REGISTERED A.D.
To, 1.
The Manger Human Resources & Administration/occupier, Pan Pacific (Pvt.) Ltd. 12-M Block, 6 PECHS, KARACHI.
2.
The Chief Executive, Pan Pacific (Pvt.) Ltd. 12-M Block, 6 PECHS, KARACHI.
3.
Abdul Hameed Shah, National Sales Manager, 275-Shamsabad Colony, Multan.
GRIEVANCE NOTICE U/S 25-A OF I.R.O., 1969.
Respected Sir, 1. That I was employed in your establishment as Warehouse Assistant in August, 1994, and I performed my duties to the entire satisfaction of my superiors and nothing adverse is on my service record. 2.
That I am a worker/workman as defined in the Industrial Relations Ordinance, 1969 and West Pakistan Industrial and Commercial Employment (Standing Order) Ordinance, 1968.
3.
That the terms and conditions of applicant/workman are being
governed
under
the
Industrial
Relations
Ordinance, 1969 and Standing Order Ordinance, 1968. 4.
That the applicant’s salary and expenses were with-held with effect from 12.10.2000 and thereafter the applicant was compelled by Abdul Hameed Shah National Sales Manager to resign from service, which the applicant opposed on the grounds that this is against the spirit of law.
5.
That in utter disregard of law, the applicant’s services were dismissed in garb of termination with effect from 30.10.2000. Mandatory requirement of law was not at all fulfilled. The opportunity of hearing was not provided
to
the
applicant.
No
Show
Cause
Notice/Charge Sheet was served to the petitioner. Similarly, no enquiry was held, which was mandatory requirement. 6.
That the termination of the applicant is violative of law, rules of natural justice. When a workman is stigmatized, it is obligatory on the employer to initially issue him Charge Sheet, hold an enquiry, give him chance of personal hearing and thereafter, if found guilty of the charges leveled against him, dismissal or termination is carried out. But in the applicant’s case, nothing has been done.
7.
That the applicant is innocent. He is not at all involved in any matter as alleged in the letter of termination.
8.
That the applicant is jobless since the time of termination dated 30.10.2000.
9.
That I am sending you this grievance notice U/s 25-A of I.R.O. 1969 under registered cover as required under the law. In view of above, it is requested that the applicant may be reinstated into service with back benefits, otherwise, the applicant will take the matter to the Labour Court at your costs and risks. Yours obediently, Rashid Sindhu, Dated: 4.12.2000
REGISTERED A.D.
To, 1.
The Manger Human Resources & Administration/occupie r, Pan Pacific (Pvt.) Ltd. 12-M Block, 6 PECHS, KARACHI.
2.
The Chief Executive, Pan Pacific (Pvt.) Ltd. 12-M Block, 6 PECHS, KARACHI.
3.
Zonal Manger, Pan Pacific (Pvt.) Ltd. D.G. Khan.
4.
Abdul Hameed Shah, National Sales Manager, 275-Shamsabad Colony, Multan.
GRIEVANCE NOTICE U/S 25-A OF I.R.O., 1969.
Respected Sir, 1. That I was employed in your establishment as Warehouse Assistant on. 5.6.1997, and was posted at D.G. Khan Zonal Office. I performed my duties to the entire satisfaction of my superiors and nothing adverse is on my service record. 2.
That I am a worker/workman as defined in the Industrial Relations Ordinance, 1969 and West Pakistan Industrial and Commercial Employment (Standing Order) Ordinance, 1968.
3.
That the terms and conditions of applicant/workman are being
governed
under
the
Industrial
Relations
Ordinance, 1969 and Standing Order Ordinance, 1968. 4.
That the applicant’s salary and expenses were with-held with effect from 12.10.2000 and thereafter the applicant was asked by Mr. Jameel Tabassum, Zonal Manager, D.G. Khan to report for duty at Multan to Abdul Hameed Shah National Sales Manger.
5.
That the applicant reported for duty in the office of Abdul Hameed Shah National Sales Manger. The officer concerned asked the applicant to resign from duty, which applicant opposed on the grounds that it is illegal.
6.
That withholding of salary and compelling the applicant to resign from service is violative and rules of natural justice. The applicant is continuously reporting for duty but the concerned officer is not taking the applicant on duty.
7.
That the applicant is innocent. He is not at all involved in any matter.
8.
That I am sending you this grievance notice U/s 25-A of I.R.O. 1969 under registered cover as required under the law. In view of above, it is requested that the salary of the applicant may kindly be released and applicant may also be permitted to perform his duties, otherwise, the applicant will take the matter to the Labour Court at your costs and risks. Yours obediently, Muhammad Asif Malik Dated: 4.12.2000