• Termination in IT Firm

Background:

We are a small Indian proprietorship in Uttar Pradesh. An employee (Noida-based, remote, gross about ₹2 lakh per month) was confirmed after probation and worked on a US client assignment.
We told him the client would end the assignment in 30 days for performance reasons, and gave him a 60-day working notice period.
In the second week of notice he missed a client meeting without approval and was warned in writing. In the third week he missed another without informing anyone, and the client escalated and ended the assignment.
We then terminated him with immediate effect, relying on the offer letter. It says no notice or compensatory salary is payable on termination for “dishonesty, theft, fraud, loss to company, performance, or any violation to work norm policy”.
His final settlement of ₹1.45 lakh was paid. We withheld ₹48,000 until he returned the company laptop. He returned it late and says he will pursue the remaining notice-period salary and the ₹48,000, and has threatened legal action.
Our inspection of the laptop found little damage, personal media and a torrent client. After termination, and after we had told him in writing not to delete data, a personal hard drive was connected for about 45 minutes while about 78 work-related items were deleted.
The offer letter’s arbitration clause lets a director of the company appoint the sole arbitrator, with courts at Noida having exclusive jurisdiction.

Questions:

1. We issued a 60-day working notice and then terminated him three weeks in for misconduct. Is our exposure on the remaining notice-period salary high or low? What evidence do we need?

2. Is the arbitration clause enforceable, given that our director appoints the sole arbitrator? Where would his claim probably be filed?

3. Is it safe to release the withheld ₹48,000 without conditions, and does it weaken or strengthen our position?

4. The laptop inspection found personal use, a torrent client, and deleted work data. Can we claim damages, and how strong is it without proof of what was copied?

Kindly note: please do not post an AI generated answer. Thanks.