customers employee has lost 3 fingers of right hand.
Now customer factory is yet to be established , but according to him he is not liable to pay anything to his employee because that factory is yet to be established.
Further , he demanded certain amount from us on the grounds that our engineer has not given proper instructions to machine operator while installing machine.
Now we are ready to compensate certain amount , but we want to pay off in one shot and we also expect that customer or his employee will not demand anything else than one tome settlement .
Now my queries are ,
1. With whome we should enter into one time settlemet Agreement , with our customer or his employee , as we do not have any direct liability to wards employee as such.
2. If we enter into settlement agreement with employer then how we will ensure that benificiary has been fully compensated and he will not raise any further demand on us.
Please share if you have any draft contract in this repsect