Defence Statement before Departmental Inquiry

BEFORE THE LEARNED INQUIRY OFFICER, department_name, GOVERNMENT OF government

Inquiry No. _____ of year Under Rule 5 of the Government Servants (Efficiency and Discipline) Rules 1973

In the matter of charge sheet dated charge_sheet_date bearing reference charge_sheet_reference Issued to: officer_name, BPS-officer_bps, officer_designation, posted at officer_posting, holder of CNIC No. officer_cnic

WRITTEN DEFENCE STATEMENT IN REPLY TO CHARGE SHEET

Respectfully submitted:

1. That the undersigned officer has the honour to receive the charge sheet dated charge_sheet_date issued under Rule 5 of the Government Servants (Efficiency and Discipline) Rules 1973, alleging the commission of misconduct / inefficiency under Rule 3 of the said Rules. This written defence statement is submitted within the prescribed period of fourteen days.

2. That the officer has rendered years_of_service years of unblemished and dedicated service to the Government and has, throughout the period of service, conducted himself / herself with integrity and devotion to duty, as borne out by the annual performance evaluation reports and commendations on record.

3. That the charges levelled in the charge sheet, summarised by the officer's understanding as charges_summary, are denied in their entirety. Each charge is responded to specifically as follows.

4. CHARGE NO. 1: charge_1. RESPONSE: This charge is denied. response_to_charge_1. The documentary record relied upon is misread and misappreciated.

5. CHARGE NO. 2: charge_2. RESPONSE: This charge is denied. response_to_charge_2.

6. CHARGE NO. 3: charge_3. RESPONSE: This charge is denied. response_to_charge_3.

7. That the proceedings prior to issuance of the charge sheet were not conducted in accordance with the principles of natural justice and the procedure prescribed by the E&D Rules 1973. procedural_defects.

8. That the officer relies on the following documentary evidence in support of the defence: documentary_evidence_list.

9. That the officer also seeks to examine the following witnesses, whose testimony is necessary for a just adjudication: witness_list.

10. That the action proposed by the Authority is harsh, disproportionate to the alleged conduct, and not commensurate with the principles of proportionality recognised by the superior courts in service matters. mitigating_circumstances.

11. That the officer reserves the right to file additional written submissions, produce further documentary evidence, and lead oral evidence at the appropriate stage of the inquiry, in accordance with the procedure prescribed by the Inquiry Officer.

PRAYER

In light of the foregoing, it is most respectfully prayed that the Honourable Inquiry Officer may be pleased to:

(a) Hold a full and fair inquiry in accordance with the principles of natural justice and the E&D Rules 1973;

(b) Permit the officer to lead oral and documentary evidence in support of the defence and to cross-examine the prosecution witnesses;

(c) Find the officer not guilty of the charges framed against him / her and recommend dropping of the proceedings;

(d) Alternatively, in the event of any finding of guilt, recommend a penalty that is just and commensurate with the conduct alleged; and

(e) Pass any other order that the Honourable Inquiry Officer may consider just and proper in the circumstances.

Yours faithfully, _____________________________ officer_name officer_designation (BPS-officer_bps) Date: ____________