Service Appeal (Federal)

IN THE FEDERAL SERVICE TRIBUNAL, ISLAMABAD

Service Appeal No. _____ of year

appellant_name (Federal Civil Servant, employee_grade, ministry_or_department) APPELLANT VERSUS respondent_designation, ministry_or_department AND The Federal Government of Pakistan through the Ministry of relevant_ministry RESPONDENTS

SERVICE APPEAL AGAINST ORDER ON TERMS AND CONDITIONS OF SERVICE

Subject: Service Appeal against the impugned order dated impugned_order_date on terms and conditions of service

Appellant: appellant_name Employee Grade: employee_grade Service: service_name Ministry/Department: ministry_or_department Date of Impugned Order: impugned_order_date

Respectfully submitted:

1. The Appellant files this Service Appeal under Section 4 of the Service Tribunals Act 1973 (Federal) against the impugned order dated impugned_order_date, which pertains to order_subject_matter and is alleged to be unlawful and in violation of the Appellant's constitutional and statutory rights.

2. The Appellant is a federal civil servant, presently holding the position of current_position in employee_grade of service_name in ministry_or_department, with years_of_service years of continuous service. The Appellant has an unblemished record of service and has performed all duties with diligence and integrity.

3. The impugned order was issued by issuing_authority_name, issuing_authority_designation, on impugned_order_date. The order pertains to order_subject_matter and directly affects the terms and conditions of the Appellant's service.

4. The Appellant submits that the impugned order is unlawful for the following reasons: grounds_of_appeal

5. The impugned order violates the statutory provisions of relevant_statutes_and_rules, which govern the terms and conditions of service for federal civil servants.

6. The Appellant has exhausted all remedies available under departmental procedures and has made representations to appellate_authority_name, appellate_authority_designation, but to no avail.

7. The impugned order causes irreparable prejudice to the Appellant's career, service record, and financial interests. The Appellant is entitled to relief under the Federal Service Tribunal's jurisdiction.

8. A certified copy of the impugned order dated impugned_order_date is attached as Annexure-A. Copies of all relevant departmental correspondence, service record documents, and supporting evidence are annexed hereto.

9. The Appellant is available for hearing and will present oral submissions as may be required by the Tribunal.

LIMITATION: The present appeal is filed within the period of limitation prescribed by the parent statute, computed from the date of communication of the impugned order to the appellant. The certified copy of the impugned order has been obtained and is annexed.

PRAYER

(a) Set aside the impugned order dated impugned_order_date as unlawful and unconstitutional; (b) Declare the order to be declaration_relief; (c) Restore the Appellant to restoration_relief; (d) Award back-wages and all consequential benefits from effective_date onwards; (e) Grant any other relief deemed just and proper in the circumstances of the case.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of this Appeal are true and correct to the best of my knowledge and belief.

_____________________________ appellant_name Appellant Through: _____________________________ counsel_name Counsel for the Appellant