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4596/2020 Const. P. Muhammad Jam (Petitioner) V/S Fed. of Pakistan and Others (Respondent)

Sindh High Court2025

Bench: Hon'ble Mr. Justice Muhammad Karim Khan Agha, Hon'ble Mr. Justice Adnan-ul-Karim Memon

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4596/2020 Const. P. Muhammad Jam (Petitioner) V/S Fed. of Pakistan and Others (Respondent) Sindh High Court

Bench: Hon'ble Mr. Justice Muhammad Karim Khan Agha, Hon'ble Mr. Justice Adnan-ul-Karim Memon Order Date: 12-MAY-25

The Supreme Court has ruled that proforma promotion is a remedy for individuals who miss promotion due to administrative errors or delays and subsequently retire. If a qualified and senior employee is denied timely consideration by a DPC or Selection Board due to administrative oversight, they have a legitimate expectation for proforma promotion with related benefits. This concept is rooted in the now-omitted Fundamental Rule 17, which allowed for back pay and allowances through proforma promotion for those wrongly prevented from higher posts through no fault of their own. Unjustified delays in proforma promotion cases cause hardship and unnecessary litigation. Competent authorities should establish strict timelines for proforma promotion committees to ensure swift and rational decisions, preventing retired employees from having to seek court intervention for their rightful benefits.

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