1. That the petitioner having qualification of B.E (Mechanical) was appointed as Terminal Engineer in Pakistan State Oil in the year 1990 on temporary basis and was confirmed in the year 1992 in group VI.
2. That the petitioner has all along been working honestly and has never been awarded any punishment nor was ever even issued any explanation but was always ignored from any further promotion.
3. That due to the above indiscriminating attitude of the authorities the petitioner is drawing 1/3rd salary after completion of 18 years of service after confirmation as compared to the most juniors of the same grade.
4. That in normal course the petitioner would have been promoted to grade III at least, due to his seniority and bright service record but he has been deprived of his right of promotion on one hand and even is not paid at par at least according to the salary table of the organization
5. That record may be checked of promotions since 2000 till date. It will reveal that how their dear once got promoted every year or alternate year. That in PSO seniority is not counted; most juniors are upgraded each and every year thus creating frustration among others who are neglected.
6. That on 23rd October 2009 promotion of 100 management employees was announced, out of which 69 are junior than me, ( List attached, Highlighted with marker are junior than me).
7. That once again I am victimized this year, though I was ranked with 3.02 points in Employee Development Report of F.Y 2008/2009.This was also endorsed by the departmental head General Manager Construction. Point score 3.02 means average employee, but at final stage I was given marginal rank. Due to this, I applead to higher authorities, but my appeal has not been considered till to date. (Copy Attached).
8. That the above circumstances and the attitude of the organization clearly show that the petitioner has been unnecessarily and cruelly victimized due to their liking and disliking.
9. Honorable Sir, I am been victimized since 1996 – 07, till to date justice may kindly be done with me, I may be considered for due promotion in higher group and all differences and benefits may also be given to me of this period.
10. That the petitioner now seeing no other way is knocking the door of justice through your lordship and pray that after calling the record of petitioner service and the record of too juniors working under the same group as of the petitioner order for redressal of the grievance of the petitioner in the interest of justice.
Aijaz Kazi email@example.com
Employee Code 2082
B.No 92 Muslim housing Society
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