To,

The Secretary,
Establishment Division,
Government of Pakistan,
Islamabad,

Subject:- APPEAL .

R/Sir

Being aggrieved with the harsh and unilateral order No.A-

10/94-PRP-2018 passed by the worthy Inspector General, Pakistan Railways
Police as Authorized Officer during disciplinary proceeding against me on
13.11.2018 (Annexure ‘A’). I, Ms. Naseem Ara Panhwar, PSP, presently
posted as Superintendent of Police, Traffic Malir Karachi beg to submit an
appeal against the said order issued to me under Government Servants (E& D)
Rules 1973 in juxta position format for kind consideration which are as under :-

S NO. ALLEGATIONS REPLIES / REMARKS

I. An enquiry committee
formed by the Honorable
Supreme Court of Pakistan
regarding illegal
appointment from the year
2010 to 2015 pointed out the
following basic flaws in its
enquiry report regarding not
completing of mandatory
formalities made by you
being SP/ District Tando
Muhammad Khan.
II. 183 Police Constables were
appointed in district Tando
Muhammad Khan against
General recruitment in the
year 2012
It is not fact that the mandatory formalities
were not completed during the appointment of
Police Constables made in the year 2014-15
(which was period of my posting) by me being
SP Tando Muhammad Khan district. While the
facts are that all mandatory formalities, Rules
and procedure as laid down in Police Rule
1934 on being as a appointing authority were
observed / fulfilled by me.
Allegation / observations already
dropped by the Enquiry Officer.
It is stated that I was not posted as SP Tando
Muhammad Khan district during general
recruitment in the year 2012 hence the period
2012 does not pertain to me.
Allegation / observations already
dropped by the Enquiry Officer and
Authorized Officer also endorsed the same.
III. Application register was
produced by staff SP office
District Tando Muhammad
Khan in which detail of 634
applications is available.
However,, the dates
mentioned in the Register
are for the year 2010 which
shows that applications were
collected much before the
initiation of Recruitment.
IV. Total 191 Police Constables
were appointed against
General recruitment in the
year 2014
The period 2010 does not pertain to me as I
was posted as SP Tando Muhammad Khan
district on 17.5.2014 (Annexure ‘B’).
Allegation / observations already
dropped by the Enquiry Officer and
Authorized Officer also endorsed the same.
Agreed, it is a fact that I was posted as SP
Tando Muhammad Khan on 17.05.2014 as
mentioned in supra para. However, it is
pertinent to point out here that the recruitment
process was initiated well before my posting
as SP Tando Muhammad Khan. I had only
issued offer/ appointment orders to 191
successful candidates, against existing/
available vacancies as mentioned below for the
post of Constable (BPS-05) as the process of
recruitment was already completed by the
committees constituted by my predecessor,
much before my posting as SP TM Khan and
details of the same are as under:-
i. Advertisement made in daily
newspapers dated 15.08.2013
(Annexure “C”)
ii. Committee constituted for the
collection of applications from
candidates from 23.08.2013 to
31.08.2013 vide No. SSC/5771-80
dated 23.08.2013 (Annexure “D)
iii. Committee constituted for the
conduct of Physical test from
15.03.2013 to 19.03.2013 and
verification of documents written test
on 25.03.2014 (Annexure “E”)
The perusal of above mentioned schedules will
indicate that before my posting as SP Tando
Muhammad Khan, the required process/
formalities for the recruitment of Police
Constables were already completed. Thereafter
during my posting as SP Tando Muhammad
Khan on 13.06.2014 a letter vide No. 7526-
32/EB-III/T-7 S&S dated 13.6.2014 was
received from the AIGP/Estt. CPO Sindh
Karachi(Annexure “F”). The contents of the
said letter are as under:-
i. Since the recruitment process of
Constables in Sindh Police is completed. I am
therefore, directed to request that successful
candidates may please be issued offer letter
after completion of all codel formalities from
Monday i.e. 16.06.2014 as per number of seats
available/ allocated.
ii. Character antecedents may be got
verified from all the districts of the concerned
Ranges through Local Police and Special
Branch.
iii. Compliance report in this regard, may
also be sent to this office for perusal of the
competent Authority.
In pursuance of the direction of worthy
IGP Sindh Karachi under his letter number
quoted above. The appointment/offer orders
were issued to candidates those who had
qualified all required tests from the month of
July, 2014 and onwards.
For reference copies of
appointment/offer letter. (Annexure ‘G’)

Allegation / observations already

dropped by the Enquiry Officer and
Authorized Officer also endorsed the same.
V. SP District Tando
Muhammad Khan vide
office letter No.
Estt/6075/2013 dated
31.08.2013 reported that at
the time of advertisement 86
vacancies were available in
District Tando Muhammad
Khan and DIGP Hyderabad
office letter No. Estt:/16058
dated 04.09.2013 reported
that at the time of
advertisement 71 vacancies
were available in District
Tando Muhammad Khan.
In this connection it is stated that the
verification of office record shows and
authenticate that 198 vacancies of Constables
(BPS-05) were available against the
sanctioned strength for year 2014-15 in district
Tando Muhammad Khan. The vacancy
position are as under:-
Vacancies already available 76
in T.M Khan District vide
District Accounts Officer T.M Khan
letter No. DAO/168 dated 12.3.2015
(Vacancies available from the
Month of May, 2014 (Annexure “H”)
Vacancies provided by the IGP Sindh vide
his letter No. 4075-79 /E-III/P-7/S&S
dated 20.3.2014. (Annexure “I”) 100
Vacancies provided by the IGP
Sindh Karachi vide letter No. B-I/
1200 dated 3.6.2015(Annexure “J”) 22
Total vacancies of Constables were. 198
Hence 191 offer letters were issued
against 198 vacant posts of Police Constable in
Tando Muhammad Khan district during the
financial year 2014-15.
Allegation / observations already
dropped by the Enquiry Officer and
Authorized Officer also endorsed the same.
VI. CPO Sindh has allocated
100 new posts of Police
Constables vide letter No.
4075-79/ E-III/T-&S&S
dated 20.03.2014 and DIGP
Hyderabad Range has
further allocated above new
posts of Police Constables in
March 2014, to District
Tando Muhammad Khan.
The approval from
competent authority/
Recruitment committee was
not obtained.
The staff of district Tando
Muhammad Khan showed
reluctance to provide soft
record of the process so that
it is impossible to check
either to process was
accurate or otherwise.
The detail of vacancies of Constables available
in Tando Muhammad Khan district at the time
of appointment is shown in para No. V supra
which clearly shows that no excess
appointment of Police Constable was made in
Tando Muhammad Khan district during the
financial year 2014-15.
Allegation / observations already
dropped by the Enquiry Officer and
Authorized Officer also endorsed the same.
It is stated that in compliance of the directions
of IGP Sindh Karachi which received through
the Office of the AIG Establishment vide his
letter No. Estt/ vide No. 7526-32/EB-III/T-
7/S&S dated 13.06.2014 regarding issuance of
offer orders to the successful candidates who
had completed all required tests for the said
post, is to be treated as the approval of higher
authorities, accordingly the appointment
orders were issued (Annexure “K”) It is
further mentioned here that as provided in
Police Rules 12.1 and The Sindh Civil
Servants (appointment, Promotion & transfer)
Rules 1974 being appointing authority issued
offer/appointment orders. (Annexure L & M)
Allegation / observations already
dropped by the Enquiry Officer and
Authorized Officer also endorsed the same.
It is stated that the matter does not pertain to
me, which is related with the office staff as I
was not posted at SP TM Khan at that time
whereas said process was done by the
concerned staff under the supervision of
former SP Tando Muhammad Khan.
Allegation / observations already
dropped by the Enquiry Officer and
Authorized Officer also endorsed the same.
 Enquiry Officer has reported
that 191 Police Constables
were appointed against the
allocated 100 seats out of
them 62 were having
domicile of district other
than Tando Muhammad
Khan. Most of those 62
appointed candidates have
managed their transfers from
district Tando Muhammad
Khan. Summary which are
as under
S.NO. DISTRICT OF
DOMICILE
NO.OF APPOINTEES
The detail of vacancies against whom appointment
of Constables were made in Tando Muhammad
Khan district is already shown in para V supra. In
this connection I have already mentioned in the
above paras that required process for the
appointment of Constables was completed by my
predecessor SP from 15.08.2013 to 12.04.2014
and after some time in compliance of the
directions of IGP Sindh received through the
Office of the AIG Establishment vide his letter
No. Estt/ vide No. 7526-32/EB-III/T-7/S&S dated
13.06.2014.06.2014 as mentioned in supra paras I
just issued appointment/offer orders to successful
candidates from the month of July, 2014 and
onwards. As regards, appointment of candidates
having domicile of other district in this

Dadu connection, it is pertinent to mention here that I

1 14
Mirpurkhas
was neither informed nor any record of any
2 16 candidate was produced before me regarding
3 Hyderabad 13 possessing / holding domicile of neighboring
4 Khairpur 05 districts or otherwise.
5 SB Abad 02 It is further submitted that copies of all
6 Larkana 04 appointment orders including 62 (later-on
7 Noshera 01 discharged from service) were also sent to all
Feroze concerned officers/highups but none of them
8 Tando 02 pointed out to me that appointment orders of
Allahyar Constables having domicile of neighboring
districts were to be withdrawn or cancelled. But
9 Thatta 01
after the elapse of 02 years they were discharged
10 Matiari 01 from service with effect from 20.03.2016 on the
11 Badin 02 recommendation of Enquiry Committee
12 Sanghar 01 constituted by the honorable Supreme Court in
Total 62 HRC No.16082/2015 dated 13.12.2015 regarding
recruitment / appointment made in the Sindh
Police during the year 2012 to 2015 on the pretext
having domicile of other districts (Annexure
“N”).
Further, the said enquiry The allegations mentioned in this Para are
reveals that some candidates totally false & baseless as the enquiry officer
paid Rs. 03 to 04 Lac for the has also mentioned that these have not been
appointment but this is not substantiated by the documentary evidence/
substantiated by the proof.
documentary evidence or Allegation / observations already dropped
otherwise. by the Enquiry Officer and Authorized
Officer also endorsed the same.
VII. From the perusal of
available record and on the
basis of enquiry, the enquiry
committee recommends as
follows.
The recruitment made in
district Tando Muhammad is
in excess to the number of
vacancies available.
However, the number of
excess recruitment cannot be
ascertained because of non-
availability of verifiable
figures of vacancy available
at the time of recruitment,
62 candidates were
appointed without taking
into consideration the
district of their domicile
which is in violation of the
rule as well as the
instruction issued by CPO.
The committee recommends
that department action
should be initiated against
you and the member of
scrutiny committee
In this regard it is humbly submitted that an
enquiry was conducted by Mr. Khadim Hussain
Bhatti, PSP, Addl: IGP Traffic Sindh Karachi who
had reported that 16 Constables were appointed in
excess in T.M Khan district for which the former
IGP Sindh Karachi had issued explanation to me
and after submission of my reply, the same was
filed vide former IGP Sindh Karachi’s order
No.2587-2607/E.I dated 12.3.2016 (Annexure
‘O’ & P’.) It is further stated that no. excess
appointment was made in Tando Muhammad
Khan district during my period of posting as SP
i.e. 17.5.2014 hence the allegations are not
correct that 15 Police Constables were recruited
by me in excess while 191 Police Constables were
appointed against available 198 posts in Tando
Muhammad Khan as mentioned in supra paras.
Allegation / observations already
dropped by the Enquiry Officer and
Authorized Officer also endorsed the same.
No violation of the Rules had been committed
by me in the process of recruitment of Police
Constables being senior and responsible Police
Officer having awareness of rules and
procedure. It is further stated that as far as
concern of 62 candidates appointed without
taking into consideration of their domicile, the
said exercise had already been done by the
Recruitment / Scrutiny Committees constituted
by the then SP Tando Muhammad Khan well
before my posting as SP Tando Muhammad
Khan. As regards, recommendations of
Enquiry Committee headed by Mr. Sanaullah
Abbasi, former Addl. IGP CPO Sindh issued
enquiry report without hearing me into the
matter is against fundamental Rights and
Justice by not providing any opportunity to
appear before the committee for statement.
 4. Mr. Muhammad Saleem, PSP
(BS-20), DIGP/NH & MP, South
Karachi (Enquiry Officers) after
conducting through enquiry
concluded that:-
“From detail enquiry personal It is stated that the DIG NH & MP, N-5 South
hearing and perusal of record, it Karachi as Enquiry Officer was fully
is concluded that in district convinced / agreed of my version presented to
Tando Muhammad Khan in the him with supporting documents during the
year 2014, 191 Police Constables
course of Departmental Enquiry and after
were appointed against 198
allocated seats. Out of 191 finalizing the same was submitted to the
Constables 62 were having Inspector General Pakistan Railways Police
domicile of district other than (Authorized Officer). Moreover, the Enquiry
Tando Muhammad Khan, which Officer had reported in his findings and
is in violation of the rule as well conclusion that no excess appointment was
as the instructions issued by
made by me and secondly entire process of
CPO. This allegation has been
found correct through the recruitment of Constables in district Tando
recruitment process for 191 Muhammad Khan was completed prior to my
Constables was already posting as SP Tando Muhammad Khan.
completed by the recruitment
committee prior to her posting.
As regards, verification of record/domicile of
However, she followed the same
list and issued appointment 62 out of district candidates, in this connection
orders without any verification of it is stated that the assignment of verification
record of 62 out of district of documents including domicile was the sole
candidates, consequently 62 responsibility of Recruitment Committee
candidates got illegal which was constituted by the then SP Tando
appointment orders in the district.
Muhammad Khan district and the said process
Anyhow, on the recommendation
of enquiry committee constituted was completed before my posting as SP district
on the orders of Honorable Tando Muhammad Khan. (Annexure ‘Q’)
Supreme Court of Pakistan al 62
out of district constables were
discharged from service”

5. Subsequently, Ms. Naseem Yes. Final Show Cause notice was received
Ara Panhwar, PSP (BS-18) (Annexure ‘R’)
was issued Final Show
Cause Notice No. A-10-94
PRP dated 02.11.2018 by
the Authorized Officer to
finally Show Cause Notice
within 07 days from the date
of its receipt.
6. In response the forenamed Yes. Defense reply was submitted
accused Officers submitted (Annexure ‘S’)
defense reply dated 06.11.2018
and requested for personal
hearing to explain her position
personally. She was called by
the undersigned on 12.11.2018
for personal hearing vide letter
No. A-10/94-PRP dated
09.11.2018. However, she
appeared in person on
13.11.2018 and heard by the
undersigned in two sessions:
7. She was given a patient hearing It is quite evident and clear since 191
and record was examined. The candidates had qualified all required tests and
minute examination of record
subsequently declared successful by the
revealed that merit list of 191
candidates did not mean to Recruitment Committee for the post of Police
appoint all of them. Constable as per merit list containing 191
besides on the directions of IGP Sindh
Karachi received through the Office of the
It was the duty of accused AIG Establishment vide his letter No. Estt/
Officer to check the relevant
vide No. 7526-32/EB-III/T-7/S&S dated
documents and then issue
appointment orders after her 13.06.2014 whose appointment orders had to
satisfaction that they belonged to be issued by me to comply with the orders of
the same district, which was higher authorities against existing 198
proved in the said enquiry and vacancies of Police Constables for the
subsequently 62 illegal financial year 2014-15.
appointees were discharged from
As regards, before issuance of offer letters I
service vide Rule 12.21 of Police
Rules 1934 by Mr. Munir Ahmed had to verify record/documents of successful
Shaikh, PSP Sr. Superintendent candidates , in this connection it is stated that
of Police, Tando Muhammad the verification of documents and domicile of
Khan vide order No. SSC/3738- the successful candidates, the said process had
50/2016 dated 20.09.2016 out of already been completed/done by the
which three Constables were re-
Recruitment Committee constituted by the
instated in service in the year
2017 as per directions of then SP Tando Muhammad Khan before my
Honorable Supreme Court of posting as SP Tando Muhammad Khan district
Pakistan. therefore the same exercise was not repeated by me.
Whereas, 198 allocated seats In this connection it is stated that the Enquiry
were erroneous assumption the Officer has conceded/endorsed my version
Enquiry Officers. She presented a regarding availability of 198 posts of Police
letter of CPO, Karachi bearing Constable on the basis of relevant record
No. 4075-79 /E-III/T-7/ S&S
produced before him during the course of
dated 20.03.2014 to the fact that
100 seats of Constables were enquiry and he reported in his findings /
allocated. She also presented a conclusion that no excess appointment was
letter No. DAO/TMK /168/2015 made by me. (Annexure ‘T’)
dated 12.03.2015 of Divisional
Accounts Officer, Tando
 Muhammad Khan regarding
vacancy position. After summing
it comes to 176 vacancies. She
also submitted a letter of her
explanation No. 11459 /E-I dated
17.11.2015 and letter No. 2587-
260 /E-I Karachi dated
12.03.2016 of its withdrawal
about excess recruitment of
Constables than the available
posts which again proved by
letter No. B-1-6300 dated 31st
December 2014 from IGP Sindh
Karachi Office to Home
Secretary, Karachi and Finance
Department, Govt: of Sindh letter
No B&E-II/1-91/2014 dated 16th
March 2015 of creation of posts
in 2015.
Therefore, appointment against
191 posts were excess by 15
appointment. She admitted that
those appointment were found
out of district Tando Muhammad
Khan and it was her mistake. She
also admitted excess appointment
but argued that those were
regularized later. It was argued
by her that she was a lady Officer
and first time posted in district
Tando Muhammad Khan.
Moreover, the recruitment
process was continuous through a
couple of year and she was only
held responsible for these
recruitments, whereas,
negligence of the then
recruitment committee was also
evident.
8. Moreover, letter No. 7526-32
E/EB-III/T-7/S&S dated
13.06.2014 from IGP Sindh
Karachi ordered to issue offer
letters as per the merit list
finalized earlier by the
As regards, 15 excess appointments of Police
Constable in Tando Muhammad Khan district
it is stated that 191 offer letters were issued by
me from the month of July 2014 and onwards
to successful candidates on the basis of merit
list / recommendation prepared and duly
signed by the Recruitment Committee. I
already informed that said process of
recruitment was already completed before my
posting as SP Tando Muhammad Khan and it
was the responsibility of Recruitment
Committee as well as concerned staff that they
should have mentioned in the merit list that
amongst 191 successful candidates the offer
orders may be issued to 176 candidates and
remaining 15 orders to be issued when the
vacancies will be provided / allocated by the
Police department. It shows that that 198 posts
were available against whom offer
appointment orders were issued by me.
I also vehemently denied the charges of any
excess appointment made by me as SP Tando
Muhammad Khan during the financial year
2014-15. Since I have not committed any
mistake as to why should I may admit the
mistake before the Authorized Officer. My
defense reply in the Final Show Cause Notice
which was submitted to the Authorized Officer
may kindly be perused wherein no excuse was
offered by me of any doing mistake in the
process of recruitment.
In this connection it is stated that on the
recommendation and basis of merit list
prepared by Recruitment Committee the
offer/appointment letters were only issued by
me to 191 successful candidates against 198
available/allocated posts of Police Constable
 recruitment committee but it in Tando Muhammad Khan district during the
had to be done as per financial year 2014-15.
availability of allocated
vacancies
 Firstly she should have
verified the domiciles of
candidates on merit list
before issuing appointment
letters and only candidates
belonging to said district
would have been enrolled
 Secondly the issuance of
offer letters should have
been as per availability of
allocated vacancies. She had
to refer back to IGP Sindh
Karachi to seek further
guidance of candidates when
their numbers were in
excess and vacancies were
less. I differ with the
Enquiry Officer that the
number of vacancies were
198 rather it were 176 as per
her version and documents
provided (100 seats were
given vide IGP/ Sindh,
Karachi letter No. 4075-79
E-III/T-7/S&S Karachi
dated 20.0.2014 and 76 as
per district Accounts
Officer, Tando Muhammad
Khan vide letter No.
DAO/TMK/168/2015 dated
12.08.2015 about vacancy
on May2014)
9. Her voluntary admission of
excess appointment is a
grater proof than all other
evidence and ignorance of
law/ Rules is no excuse. So
found guilty on two above
cited points, she is awarded
the penalty of “withholding
It is stated that the said assignment was
already completed by the scrutiny committee
constituted by the then SP Tando Muhammad
Khan hence does not require repetition.
As regards issuance of offer letters to
successful candidates, in this connection it is
mentioned here that on the directions of IGP
Sindh appointment orders/offer letters were
issued to 191 successful candidates who had
completed all codel formalities for the post of
Police Constables against the available 198
vacancies during the year 2014-15 therefore it
was not necessitated to refer back to IGP
Sindh Karachi to seek further guidance once
the guidance of IGP has already been received.
I totally differ with the Authorized Officer that
the number of candidates were excess and
vacancies were less. Vacancy position of
Police Constables were 198 in district Tando
Muhammad Khan the same had been
authenticated / conceded by the Enquiry
Officer (DIG NH & Motorways South
Karachi) in his enquiry report which was
submitted to the Inspector General Pakistan
Railways Police (Authorized Officer).
Sir, neither I voluntary admitted any fault/
omission nor prayed for overlook my mistake
to the Inspector General Pakistan Railways
Police (Authorized Officer) during my
personal hearing, however, I had requested for
provision of fair justice as Senior most officer
having unblemished service career from the
date of joining of Police Service to date. As I
 of promotion for next three had not done any thing wrong in the process of
years”. Orders announced in appointment, that’s why I was expecting after
her presence. submission of relevant record and document to
the Authorized Officer which were
considerably sufficient to prove my innocence
but on the contrary I astonished to receive the
harsh order passed by the Authorized Officer
wherein he had mentioned on his own that I
had voluntary admitted in making excess
appointment which is totally denied by me.

In the prime interest of fair justice, on being

appellate authority, it is humbly requested that harsh and unilateral
order passed by the worthy Inspector General, Pakistan Railways
Police (Authorized Officer) may kindly be vacated as the allegations
leveled against me had not even been substantiated by the DIG NH
& MP, N-5 South Karachi (Enquiry Officer) in his enquiry report
submitted to the Authorized Officer.
It is further requested that I may kindly be given an
opportunity of personal hearing so that I may be able to brief the
facts.
Yours Obediently

(MS. NASEEM ARA PANHWAR) PSP

SUPERINTENDENT OF POLICE (BS-18)
TRAFFIC DISTRICT MALIR KARACHI