APPLICATION FOR COMPENSATION BY WORKMAN
To,
(Through Proper Channel)
Subject: Appeal under Rule 23 of CCS (CCA) Rules 1965 against the impugned order passed by the Disciplinary Authority dated ______ (received by the appellant on ______), whereby it has been ordered that ______-_
Sir,
With due respect and humble submissions the appellant begs to submit the following few lines for your kind consideration and necessary actions please.
1. That the appellant joined service in the department in the year _____ as a _____ . Ever since the appellant has been discharging his duties to the entire satisfaction of his superiors with the best of his abilities and the whole service record till now has been unblemished ______.
2. That on _____
3. That a charge sheet was issued to the appellant on _____ to which the appellant filed a detailed reply on ______.
4. That the said impugned order is illegal, arbitrary and non-speaking and deserves to be quashed.
5. That none of the charge against the appellant was proved.
6. That the impugned order _____ issued by the Disciplinary Authority is arbitrary, malafide, illegal, ultra vires, against the Articles 14 and 16 of the Constitution of India, dehors the rules and regulations and against the natural justice.
7. ________
8. That it is submitted that the initiation of the impugned disciplinary proceedings by issuing a charge-sheet levelling charges which were stale and on materials gathered as an afterthought was an action tainted with malice and such proceedings are liable to be quashed as being mala fide and malicious in law.
9. _______That as per the settled principle of law, the alleged misconducts pertaining to the period prior to the promotion of the applicant stands condoned. As such the misconducts in Articles of Charges Nos. ______ cannot be made grounds for punishment of the applicant. The Disciplinary Authority was prejudiced against the applicant and due to malafide intention and for the extraneous reasons has awarded impugned punishments on the applicant.
10. _____That on ______ (Annexure A-______), the applicant was served with charge sheet by the Disciplinary Authority for the following four charges:-
11. ______That the applicant submits that on ______ (Annexure A-_______) the applicant has prayed for copy of ______ mentioned in the Annexure A-III with the Charge Sheet so as to enable the applicant to submit his written statement of defence as sought for by the Disciplinary Authority.
12. ______ That it is against well established principles of law, rules and regulations that the person who happens to be witness cannot be appointed as Presenting Officer and vice versa.
13. ______That the applicant submits that on ______ (Annexure A-______) the applicant made a representation to the Disciplinary Authority with a copy of the same endorsed to and got received on the same date by