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Wednesday, February 05, 2014

LIC AFFIDAVIT OF 1-2-2014 & SUBMISSIONS FOR EPIC 6-2-2014.


1.  Hon SJ Rajasthan HC Bhandai’s Order dt 12/1/2010: “In the light of the discussions made above, both the writ petitions are allowed.----------------------------------------------------------------------------------so that every retired employee can get the same benefit.”

i) Due stress & importance has to be made on 6/2/2014  about Hon SJ order dt 12/1/2010 that BOTH THE WRIT PETITIONS  ARE ALLOWED, meaning thereby 6676/1998 on DR & 654/2007 on Pension Upgradation

ii) Also every retired employee can get the  SAME BENEFIT means, not only DR, as then SAME BENEFIT will be deprived, it will be far lesser amount,but also Pension Upgradation with successive wage revisions, as then only every retired employee can hope to get near SAME BENEFIT reasonably.        
                
This matter has been delineated by learned Hon SJ with examples & adduced reason to remedy & rectify the anamolies  with an extension of Respondents Board Resolution dt 24/11/2001  as, with passage of time and while filing CWP654/2007 subsequent wage revisions fell due & those employees/retirees got due uplift in pension denying the altered pension substituting new scales of pay being  denied to existing pensioners still struggling with low basic pension, unaltered for 20 years & more.

2.  Hon JS. Chauhan order dt 22/1/2014: “One of the directions given by the Hon SC is that the Corporation shall deposit the pensionary benefit amount, which is due to the petitioners.”

i) Here also, the pensionary benefit applies to mainly Pension with attendant DR.

ii)  Here it is eminently desirable to quote Hon SC Bench order dt 17/10/2012 on their earlier order dt 14/11/2011,  -- within 8 weeks from today,the petitioner shall deposit in the Registry of the HC the amount due to the pensioners  ie the writ petitioners wef the date of their eligibility to get retiral benefits ”.  This refers to the DATE OF Retirement only.

Respondent, however ,never calculated any amount from date of retirement, confined to DR aspect only & there also with many aberrations, & also eliminated from consideration post-8/1997 pensioners ,thus defying & denying due benefit to all classes of pensioners without  classification. Thus, undertaking given to fulfil  SC orders was not adhered to by distorting & misinterpreting the Judgement to suit  their own erroneous interpretation &  narrowly circumscribing solution to DR factor only without realizing the true intent & purpose of the impartial verdict  offering solution to pensioners woes as delineated in both the writs.

Further, it becomes clear that DR only interpretation is absurd & even nonsensical as HON SJ Rajasthan HC  has admitted both the writs CWP 6676/1998 & 654/2007 on pension upgradation.

iii) This becomes necessary to click the EFFECTIVE DATE as otherwise, LIC will  refer to Prospective date only,mentioned in Board Resolution,which has to be rebutted. What petitioner humbly & respectfully is  pleading is that Respondent should now give correct & unbiassed  acceptance & implementation of the twin benefits delineated by Hon SJ HC  from effective dates when discrimination arose, viz 1/8/1997 for pre-8/1997 pensioners, now getting 50% of DR only ,at Full rate of DR as is being paid for post 8/1997 pensioners regularly  & pension revision either from 1/12/2001 immediately after Board Resolution or   from the date of the CWP 654/2007 of Applicant from 1/2 /2007 with correct merger of full DR with basic pension with successive wage revisions of  1997, 2002 & 2007  & after subsequent wage revisions, as & when it takes place.

iv) Further, much more time has to be spent in litigation to derive full benefit of the meaning & substance of the Judgement  in a holistic way,rather than bits & pieces.DB Rajasthan HC mentioned that LIC Board Resolution has become the property of the HC & so ,keeping quiet for 10 yrs then means approval of the same by LIC/UOI

3.  Here we must readily have & quote succinct PARAS of Hon SJ judgement driving home, terrible anamolies, several cadres below get more pension, date of retirement is irrelevant & so new scales of pay have to be substituted to arrive at SAME PENSIONARY BENEFIT.

When Respondent has not paid a single paisa towards pension upgradation for which alone this CCP 760/2010 was filed,it becomes crystal clear that it is direct violation of Hon SJ judgement dt 12/1/2010 admitting both the writs.This Hon Court must, therefore, straightaway dismiss this reply as of no consequence& not befitting an institution which must honourably fulfil in entirety the  full & complete orders of Hon SJ.

Doing something slipshod & trying to prove the wrong direction in which Respondent is proceeding without any rectification or correction in its course clearly points out the absurdity of their intentions, with only one main aim to thwart the Hon SJ verdict & deny due benefits allowed by Hon SJ in his Judgement dt 12/1/2010.
  
4. Also. Hon SJ has mentioned  at quite a few places – DR  & pension.This cannot be overlooked.

5. It is also to be highlighted that SC Bench in their order dt 8/8/2013 said a)IA 12 & IA 13 are admitted b) SLPs 29956 & 29957 are dismissed. So,it is necessary to forcefully repeat RELEVANT PARAS from Sri Asthana’s application where Pension revision with successive wage revisions,1997,2002,2007 & future wage revisions are mentioned.

6. (i) While LIC may again parrot like repeat their WRONG understanding, just to deprive pensioners, of the full import & significance of SC Order, we should not now enter into micro-details of the correctness or otherwise of the amounts, except  to say, only DR is done, Effective date is wrong & absurd,weightage not taken into account, post-8/1997 petitioners are coolly omitted by LIC,which is retrograde.

(ii) Respondent has to address to resolve twin issues by acting on that judgement & complying with in toto with a clear administrative  Circular within short stipulated time & payment of arrears to eligible pensioners within few weeks time as may be decided by this Hon Court to avoid any further delay as already thousands of pensioners have died & are dying. We repose full faith & confidence in this Hon Court to fill the gap in enforcing implementation of the twin benefits to aged pensioners, many above 70 years & already many dead& are dying.   It is unethical & immoral to postpone compliance any longer as CCP has run for much  greater length of time than warranted, more so after an assertion by Hon SC that there is No Stay on Hon SJ judgement dt 12/1/2010.
           
(iii) It is enough if it is mentioned that – the SAME PRINCIPLE & PROCEDURE which is followed by LIC for wage negotiations implementation,ie MERGER OF DA WITH BASIC PAY, Same Principle & Procedure should be followed by MERGER OF CORRECT 100% DR WITH BASIC PENSION for pensioners at successive CPIndex followed for wage revisions  600/1148/1740/2328/2994 etc. This will make the task easy to enable Hon Judge to conclude rather than prolong submissions on this score.

7.  LIC has wrongly taken truncated 50 % existing DR INSTEAD of CORRECT FULL 100% DR while merger with Basic Pension takes place.This is deliberate or absurd & should be corrected .Hon Judge will understand to point out to LIC Counsels so that later, they don’t repeat the error or blunder. LIC makes it easy to calculate for them, but hitting the pensioners harsh considerably.

8. Hon Judge J.S.Chauhan has asked Respondent on an affidavit  to emphatically state whether the amount is being deposited in consonance with or in contravention  of Board Resolution dt 24/11/2001 & what steps & decisions taken by LIC for implementation. This exercise before 1/2/2014 etc.

(i) This is a golden opportunity for us to refer to all or main important letters dt 31/12/2001 ,8/8/2003 & subsequent followups  20/2/2009 & 6/5/2009 LIC has not bothered to do some introspection &help fulfillment of Hon SJ dt 12/1/2010 as HON JS.Chauhan refers to last 4 years,in 1st line of his Order,when same status quo without change in their thinking & only adhering & conforming to wrong presumptions, whereas in reality, LIC wanted to merge DR with Basic Pension at various CPIndices to bring intergenerational pension parity for all groups, also pointing to CG CCS Pension Rules, on the basis of which LIC PR 1995 came into being. LIC cleverly does not want to show  followup  as that will expose LIC’s good intentions in the spirit in which that concept of pension upgradation was rightly conjured & letter to MOF written.

When Respondent has not paid a single paisa towards pension upgradation for which alone this CCP 760/2010 was filed,it becomes crystal clear that it is direct violation of Hon SJ judgement dt 12/1/2010 admitting both the writs.This Hon Court must, therefore, straightaway dismiss this reply as of no consequence & not befitting an institution which must honourably  fulfil in entirety the  full & complete orders of Hon SJ.

Doing something slipshod & trying to prove the wrong direction in which Respondent is proceeding without any rectification or correction in its course clearly points out the absurdity of their intentions, with only one main aim to thwart the Hon SJ verdict & deny due benefits allowed by Hon SJ in his Judgement dt 12/1/2010.

9.  Hon SJ adjudicated on both issues of Full DR & pension upgradation with sound submissions by all parties  & citing several case laws in support of the same with valid , justifiable &  justiciable  reasons forcefully depicted in  judgement   unambiguously. To deny this is to deny full equity, justice, fair play & sabotage Fundamental Rights enshrined in Constitution  which no Court can allow to be tampered under any circumstances. Human rights cannot be allowed to be trampled upon . Fixity of notions on the part of the Respondent to deny pension upgradation is a severe contempt of this HC & not to implement for so many years by an extension of Respondents own Board sanctified Resolution dt 24/11/2001 to subsequent wage revisions as was delineated by Hon SJ in his judgement dt 12/1/2010 is a standing example of the adamancy & single track mind of Respondent to nullify  hard earned   judgement with heavy costs & expenses in many directions strictly not affordable by pensioners fraternity, yet borne with patience & endurance to solicit victory for the just, modest & legitimate demands of pensioners. One cannot throw all the positive & unanimous judgements  from many HCs as irrelevant  & unjustifiable from any point of view.

10.  When pensioners brought halo & glory to the institution

--- with long dedicated, devoted services of 35 years & more,
--- in the twilight of their lives,
--- pension upgradation voiced by multiple case laws of many Courts, SC,& Tribunals
--- any discrimination& attack on Fundamental Rights enshrined in our Constitution  must be  countered  with an open mind, fair & transparent
---- restoring the pride & position which  SC & HCs enjoy unfettered.

Pensioners’ fraternity must appreciate the strength and   solidity of our argument &  expose LIC wily tactics & strategy to always delay & dither consuming such long time of 4 yrs as Hon Judge himself feels. May darkness disappear and light illumine the minds and hearts of all pensioners to rejoice.

R.B.KISHORE,VP,AIRIEF