5497/2019 Const. P. Manzoor Ahmed Jokhio (Petitioner) V/S Province of Sindh & Others (Respondent)
Bench: Hon'ble Mr. Justice Muhammad Karim Khan Agha, Hon'ble Mr. Justice Adnan-ul-Karim Memon(Author)
5497/2019 Const. P. Manzoor Ahmed Jokhio (Petitioner) V/S Province of Sindh & Others (Respondent) Sindh High Court
Bench: Hon'ble Mr. Justice Muhammad Karim Khan Agha, Hon'ble Mr. Justice Adnan-ul-Karim Memon(Author) Order Date: 02-MAY-25
The provided rule and Supreme Court precedents establish a civil servant's entitlement to pro-forma promotion. The Supreme Court in Secretary Schools of Education v. Rana Arshad Khan (2012 SCMR 126) granted proforma promotion to retirees due to unjustifiable departmental delays in their promotion process before retirement. Similarly, Federation of Pakistan v. Jahanzaib (2023 PLC (C.S.) 336) held that proforma promotion is applicable when an administrative oversight delays consideration for promotion until after retirement. Furthermore, in Homeo Dr. Asma Noureen Syed v. The Government of Punjab (2022 SCMR 1546), the Supreme Court remanded a case back to the Service Tribunal for fresh consideration of proforma promotion for a retired civil servant. These judgments underscore that employees should not suffer due to departmental failings regarding timely promotion consideration.