COMPLAINT FORM

WORLD BANK GRIEVANCE REDRESS SERVIC

(GRS)
1. Complainants Information

(This information must be provided. The identity of complainants will be kept confidential if they request so. Anonymous complaints will not be ac

Names and
Titles (Dr., Mr.,
Ms., Mrs.)
1..
2..
3..
4..

Signatures

Iqbal Hassan
Riaz Khan
Fatima Saeed
Shagufta Abid

Positions/Organ
izations (If
any)
1.. Facilitator
2.. Office
Assistant
3.. Facilitator (F)
4.. Facilitator (F)

Addresses
1..KP-SADP, DIUTank
2.. KP_SADP, DIUTank
3.. KP-SADP, DIUTank
4.. KP-SADP, DIULakki Marwat

Contact
numbers
1.. +92-3345033675

E-mail addresses
Iqbal_eco@yahoo.com
riaz_tharukhel@yahoo.com,

2.. +92-3005878704

Please indicate how you prefer to be contacted (e-mail, mobile, etc.): E-mail and Mobile

Do you request that identity be kept confidential?

Yes

No

3. Project Information
Project name (and
project number if known)
Project location
(Country, Province, City,
etc.)

KP-Southern Area Development Project, P130835

Pakistan, Khyber Pakhtunkhaw (KPK), Dera Ismail Khan, Lakki Marwat and Tank

Venerable Sir/Madam
Keeping into account the prestige and grace attached with and being enjoyed by this highest profile
organization, The World Bank, we humbly and meekly put our case and bring some facts in the kind notice of all
those responsible for the peaceful running of its affairs and operations. We are very much confident and hopeful that
due consideration will be paid to our appeal and that all possible efforts will be made to redress our serious
grievances and distress with justice, impartiality and equitably, at the earliest. Though the facts of our case are quite
simple and straightforward, admitting no any ambiguity, but the intransigence, high handedness and insensitivity on
the part of the project management, have thrown all of us in an awkward conditions and have rendered us pitiable
victims of injustice and prejudice.
We have been employees of KP-Southern Area Development Project (KP-SADP), an initiative of Provincial
Government of Khyber Pakhtunkhwa (KP), Pakistan, with the financial assistance of Multi Donor Trust Fund
MDTF/World Bank. The Project ID is P130835. The project was practically launched in May-2013. All the
post/vacancies from top to bottom were published in the News Paper for an open competition. We applied against
the desired posts and were appointed on the undermentioned posts purely on merit w.e.f 27 May 2013 till 30 June

2014. Out of one year contract agreement, we successfully completed our probation period for 6-months, and then
the contract extension was granted after every 6-month till 31 October 2015 along with all the other staff of the
project.
During our tenure in office we performed our duties with professionalism, dedication, commitment and
integrity. We have gained much-too-much experience and knowhow of the project design, purpose and
methodology. But despite the fact it is stated with broken hearts that our contract was not granted extension after 31
October 2015 without any good and cogent reasons, while all the rest of the project staff was granted contract
extension till 12 November 2015.It is also pertinent to mention here that the project has tremendously suffered from
the high turnover of the project employees in the past and currently 21 key post excluding our posts, of different
categories are laying vacant. But totally ignoring and disregarding this grave issue with the project, our contracts too
were not given extension which is posing a severe blow to the smooth, efficient and effective functioning of the
project.
Although we were continually attending our office for the month of November 2015, but the letter issued on
23rd November 2015 by the Project Director/Commissioner Dera Ismail Khan, mentioning extension till 12 December
2015 and the list of the staff attached with it, was missing our names and hence no extension of our contract
agreements. Feeling extremely grieved, dejected and appalled, we lodged appeal before Project
Director/Commissioner Dera Ismail Khan, dated 26 November 2015, for a just and fair treatment. In our personal
meeting with him, we were assured of just and equitable treatment. But after a prolonged period of 18 days, we were
served by a letter issued by Finance Specialist/Focal Person, dated 12 December 2015 through E-mail quoting the
reasons for dismissal of our appeals and non-extension of our contract agreements. The only plea adopted in the
letter was that the so called evaluation was conducted by the internal as well as external evaluation committees and
subsequently non-receipt of NOL from the World Bank. We then raised our strong objections and deep reservations
over the contents and timing of the aforesaid letter, through our letter dated 06 January 2016, while copying the
same letter to all the parties concerned, but all in vain and we did not receive any response from any of the parties
concerned till the date.
Having frustrated and disappointed from their side and having no any other efficacious remedy, we lodged a
writ petition against non-extension of our contract agreements in the Peshawar High Court Dera Ismail Khan Bench.
The Honourable Court granted us interim relief dated 17 December 2015 stating that the petitioner shall not be
relieved from the Project till the final decision of the main writ petition. We assumed our duties on the directive of
Peshawar High Court Dera Ismail Khan Bench and in compliance with Court orders, the Project
Director/Commissioner Dera Ismail Khan reinstated us along with all the other staff of the Project through a letter
dated 28th December 2015.
Although we were regularly attending our office and performing our official duties, but then they started
playing very cruel tricks against us, as they were bent upon not to release our salaries in a cynical disregard for
court orders and despite the frequent notices issued by the Honourable Court , in one pretext or another. They took
a firm stand before the Court that the World Bank is not willing to pay them their salaries, and that the government
and Project Director have no any say in this matter. And that being financed by the World Bank, the Project is
immune and exempted from proceedings of the court. As the honourable court was showing high regard for the
World Bank, it has shown great restraint to issue strict order under Contempt of Court proceedings for not releasing
our salaries, and thus we have been kept deprived of our 7-months salaries and have also lost our jobs.
Kind Sir/Madam
The case is not that we have committed any serious act of omission or commission, committed grass
misconduct, corruption, misuse of authority or cause loss to the project or any economic crime. In our evaluation
proformas, the comments are just verbose and proof less assertions, which are of no any legal value or worth, and
which are highly prejudicial, biased and are based on mal intent, and even if these comments are of any value or
worth, does it not in itself raise serious question marks over their key responsibilities as a manager/Administrator to
direct, communicate, plan, organise, implement and control their sub-ordinates? Can we be shown any steps taken
in fulfilling these sacred responsibilities particularly in our case? Does it not manifests that our service tenure is
extremely insecure and unreasonably fragile, for which even recourse to fulfilling the codal formalities is not
needed? Does it not shows the main cause of high turnover of the project employees?
As for as the most serious and gravest mistake committed in our case is the violation of the universal dictum
of established practice of law, which does not permit an individual to arrogate unto himself the roles of complainant,
prosecutor, judge and executioner. We were totally kept in darkness and unaware about the allegations levelled
against us. We were not even bothered to provide us an opportunity to put across our views about each and every
allegation hurled at us. The rational, equitable and factual course of action necessitates to ascertain the correctness

of such news or information before acting upon the same. But in our case they acted upon nothing but hearsays
without getting this information ascertained, verified or investigated and without affording us an opportunity of being
heard.
Also as a rule of established practice and procedure, once an employee satisfactorily complete his probation
period, then in accordance with the service policy, the contract should be extended till the completion of project life
except in case of commission of any of the aforementioned offences. But the prevalent practice in our project is that,
the Sword of Damocles- in the form of so called satisfactory performance or otherwise- is permanently hanging over
our necks. This clause is being extremely misused and abused against the project employees. Every time during the
extended period of contract agreement, everything will be ok with the employees, but suddenly at the evaluation day
they will become made at any employee. Our case is not the only one. The same foul and unlawful practice has also
been used in the past several times against the project employees, but they were bring back into the project- as
nothing was proved against them-by the intervention of the project director/Commissioner Dera Ismail Khan and
Peshawar High Court. But in our case the burden of responsibility has been wholeheartedly shifted toward the World
Bank in the form of non-receipt of No-Objection-Letter (NOL), which has been pleaded as the main cause of action,
whenever we ask them about the reasons, logic, justification and rationality behind this act.
We would also deem it necessary to mention here that the project is practically dormant and dysfunctional
since 30 June 2015 till the date. Not even a single penny has been spent in the developmental activities owing to the
poorest of the poor decision making abilities of the project staff at the upper level. The project is undergoing through
a state of great depression of its life, for which the upper level staff of the project is wholly and solely responsible
due to their ineptness and inertia. With grief and very much sorry to say that the project is going to be closed at 30
June 2016 due to low utilization of developmental fund and achievements of targets and goals. The project is also
deprived of its own full time project director since the last 2 years, and commissioner Dera Ismail Khan has been
assigned additional charge of the project Director. Due to his extremely busy schedule he cannot spare sufficient
time to oversee and manage the activities of the project with full focus, and to resolve the issues in an effective and
amicable way. He is practically inaccessible to lower staff. In our detailed letter to the new Project Director/
Commissioner, dated16 February 2016,we also vehemently raised the issue with him and requested him to conduct
a high level impartial inquiry in to our case, and he marked our letter to the focal person for a detailed report but they
turned blind eyes to it and did not pay any heed. In our case the worse of it is that, the finance specialist, who has
been made as focal person, is totally devoid of any administrative and managerial skills. He was not the principle
candidate for the post of financial specialist and he was inducted in the project on a deputation from the government
department against the criteria set forth in the advertisement. As for as the District Officers at District Implementation
Units (DIUs) level are concerned, the District Officer of D.I.U Lakki Marwat was involved in sexual harassment of
female staff. He has been made as OSD from the last one year. Recently an inquiry has been conducted by the new
Project Director, while its finding has been kept as secret and is not revealing its recommendations to the victim. The
District Officer D.I.U Tank was initially appointed as District Officer D.I.Khan, but due to his male administration and
mis-management, transferred to D.I.U Tank as punishment by the then project Director. Now he has been
transferred to D.I.U Lakki Marwat on the similar grounds. He is not even conversant with the ABC of the Community
Driven Development approach, and is completely devoid of any managerial and administrative capabilities. Lack of
this skill and ability can be gauged from the fact, that although he has levelled very serious, somewhat vague and
irrational acquisition against us, but at the same time showing complete failure to take any step in this regard, in
fulfilling his sacred responsibilities as a manager or administrator.
Now by minutely analyzing the aforementioned facts and figures can they claim a moral high ground not to
extend our contract on the basis of so called satisfactory performance or otherwise-when they themselves holding
the highest position in the project have proved their inefficiency and incompetence to steer the project out of crisis
and who being the real decision makers are entirely responsible for the sorry state of affairs that the project is going
through? Is it the right time not to extend our contract agreements when the project is practically dysfunctional and
dormant? Also it not clearly manifest that we the lower staff have been made scape goats in the shape of shifting the
burden of responsibility of failure and incompetence towards us? How can they be expected to bring about
development in these least developed and crisis hit area and relief to the marginalised and vulnerable people-the
real purpose and vision of the project-when they are meting out such a callous and prejudicial treatment with their
fellow colleagues?
Kind Sir/Madam
We feel deeply offended, grieved and alienated. Very humiliatory treatment have been meted out to us. We
have been tremendously suffered mentally, physically and emotionally. We have been subjected to an extreme
extent of injustice, discrimination and mental anguish. We have used every weapon in our armour but they are not

responding in no anyway whatsoever. We are suffering from frustration and disappointment. Our seven months
salary has been still withheld, not to speak of our lost jobs .And all this is done to us by using the name of your
internationally acclaimed organization. We heaved a sigh of relief and comfort when as a last resort we came across
the website of this highest profile organization and found this great initiative for redressal of grievances. We knocked
at every door for the provision of justice and relief but got nothing less than frustration and humiliation. Now we have
pinned all our hopes on you. We lodge our case in the court of World Bank, with full trust, hope and optimism that
speedy and cheap justice will be provided and fair and equitable treatment will be meted out to all of us and that our
despair will be turned in hope. As far as the release of our pending salaries are concerned ,the Bank authorities
concerned are requested to kindly bound them release our salaries with immediate effect on humanitarian and
compassionate grounds, as we are suffering from severe financial constraints. While the modus operandi that will be
employed to resolve our main case of reinstatement, is totally left at kind discretion and expertise of the Bank
authorities concerned. In the instant case each and every documental evidence will be shared with the World Bank
authorities concerned for smooth investigations.
Best Wishes with highest Regard

Name of the person who completed this form:

Iqbal Hassan and Riaz Khan
Signature:
Date:
04-06-2016
Please send the complaint to:
The World Bank
Grievance Redress Service (GRS)
MSN MC 10-1018
1818 H St NW
Washington, DC 20433, USA
Email: grievances@worldbank.org
Fax: +1 202 614 7313
Complaints may be submitted by mail, fax, e-mail, or hand delivery to the World
Bank headquarters or any World Bank country office.