Before the Hon’ble Chairman, National Industrial Relation

Commission, Islamabad.

Case No. 18 (1)/2000

Kot Addu Power Company

Vs.
Al-Takbeer KAPCO Labour Union,
Kot Addu Power Company and others.

WRITTEN ARGUMENTS

Respectfully Sheweth: -
1. That prior to privatization, WAPDA used to pay generation
allowance to those employees who were directly connected
with generation. The rate at which these employees were paid
generation allowance was as under: -
a) Upto 7 years service 50% of pay
b) 7 to 14 years service 55% of pay
c) 14 years and above 6-% of pay
2. That non-generation employees were paid hardship allowance
in lieu of generation allowance at the rate mentioned below: -
a) BPS 1 to 7 Rs. 75/- per month
b) BPS 8 to 10 Rs. 100/- per month
c) BPS 11 to 16 Rs. 150/- per month
3. That on execution of Staff Agreement, generation and non-
generation employees were treated at par and were given
generation allowance. It is pertinent to mention here that non-
generation employees after privatization started receiving
generation allowance which is more than hardship allowance.
This was actually done to keep both the categories of
employees at par, photo-copy of agreement attached.
4. That on 15.5.1997, an agreement was executed in which
certain monetary benefits were given to employees on the
demand of CBA, copies which were endorsed to various
 Govt. functionaries. In the same agreement working days and
working hours were also agreed upon in para 5 of agreement
which is as under: -
Working days and working hours: -
Consequent upon declaring Sunday as holiday and Friday as
half working day, following office timings were agreed
enabling to have 42 hours per week for day worker: -
Start Finish Lunch/prayer break
Monday—Thursday 0800 1600 1300—1330
Friday 0800 1230 No break
Saturday 0800 1600 1300—1330

5. That another agreement was executed on 15.9.1997 between

Management and CBA Union before the Conciliator and one
of the demands of the CBA was: -
“Demand No. 2—50 per cent technical allowance to Technical
employees.”
STATEMENT: -
The Management is already paying generation
allowance to all workers irrespective of technical or non-
technical employees, but in the present case, only technical
staff will gent technical allowance from grade 1 to 10 Rs.
300/- per month, grade 11 to 15 Rs. 400/- per month and grade
16 Rs. 500/- per month. However, technical staff will be
defined only those directly connected with generation and as
per WAPDA previous practice.

In view of the above, it is therefore, prayed that

petition may kindly be accepted as the non-generation
staff does not does not stand entitled for hardship
allowance as they have been given generation
allowance.

Dated: 4.2.2002

Through: -
RIAZ-UL-HASSAN
Advocate