Appeal against a major penalty imposed on a civil servant, pleading violation of the Efficiency & Discipline Rules and denial of a fair hearing.
When to use this draft
Use after a departmental representation has been rejected or ninety days have elapsed without a decision.
Essential contents
- Terms and conditions of service and the applicable rules
- Charge sheet, statement of allegations and inquiry report
- Departmental representation and its fate
- Violation of natural justice and the E&D Rules
- Limitation - thirty days from the impugned order or rejection
Drafting notes
- Denial of the right of cross-examination in the inquiry is the most effective ground.
- Show the representation was filed - the appeal is otherwise premature.
- Attach the inquiry report; refusal to supply it is itself a ground.
Adapt before filing
This is a structural template, not advice on your matter. Facts, dates, valuation, jurisdiction and the prayer must be settled by a lawyer licensed to practise in Pakistan.