Ghulam Shabbir
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BEFORE THE HON’BLE PRESIDING OFFICER, PUNJAB LABOUR COURT NO. 9, MULTAN.
Case No. _____________/2000 Ghulam Shabbir Vs. Factory Manager, Ehsan Ilahi Textile Mills (Pct.) Ltd.
WRITTEN STATEMENT ON BEHALF OF RESPONDENT
PRELIMINARY LEGAL OBJECTIONS: 1.
That the petitioner has got no cause of action against respondent, therefore, petition is not maintainable.
2.
That the petitioner has got no locus standie to file present petition.
3.
That the services of the petitioner has not been terminated either verbally or in writing, therefore, petition is not maintainable.
4.
That the petitioner is facing disciplinary action for remaining absent from duty for more than ten days without prior information and permission, therefore, petition is not maintainable.
5.
That the petitioner has not made the company a party, therefore, petition is not maintainable.
ON FACTS: 1.
That the contents of para No. 1 are not disputed except this that the petitioner was employed as “Fitter”.
2.
That the contents of para No. 2 are admitted.
3.
That the contents of para No. 3 are denied being incorrect. The allegation leveled against management is false and totally incorrect.
4.
That the contents of para No. 4 are admitted correct.
5.
That in reply to para No. 5, it is submitted that termination or dismissal of the petitioner has not been carried out till todate. The fact remains that the petitioner remained absent from duty for more than 10 days and Charge Sheet to this effect was issued to the petitioner on 30.8.2000, wherein the petitioner was also directed to report for duty and reply the Charge Sheet, but the petitioner did not turn up to perform his normal duty. The petitioner was also asked vide letter dated 13.9.2000 addressed to Joint Director, Labour Welfare, and copy endorsed to the petitioner to report for duty, but petitioner again did not turn up for performing the duty.
6.
That in reply to para No. 6, it is submitted that termination or dismissal of the petitioner either verbally or in writing has not been carried out, therefore, violation of Standing Order Ordinance, 1968 does not arise at all.
7.
That the contents of para No. 7 are not admitted as correct.
8.
That the contents of para No. 8 are admitted.
9.
That in reply to the para No. 9, it is submitted that since the grievance notice was misconceived, therefore, same was not replied.
10.
That the contents of para No. 10 are not admitted. That the respondents are not at all inimical to the petitioner, and his co-workers. This is totally false allegation against the management. Counter affidavit is attached.Pir
In view of above, it is respectfully prayed that the petition of the petitioner may kindly be dismissed with cost and petitioner be directed to report for duty and face the disciplinary action pending against him in the interest of justice. Humble Respondent Dated: ________
Through: MUHAMMAD AMIN MALIK Advocate High Court, Court,
RIAZ-UL-HASSAN Advocate High
38-Muhammadan Block, District Courts, Multan.
BEFORE THE HON’BLE PRESIDING OFFICER, PUNJAB LABOUR COURT NO. 9, MULTAN.
Case No. _____________/2000 Ghulam Shabbir Vs. Factory Manager, Ehsan Ilahi Textile Mills (Pct.) Ltd.
WRITTEN STATEMENT ON BEHALF OF RESPONDENT
AFFIDAVIT of: Factory Manager, Ehsan Ilahi Textile Mills (Pct.) Ltd. I, the above named deponent do hereby solemnly affirm and declare that the contents of the above Statement are true and correct to the best of my knowledge and belief and nothing has been kept concealed thereto. DEPONENT Verification: Verified on oath at Multan, this _____ day of December 2000 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT
Case No. _____________/2000 Ghulam Shabbir Vs. Factory Manager, Ehsan Ilahi Textile Mills (Pct.) Ltd.
WRITTEN STATEMENT ON BEHALF OF RESPONDENT
PRELIMINARY LEGAL OBJECTIONS: 1.
That the petitioner has got no cause of action against respondent, therefore, petition is not maintainable.
2.
That the petitioner has got no locus standie to file present petition.
3.
That the services of the petitioner has not been terminated either verbally or in writing, therefore, petition is not maintainable.
4.
That the petitioner is facing disciplinary action for remaining absent from duty for more than ten days without prior information and permission, therefore, petition is not maintainable.
5.
That the petitioner has not made the company a party, therefore, petition is not maintainable.
ON FACTS: 1.
That the contents of para No. 1 are not disputed except this that the petitioner was employed as “Fitter”.
2.
That the contents of para No. 2 are admitted.
3.
That the contents of para No. 3 are denied being incorrect. The allegation leveled against management is false and totally incorrect.
4.
That the contents of para No. 4 are admitted correct.
5.
That in reply to para No. 5, it is submitted that termination or dismissal of the petitioner has not been carried out till todate. The fact remains that the petitioner remained absent from duty for more than 10 days and Charge Sheet to this effect was issued to the petitioner on 30.8.2000, wherein the petitioner was also directed to report for duty and reply the Charge Sheet, but the petitioner did not turn up to perform his normal duty. The petitioner was also asked vide letter dated 13.9.2000 addressed to Joint Director, Labour Welfare, and copy endorsed to the petitioner to report for duty, but petitioner again did not turn up for performing the duty.
6.
That in reply to para No. 6, it is submitted that termination or dismissal of the petitioner either verbally or in writing has not been carried out, therefore, violation of Standing Order Ordinance, 1968 does not arise at all.
7.
That the contents of para No. 7 are not admitted as correct.
8.
That the contents of para No. 8 are admitted.
9.
That in reply to the para No. 9, it is submitted that since the grievance notice was misconceived, therefore, same was not replied.
10.
That the contents of para No. 10 are not admitted. That the respondents are not at all inimical to the petitioner, and his co-workers. This is totally false allegation against the management. Counter affidavit is attached.Pir
In view of above, it is respectfully prayed that the petition of the petitioner may kindly be dismissed with cost and petitioner be directed to report for duty and face the disciplinary action pending against him in the interest of justice. Humble Respondent Dated: ________
Through: MUHAMMAD AMIN MALIK Advocate High Court, Court,
RIAZ-UL-HASSAN Advocate High
38-Muhammadan Block, District Courts, Multan.
BEFORE THE HON’BLE PRESIDING OFFICER, PUNJAB LABOUR COURT NO. 9, MULTAN.
Case No. _____________/2000 Ghulam Shabbir Vs. Factory Manager, Ehsan Ilahi Textile Mills (Pct.) Ltd.
WRITTEN STATEMENT ON BEHALF OF RESPONDENT
AFFIDAVIT of: Factory Manager, Ehsan Ilahi Textile Mills (Pct.) Ltd. I, the above named deponent do hereby solemnly affirm and declare that the contents of the above Statement are true and correct to the best of my knowledge and belief and nothing has been kept concealed thereto. DEPONENT Verification: Verified on oath at Multan, this _____ day of December 2000 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT
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