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BY REGISTERED POST A.D. / COURIER [COPY BY E-MAIL] — PLEASE ACKNOWLEDGE RECEIPT
Date: [DD/MM/YYYY]
To:
[NAME AND DESIGNATION OF THE EMPLOYER OR HEAD OF HR / CHIEF EXECUTIVE]
[NAME OF THE ESTABLISHMENT / COMPANY]
[ADDRESS OF HEAD OFFICE OR ESTABLISHMENT]
From:
[FULL NAME OF WORKER]
S/o, D/o, W/o [FATHER'S OR HUSBAND'S NAME]
CNIC No. [XXXXX-XXXXXXX-X]
Employee No. [EMPLOYEE NUMBER]
[POSTAL ADDRESS]
[MOBILE] · [E-MAIL]
Subject: GRIEVANCE NOTICE under section 33 of the Industrial Relations Act, 2012 against my [TERMINATION / DISMISSAL / REMOVAL / RETRENCHMENT] from service with effect from [DD/MM/YYYY]
Sir/Madam,
I, the undersigned, bring the following grievance to your notice under section 33(1) of the Industrial Relations Act, 2012, within ninety days of the day on which the cause of the grievance arose:
1. That I joined your establishment on [DD/MM/YYYY] as [DESIGNATION] in the [DEPARTMENT] at [PLACE OF POSTING], and was confirmed / have worked continuously since then as a [PERMANENT / CONTRACT / THIRD-PARTY] worker. My last drawn monthly wage was Rs. [AMOUNT].
2. That my work is of a [CLERICAL / TECHNICAL / OPERATIONAL / SUPERVISORY] nature; I do not perform managerial or administrative functions.
3. That your establishment [IS SITUATED IN THE ISLAMABAD CAPITAL TERRITORY / CARRIES ON BUSINESS IN MORE THAN ONE PROVINCE, WITH OFFICES AT [CITIES]].
4. That throughout my service my record has been [CLEAN / SATISFACTORY]. [MENTION ANY APPRECIATION, INCREMENT OR PROMOTION, IF ANY.]
5. That on [DD/MM/YYYY] I was [ORALLY TOLD NOT TO COME TO WORK / HANDED A LETTER No. ___ DATED ___] terminating my services with effect from [DD/MM/YYYY]. [IF A LETTER WAS GIVEN: The letter does not state any reason / states the reason as "___", which is incorrect because ___.]
6. That the action is illegal and unjustified because:
a) no order in writing explicitly stating the reason for the action was given to me, as required by Standing Order 12(3) of the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968 [DELETE IF A REASONED ORDER WAS GIVEN];
b) [I was not given one month's notice or one month's wages in lieu of notice under Standing Order 12(1)];
c) [no charge of misconduct was communicated to me in writing, I was given no opportunity to explain, and no independent inquiry was held, as required by Standing Order 15(4)];
d) [the action is mala fide / discriminatory / by way of victimisation for ___];
e) [my wages and other dues, including payment for unavailed leave, were not paid before the expiry of the second working day after termination, as required by Standing Order 12(4)].
7. That the following dues remain unpaid:
Item Period Amount (Rs.)
Wages for [MONTH(S)] [FROM – TO] [AMOUNT]
Wages in lieu of notice one month [AMOUNT]
Unavailed leave [NUMBER] days [AMOUNT]
Gratuity / provident fund [YEARS OF SERVICE] [AMOUNT]
Total [TOTAL]
I therefore request you to:
i. withdraw the [TERMINATION / DISMISSAL] order and reinstate me in service with all back benefits from [DD/MM/YYYY]; [OR, IF REINSTATEMENT IS NOT SOUGHT: pay me the dues listed above;]
ii. communicate your decision to me in writing within fifteen days of receiving this notice, as required by section 33(2) of the Industrial Relations Act, 2012.
Please take notice that if you fail to communicate a decision within fifteen days, or if I am dissatisfied with your decision, I shall take the matter to the National Industrial Relations Commission under section 33(4) of the Act, entirely at your risk as to costs and consequences.
Yours faithfully,
______________________________
[FULL NAME OF WORKER]
CNIC No. [XXXXX-XXXXXXX-X]
[MOBILE] · [E-MAIL]
Enclosures (copies):
1. Appointment / confirmation letter
2. Termination / dismissal letter, if any
3. Last salary slip or bank statement showing salary
4. Service card / employee ID card
5. [ANY SHOW-CAUSE NOTICE, CHARGE SHEET OR INQUIRY PAPERS]
NOTES BEFORE SENDING — delete this part
Ninety days: the grievance notice must reach the employer within 90 days of the day the cause of the grievance arose (section 33(1)) — usually the date of the termination order or the date you were stopped from work. Section 33 makes this notice the first step before any petition to the Commission. Send it early.
Fifteen days: if you send the notice yourself, the employer must give its decision in writing within 15 days (section 33(2)). If it goes through your shop steward or collective bargaining agent, the employer has 7 days (section 33(3)).
Sixty days: if there is no decision in time, or you are not satisfied, take the matter to the Commission within 60 days from the employer's decision or from the end of the 15 (or 7) days (proviso to section 33(4)). The Commission is required to decide within seven days.
Who this section covers: the Industrial Relations Act, 2012 applies to establishments in the Islamabad Capital Territory and to those carrying on business in more than one province (section 1(3)). It covers "workers" — not persons employed mainly in a managerial or administrative capacity (section 2(xxxiii)). For a business in only one province, the provincial labour law applies (in Punjab, the Punjab Labour Code 2026): check its grievance procedure and deadlines before relying on this notice.
Standing Orders (one month's notice, written reasons, inquiry before dismissal, dues within two working days) apply to industrial or commercial establishments with 20 or more workmen (Standing Orders Ordinance, 1968, section 1(4)).
Send by registered post A.D. or courier and keep the receipt and tracking: you will need proof of delivery for the 15-day and 60-day dates.
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