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The Secretary,
Irrigation & Power Department,




Respected Sir,

With due deference, I submit the following few lines for your
kind & sympathetic consideration.

1. I was appointed as Zilladar against direct quota on 31.7.1982 and

after qualifying the Departmental Zilladari Examination held on
5.10.82 and 6.10.82 and successful completion of civil training was
posted in Muzaffargarh Canal Circle vide order No. 825/A-
II/83/9984/192/69 dated 10.5.1983; and accordingly assumed the
charge on 18.5.1983. Copy of the result statement and orders dated
10.5.1983 are enclosed as Annexes “A & B” respectively.

2. That Mr. Ghulam Farid son of Hafiz Mahmood was also appointed
as candidate Zilladar against direct quota on the same date, but he
failed to qualify the Departmental Zilladari Examination held on
05.10.82 and 6.10.82. He, however, qualified the Zilladari
Examination in second chance on 28.2.83/01.03.83 and resumed
duty on 22.06.83 after more than a month later than me. (Copy of
the result sheet is enclosed as Annex “C & C/1”)

3. After the appointments of applicant and the aforesaid the Ghulam

Farid. The seniority list of Multan Zone as it stood on 01.01.84 was
notified on 17.03.84. The name of the applicant was shown at Serial
No. 76 and that of Mr. Ghulam Farid was at Serial No. 77. As such, I
was rightly declared senior to Mr. Ghulam Farid, likewise, in the
seniority lists issued in the years 1989-1993, 1997, 2000 & 2001 the
above-said position was maintained. (Copy of Seniority Lists are
Annexes “D, E, F, G & H”).

4. That Mr. Ghulam Farid, Zilladar of Multan Irrigation Zone and

Muhammad Akhtar Javed, Zilladar of D.G. Khan Zone requested for
mutual transfer in the year 1994, which was allowed by the Sec.
I & P vide his No. SO(E-II)2-24/94 dated 10.2.1994. (Copy of letter
is Annex “I & I/1”).

5. After transfer, they preferred appeals claiming seniority against each

other on the basis of date of selection and merit, but their appeals
were rejected by the Chief Engineer, Irrigation Multan having no
merits vide letter No. 790/A-II/2000/23073/259/72 dated 10.11.2000
being against the law and facts. Copy of the letter/decision is
attached as Annex “J”. No further appeal or representation was filed
by Mr. Ghulam Farid, Zilladar; as such these orders have attained

6. Again at his own request Ghulam Farid was transferred from Dera
Ghazi Khan Zone to Multan Zone in June 2001, against the said
Muhammad Akhtar Javed transferred to D.G. Khan Zone loosing
their seniority as such even. Reliance is placed on Secretary I & P
No. SO(E-II)2-24/94 dated 15.8.97 and S&GAD No. SOXII
(S&GAD)-2-39/62 dated 7.9.62. (Copies are Annexes “K & L”).

7. Now a fresh final seniority list as stood on 31.12.2001, has been

circulated on 5.6.2002 by the Chief Engineer, Irrigation, Multan,
wherein the name of Ghulam Farid, has been placed at Serial No. 9
and the applicant’s name at Serial No. 10 placing the name of
applicant below Mr. Ghulam Farid ignoring the seniority list already
prepared and confirmed by Chief Engineer, Irrigation, Multan, vide
orders dated 10.11.2000 (photo-copies are attached as Annexes “J &

8. That the proposed Tentative Seniority List is liable to be reviewed

and inter-alia: -

a) That the applicant is senior to Mr. Ghulam Farid who failed to

qualify the prescribed Departmental Examination. The
applicant assumed duty on 18.05.83 whereas Mr. Ghulam
Farid assumed on 22.06.83 after about one month, four days
later than the applicant. The seniority in this case is to be
determined from the date of joining duty after qualifying
requisite examination and successful completion of training as
mentioned in offer of appointment which reads as under: -

“4: From the date of his taking over a Zilladari

Section he will be considered to have been appointed as
an officiating Zilladar”
(Copy attached as Annex “N”).

b) That the applicant continuously served as Zilladar in Multan

Irrigation Zone and his seniority was finally determined on
01.01.84, wherein Ghulam Farid was declared junior to the
applicant and he never challenged his seniority till the year
2000. The appeal of Mr. Ghulam Farid to Chief Engineer
Multan on this issue has already been considered and rejected
on merits as a result of which the said seniority remained
intact from 01.01.84 and onward, both at Multan Zonal and
Provincial level. Which has been changed now in Zonal office
for the unknown reason in violation of Rule 7 of the Punjab
Civil Servants (Appointment & Condition of Service Rules)
Act, 1974 and Advice of S&GAD bearing No SO(E-II)2-
12/95(P) dated 26.10.2001 and also conditions of offer of

c) That the above said Zilladars, again in collusion with each

other managed to get themselves mutually transferred just to
take the benefits of seniority at Multan Zone and thus
maneuvered their transfers into repatriation as against the
interest and policies of the Government. (Copy of Transfer
Order dated 27.6.2001 Annex “O”).
d) That the present final seniority list issued dated 5.6.2002 is
incorrect, unwarranted, against the record and facts as has
been framed on some misconception, incorrect inter-
protection of the instruction contained in circular No.
SOXII(S&GAD)2-39/62, dated 07.09.62 and as well as advice
of S&GAD dated 02.08.2001 issued by the Government of the
Punjab. Moreover, office of the Chief Engineer, Multan, is not
competent to change seniority at this belated stage is intact
since 01.01.84 todate. The office has not taken into
consideration the last important words of the said advice
regarding grant of seniority to the Zilladars which reads as
under: -

“Seniority would be considered from the date of

appointment after successfully completion of training as
per condition laid down in their service rules.”

(Copy of Advice is Annex “P”).

It is, therefore, respectfully prayed that the Seniority of the

applicant may very graciously be reckoned from the date of
appointment, which remained un-disputed in Multan Zone since
31.07.1982 todate.

It is further submitted that the Final Seniority List dated

5.6.2002 issued by the Zonal Office, Multan, may graciously be
ordered to be corrected and the applicant be placed senior to Ghulam
Farid son of Hafiz Mahmood as per final Seniority Lists issued from
01.01.84 of Multan Zone as well as on provincial basis.

It is also requested that the applicant may kindly be provided

an opportunity to be heard in person and oblige.
Yours obediently,
D.A. As Above.
(Muhammad Hussain Gauhar)
Zilladar, Rawan Section,
Multan Canals Division,
The Secretary,
Irrigation & Power Department,




Respected Sir,
The appellant humbly submits as under: -
1. It is regretted to point out that before issuing tentative seniority list
of Zilladars on Punjab basis, the appeal dated 11.6.2002, lodged by
me against the final seniority list of Zilladars of Multan Zone has not
been considered/decided which is requested to be considered in the
light of rules on the subject and decided accordingly.

2. That in the above referred seniority list the dates under Column Date
of appointments has not been cleared as to whether these dates are of
the selection as candidates or are the dates of joining as Zilladar after
completion of successful training. This is the basis for ascertaining
seniority, without which no one will be in a position to raise
objection against seniority of Zilladars of other zones. This fact is
pointed out in respect of Zilladars at Serial No. 39 to 59 whose dates
of selection as candidate Zilladari have been shown as the date of
their appointment, which is against the Service Rules. In this regard,
as well as the clarification made by S&GAD dated 2.8.2001 is very
clear, “that seniority would be considered from the date of
appointment after successfully completion of training as per
conditions laid down in their Service Rules”.

3. That in the above referred seniority list, no separate column has been
assigned for date of selection and date of joining after training,
which creates confusion about the dates of appointment. Factually,
the same (column) should have been divided into two parts showing
dates of selection and dates of joining after successful completion of
required training.
In light of above narration, it is requested that the
following action may kindly be taken before finalization of the
seniority list on Punjab basis: -

(i) Appeals against final seniority lists issued by the Zonal Office
Multan, be disposed of.

(ii) The Column Date of appointment must show the date of

selection as candidate and date of joining as Zilladar after
successful completion of training.

(iii) Service Books of all the Zilladars be called for verification of

actual dates of taking over charge of Zilldari section after
successful completion of training, to provide justice to
aggrieved persons strictly in accordance with service ruels and
instructions issued by S&G.A.D.

4. That the Zilladars at Serial No. 39 to 60 of Bahawalput, Faisalabad,

D.G. Khan and Sargodha Zones may kindly be declared junior to the
appellant in the light of above submissions and Punjab Service
Tribunal decision in Appeal No. 529/93 announced on 7.5.02 (copy
enclosed) specially in respect of Serial No. 60 who passed the
examination later than the appellant i.e. 27.6.83 as notified by Chief
Engineer, Multan, No. A-II/2002/12966/259/72, dated 29.6.02.

It is also requested that the applicant may very

graciously be provided an opportunity to be heard in

Yours obediently,

D.A. as above.

(Muhammad Hussain Gauhar)

Zilladar, Rawan Section,
Multan Canals Division, Multan.