To,

The Worthy Regional Police Officer,

Sahiwal.

Trough Proper Channel

Subject: APPEAL AGAINST THE PUNISHMENT OF FINE EQUL

TO HALF MONTH PAY AWARDED BY THE DISTRICT
POLICE OFFICER PAKPATTAN VIDE ORDER NO.
DATED .

Respected sir,

With excellent respects, utmost regards and deepest venerations, I

beg to submit the following few humble submissions for favorable and sympathetic
consideration for which all the aggrieved subordinates look towards your benevolent
hands.
1. Sir, that the appellant recruited in the police department on 08.10.1976 and ever
since his appointment in the department appellant performed his duties quite
efficiently, honestly and to the entire satisfaction of his superiors.
2. That the facts leading to this service appeal are that the appellant was proceeded
against departmentally under the PEEDA ACT, 2006 for the charge that he while
posted at PS Rang Shah Committed the following misconduct by way of show
cause notice:-

3. Sir that the appellant successfully explained his position before the competent
authority during his personal hearing in the orderly Room on 00-00-0000. But it
 was perhaps the bad luck of the appellant that the competent authority did not
positively appreciate the submissions of the appellant and rushed to pass the
impugned order (Copy of impugned order is enclosed)

4. That this is my humble appeal to the appellant authority under the mandatory
provisions of section 16 of the PEEDA ACT read with NEW CIVIL SERVICE
LAWS and various instructions from the head of the department with in
prescribed period of 30 days from the receipt of the impugned orders and
therefore, is well in time.

5. The impugned punishment orders dated 00-00-0000 is illegal, void and arbitrary
against law/ facts, hence the same is liable to be set aside by your honor on the
following amongst other:-

GROUNDS
a. That the impugned order is illegal, ultra vires and contrary to the facts of the
case of the appellant.

b. That while passing the impugned punishment, the competent authority did not
keep in mind the real state of affairs and condemned the appellant for no fault
on his part.

c. Sir, the appellant is innocent in the matter. The real states of affairs are that as
per duty roster

d. That it is now well established law that where allegations are denied and
factual controversy exist, a regular enquiry is indispensable. Denied of such
enquiry amounts to denial of justice. Reliance is placed on 2006 SCMR 605
and 2007 SCMR 192.

e. That while passing the impugned order the punishing authority did not retry
on any solid grounds / evidence rather passed the same in haste without
looking the relevant record.
 f. That the appellant was condemned vide impugned order without any wilfull
default on his part, therefore the same has caused an undue loss to the
appellant in the service career.

g. It is established principle in law that justice shall not only be done but it
should appear to have been done. But this rule was not adhered to in the case
of appellant.

h. The impugned order is against the principles of natural justice/ equity,

therefore it is not good one hence the same is not maintainable in the eyes of
law, rather is liable to be set aside to meet the ends of justice.

In view of above submissions, it is humbly prayed that the instant

appeal may very kindly be accepted, the impugned order No.
dated be set aside in the interst of justice and on
humanitarian grounds.
This humble appellant will be highly thankful for this act of
kindness and shall pray for ever from Almighty Allah for your
good self’s happy / long live. I shall perform my official duties in a
more efficient / vigorous manner.

Personal hearing is also requested, please.

Yours Obedient Servant,

Sub inspector
No.
District Pakpattan
(Sahiwal Range)

Annexures:
As Above.