To: The Chairman

State Life Insurance Corporation of Pakistan

Karachi

Through Proper Channel

Subject: “Request to Review the Decision Dated 07-05-2021 Due to Invalid Facts”

Respected Sir,

1. The Corporation in assent to the Sacked Act and Lahore High Court Bench Bahawalpur
orders dated 10-03-2021 reinstated fellow petitioners and promoted them to one grade higher
on 10-06-2021, while on the other hand, I was ousted from my promotion by an amendment
in the date of the Act 12-10-1999 to 31-02-1998 in Paragraph 7 of your order dated 07-05-
2021. (Annex-A)

2. I was disposed of from Act No. XXII 2010 by an inexact depiction of the Act in Para 10,11
and 12 of your order while Section 2f(iii) of the Act thoroughly clarifies:

“ 2(f)(iii): A person who was appointed or reinstated in service of employer during

the period from the 1st day of November 1993 to the 30th day of November 1996 (both days
inclusive) and who was subsequently dismissed or removed or terminated from service
during the period from the 1st day of November, 1996 to the 12th day of October, 1999 (both
days inclusive) or who was intermittently dismissed, removed or terminated from service
from time to time and reinstated through statuesque order or judgment of any tribunal or any
court including the Supreme Court or a High Court or through any administrative order or
through withdrawal of any order conveying dismissal, removal or termination or by any
other way on any date after the first day of November 1996. ”

3. In Para 13, by embracing only my non-qualification years instead of qualification years my

rights were overstepped. In the year 2008, I qualified for promotion for the first time and was
interviewed in 2009 but was not given my deserved seniority marks by defying Supreme
Court orders dated 29-12-2004, which states my service years to be 13 years, and yet the
Corporation created the reason for not even completing four years of service while my junior
fellows were promoted on 30-06-2009. This I’d say is a severe breach of the Apex Court and
High Court. (Annex-B)

4. In Para 14, it is being said that the grievances of mine has been redressed while this proved
to be erroneous because my grievances, which include not being granted my seniority marks
which I was entitled to by the Apex Court and Section 4(h) of the Sacked Act hasn’t been
obeyed, hasn’t been fulfilled or satisfied yet. Section 4(h) is reproduced hereunder:-

“In cases where employer fails to regularize such sacked employee within fifteen
days of the date of application filed by the sacked employee under Section 3, such
sacked employee shall stand regularize with effect from the date of enactment of this
Act, on first working day after fifteen days of the date of the application filed under
Section 3.”
5. In Para 15, my rights were untented because the attributes written in the said para don’t
quite appease the authentic facts as I qualified according to the Board of Director’s approved
criteria in 2008 and was interviewed in 2009 but by disobeying Apex Court Orders dated 29-
12-2004 the Corporation took away my seniority marks which is against the proposition
settled by the law. Further, I qualified in 2009 and 2011 but haven’t called for an interview,
and lastly again qualified in the year 2017 and was interviewed for it in 2018, yet haven’t
been considered for promotion even with abundant seats available till now. (Annex-C)

6. I have been transcribed as Ex-Area Manager in Para 16 and on top of pages 2 to 4, in

addition to that, my date of appointment and termination has also been putted incorrectly,
which clearly reveals that you didn’t passed valid and faithful judgements over my rights in
the speaking order.

7. It is being requested that the Corporation issued a letter dated 06-04-2009 under the
Presidential Ordinance dated 14-02-2009 and Office Memorandum dated 18-02-2009 with
file No. 4/4/2008-D-3 dated 18 February 2009 by the Government of Pakistan that all
employees appointed during the period November 1993 to November 1996 and Sacked
during the period November 1996 to December 1998 were to be reinstated One Grade higher
from their existing Grade. (Annex-D)

8. The Corporation on 01-06-2009 issued a letter enacting the Board of Director’s decision on
the 200th meeting held on 28-04-2009, which was the acquiescence of Fixation of Salary per
month to a Sacked Employee in conformity with the Presidential Ordinance promulgated and
published in Gazette of Pakistan on 14-02-2009. (Annex-E)

9. The Apex court on 05-05-2016 decided with a detail-oriented approach the questions
raised against Area Managers in CP No.405 to 411 of 2016 by quoting Section 2f(i, iv), 2(a),
3, and Regulation 2(c) in compliance with the Sacked Act and State Life Employee (Service)
Regulation 1973 respectively and in addition cleared out the political victimization and poor
performance demur meticulously. The Corporation implemented said order (05-05-2016) on
10-06-2016 by reinstating and upgrading Area Managers to one grade higher. (Annex-F)

10. The Apex Court again rejected the Corporation’s appeal via orders dated 17-12-2020
sustaining the Peshawar High Court orders dated 29-03-2018 through Writ Petition No. 1961-
A/2016, which have been appended to my Wirt Petition No. 695/2017. It also ordered not to
violate Article 25 of the Constitution of the Islamic Republic of Pakistan 1973. (Annex-G)

It is being requested that, keeping in view of the above and Lahore High Court Bhawalpur
Bench, Bahawalpur orders dated 10-03-2021 a faithful and veracious speaking order shall be
passed.

Yours
obediently, 
                        

Riaz Ahmed Shahid 

                                                Area Manager 685
                                                State Life Sahiwal 
                                                M# 0300 7929740
Dated: June, 2021