Dear Nidhi,
Though you have raised the query on employee leave, you have not mentioned whether the provisions of the "Factory Act" or the "Shops and Establishment Act" are applicable to your company. You need to follow the provisions of your state, as applicable.
Nevertheless, whether the Factory Act or the Shops and Establishment Act of most states state that an employee is eligible to get a day's paid leave for every 20 days he/she works. Therefore, from the 365 days of the year, when you remove 52 Sundays (or weekly offs) and 10 national and closed holidays, an average employee works for 303 days. When you divide this number by 20, the average employee becomes eligible to get 15 days paid (or earned leave) per annum.
What has been mentioned in the previous paragraph is basic eligibility. The Factory Act or Shops and Establishment Act of a few states go beyond and make provisions for sick leave or casual leave.
However, you have mentioned eligibility for 12 days of leave only. Can you please confirm the basis of your calculation? Providing a draft for the circular is fine; however, the circular has to be within the confines of the law and not outside it.
Thanks,
Dinesh Divekar