Model Representation - 9 Draft regarding charge sheet for disobedience of order book

 One woman PA had been charge-sheeted for disobedience of office book directions and also for the early leaving of office as if her habitual one. The SPM has targeted her and made a complaint purely on union affiliation. The following was the reply given in that situation. This was drafted by Com G.Gurusivam .

Sub : Submission of representation to memo of charges dated ………..issued by SSPOs, ……….. Division in file F-1/Misc-05/………/2022-23 -reg

Ref: SSPOs memo no. F-1/Misc-05/………./2022-23 dated ………

                                                            *****

With reference to SSPOs, ……….. Division memo of charge dated ………. in file F-1/Misc-05/………/2022-23 received by me on ………, I earnestly submit the following as my humble representation for favour of kind consideration.

It is imputed that I have refused to obey office order book dated ……… wherein I have

ordered to look after the duties of Aadhar updation work along with MPCM counter. This is not germane to reality. In ……….. PO MPCM counter is very busy since foot fall of customer is high. I just asked Sub Postmaster, ………. PO to intimate the time to allocate dedicatedly to do Aadhar updation. I did not refuse to work. As per Adhoc Establishment norms circulated vide Directorate no.25-11/2019-PE-I/WS dated 24.05.2019, it takes approximately 15 minutes to do an Aadhar transaction. Ergo, I explained Sub-Postmaster about the difficulty to be faced doing aadhar transaction in the midst of counter work and also this may even invite customer complaints, as they have to wait in the counter and could not render service as per citizen charter norms. To reiterate again, I never refused to obey office order work

On ………., I have been directed to maintain records of VIP articles. I did not deny obeying the orders of Sub-Postmaster dated ………. I intimated Sub-Postmaster that already I have been shouldered with heavy work and attaching maintenance of records of VIP articles additionally will be an additional burden and could not be able to accomplish the work effectively. This does not mean I have not obeyed the orders.

On ………….., it is a fact that I have been stopped and enquired by police personnel. Augmenting I have misplaced the challan given by Police personnel. Mere non production of challan due to misplacement alone could not be taken as imputation of misconduct. Since I have been inquired by police, I could not maintain my state of equilibrium in my mind and my foremost intention at that time is to attend the office at the earliest. As such preserving challan does not comes to mind. Extenuating circumstances that situation in which state of equilibrium of mind could not be maintained, psychological fear when suddenly stopped & inquired by police personnel and the situation prevailed at that time may kindly be taken into consideration.

 On ………. around 1640 hours I have been intimated that my mother in law met with an accident. After hearing the news I was put in a stage of apprehension. You will kindly agree that being a single parent and lady, I have a social obligation to take care of my mother in law. Hence I have left the office at 1645 hours after duly informing my colleague since SPM is not available at that time. After that I conveyed the same to SPM through phone. Hence I left office only with prior approval of Sub-Postmaster. Ipso facto my act of leaving office early is neither willful nor wanton. Hence it could not be concluded as habitual late attender by merely on two occasions, where justified reasons are given. Suffice to add that I have not been reprimanded or cautioned for late attendance never before. This should also be taken into consideration.

I put in …. years of unblemished service and never come across any adverse notice in my career. I may be given a chance to prove my dedication and hard work instead of blemishing my service records. Considering my points of defence in pre-paras, I humbly beseech Erudite SSPOs, to drop the charges framed against me for which act of mercifulness I will ever remain grateful to you sir.