To

The Chief Commissioner-IR,

Inland Revenue Regional Tax Office,
Peshawar.

Through: Proper Channel.

Subject: - REPRESENTATION FOR CONSIDERATION OF PREVIOUS CONTRACT

SERVICE OF THE APPLICANT FOR THE PURPOSE OF PAY
PROTECTION/RE-FIXATION OF PAY, SENIORITY, PENSION AND
GRATUITY IN THE LIGHT OF JUDGMENTS OF AUGUST SUPREME
COURT OF PAKISTAN REPORTED AS 2022 SCMR 77, PLD 2016 SC 534, 2008
SCMR 14 & 1997 SCMR 1477.

Respected Sir,

The Applicant humbly submits as under: -

1. That Applicant was appointed in this esteemed Department as Upper Division Clerk (UDC)
BPS-09 (6200-380-17600) on contract basis on 24.11.2011. Copy of the Appointment Order
bearing No. RTO (Hqrs) Appt. Contract/Admn/1516 Dated 24.11.2011 is enclosed as
Annexure “A”.

2. That since the date of appointment on contract basis, the Applicant was continuously serving
the Department as such and through Office Order No. RTO (Hqrs)/Regularization/ Admn/902
Dated 02.03.2023, his services stood regularized. Copy of the Office Order No. No. RTO
(Hqrs)/Regularization/ Admn/902 Dated 02.03.2023 is enclosed as Annexure “B”.

3. That under service laws, previous contract service of the Applicant w.e.f 24.11.2011 to
01.03.2023 needs to be counted for the purpose of Pay Protection/Re-fixation of pay, Seniority,
Pension and Gratuity, so that his contract service period be accounted for the afore-stated
service and financial benefits.

4. That Applicant humbly beseech for kind consideration of counting of his previous contract
service period w.e.f 24.11.2011 to 01.03.2023 for the purpose of pay protection/re-fixation of
pay, seniority and pensionary benefits, which is his genuine, legal and fundamental right.

5. That not counting of a previous service of the Applicant for the purposes mentioned at Para
No.4 is a denial of financial benefits and recurring liability in the light of PLD 2002 SC 723 &
1996 PLC (C.S) 1224, and shall arise the issue of discrimination because this department has
 already regularized contract employees from the date of initial appointment under the PM
Assistance Package 2014.

6. That the applicant also deserve the same treatment under Article 25 of the Constitution of the
Islamic Republic of Pakistan.

It is, therefore, humbly prayed that previous contract service period of the
Applicant w.e.f 24.11.2011 to 01.03.2023 may please be counted for the subject mentioned
purposes.

Dated:- 14.07.2023 Yours obediently

Umer Iqbal,
UDC (BS-13),
Unit 37, Range-01,
D.I.Khan Zone Regional
Tax Office, Peshawar