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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 Ware-
house 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 Ware-
house 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