Labour Court, Dwarka - Burden of proving employer & employee relationship is upon the worker and the said burden can be discharged only by leading cogent evidence

On 14 December 2018, Labour Court, Dwarka, passed an Award in LIR No. 1937/16, wherein it was held that the workers therein are not entitled to any relief.

Anuj Aggarwal, Advocate, appearing for M/s Frigorifico Allana Pvt. Ltd. (management), argued that the burden of proving the employer and employee relationship is upon the worker and the workmen, in the case, had not produced any document to prove that they were employees of the management.

Shri Lokesh Kumar Sharma, Addl. District & Sessions Judge, Presiding Officer, Labour Court – XIX, Dwarka Courts, Delhi, accepted the submission made by the counsel for the management and declared that there is no employer and employee relationship between the management and the workers and, therefore the workers are not entitled to any relief. Reference was, thus, answered in favour of the management.

http://advocateanujaggarwal.com/admin/img/Finalist/2018121615449508472018%20-%20Ved%20Prakash%20&%20Sanjay.pdf

Sexual Harassment of a female sweeper

Sexual Harassment of a female sweeper - Termination of service by Guru Nanak Public School of a driver and a conductor on the allegations of Sexual Harassment of a female sweeper – Delhi School Tribunal declared the termination of service of both the employees as illegal and directed the School to reinstatement them in service

On 20.11.2018, the Hon’ble Delhi School Tribunal, in Appeal No. 17/2018 and Appeal No. 18/2018, declared the termination of service of 2 employees (Karamvir and Amit) as illegal and directed Guru Nanak Public School to reinstatement them in service. The services of both the employees were terminated on the alleged ground of sexual harassment of a female sweeper.

Shri. Karamvir and Shri. Amit were working as driver and conductor respectively with Guru Nanak Public School, Pushpanjali Enclave, Pitampura, Delhi-110034. On 13.09.2017, an FIR [FIR No. 1246] was registered by a female sweeper against Karamvir and Amit with the allegations of sexual harassment. Next day i.e. on 14.09.2018, vide letter/order dated 14.09.2017, the services of both the employees were terminated.

Anuj Aggarwal, Advocate, counsel for Karamvir and Amit, submitted that the termination of service of both the employees was in complete violation of the principles of natural justice, provisions of the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressal) Act, 2013, provisions of the Delhi School Education Act, 1973 and the Rules made thereunder.

Shri. V.K. Maehshwari, Presiding Officer, Delhi School Tribunal, Delhi, accepted the submissions made by Anuj Aggarwal, Advocate and declared that the termination orders dated 14.09.2017 were illegal and, consequently, directed Guru Nanak Public School to reinstate both the employees in service.

http://advocateanujaggarwal.com/admin/img/Finalist/201812031543818256New%20Microsoft%20Office%20Word%20Document.pdf

Labour Court, Dwarka – Illegal termination of service of a Sr. Service Technician by M/s BSH Household Appliances Manufacturing Pvt. Ltd. – Labour Court awarded reinstatement in service with full back wages, continuity of service and with all other consequential benefits

On 11 October, 2018, Labour Court, Dwarka, declared the termination of service of a Sr. Service Technician (Sh. Vikas Kumar Sharma) by M/s BSH Household Appliances Manufacturing Pvt. Ltd. as illegal and awarded reinstatement in service with full back wages, continuity of service and with all other consequential benefits.

Sh. Vikas Kumar Sharma (workman) was appointed by M/s B.S.H. Household Appliances Manufacturing Pvt. Ltd. (management) on 08.03.2004. After working continuously for almost 10 years, the management terminated the service of the workman on 19.01.2014. Contention of the management was that the workman was an employee of a contractor and there was no employer-employee relationship between the management and the workman.

Anuj Aggarwal & Ashish Jha, Advocates, appearing for the workman, argued that the appointment letter, confirmation letter as well as the promotional letters were issued by the management and, therefore, M/s B.S.H. Household Appliances Manufacturing Pvt. Ltd. was the employer of the workman and the action of the management of terminating the services of the workman was illegal and in violation of the provisions of the Industrial Disputes Act, 1947.

Sh. Vinay Singhal, Addl. District & Sessions Judge, POLC–V, Dwarka Courts, Delhi, accepted the submissions made the counsels for the workman. The Hon’ble Labour Court declared the termination as illegal and directed M/s B.S.H. Household Appliances Manufacturing Pvt. Ltd. to reinstatement the workman in service with full back wages along with continuity of service and with all other consequential benefits.

http://advocateanujaggarwal.com/admin/img/Finalist/2018110515414309902018%20-%20Award%20-%20Vikas%20vs.%20BSH.pdf

Labour Court directs Nirula's Corner House Ltd. to reinstate 9 workers whose services were terminated by way of refusal of duty

On 09^th October, 2018, Labour Court, Dwarka, directed the Nirula's Corner House Ltd. to reinstate 9 workers whose services were illegally terminated by way of refusal of duty.

The workers were working as cooks for almost 20 years with the Nirula's Corner House Ltd. The benefits of Dearness Allowance (D.A.), Bonus, etc. were illegally denied to the said workers. The workers, accordingly, demanded their due Dearness Allowance (D.A.), Bonus, etc. from the Nirula's Corner House Ltd. The raising of demand by the workers infuriated the management and the management decided to victimize the workers. In order to victimize the workers, on account of raising the demands, in April, 2018, the management terminated their services by way of refusal of duty. Being aggrieved by their illegal termination of service, the workers raised an industrial dispute and filed a statement of claim before Labour Court, Dwarka, New Delhi.

Anuj Aggarwal & Ashish Jha, Advocates, counsels for the workers, submitted that the termination of service of the workers was illegal, in violation of the principles of natural justice and also in violation of the provisions of the Industrial Disputes Act, 1947.

Shri Umed Singh Grewal, Pilot Court, Presiding Officer, Labour Court, Dwarka Courts, New Delhi, accepted the submissions made by the counsels for the workers and declared that the termination of service of the workers was illegal. The Hon’ble Court also directed the management to reinstate the workers in service and pay 50% backwages for the period of enforced unemployment.

http://advocateanujaggarwal.com/admin/img/Finalist/201810131539425060display_pdf.pdf

2018 - Delhi High Court - After 30 years of litigation, dismissed employee gets justice – Dismissal order set aside and direction to pay full back wages up to the date of superannuation – DTC dismissed its conductor in the year 1988 on the alleged charge of participation in an illegal strike

On 19 September 2018, Hon’ble Delhi High Court declared that the dismissal of Sh. Sho Ram (Conductor) from service was illegal and directed the Delhi Transport Corporation (D.T.C.) to pay full wages, including retiral dues, to Sh. Sho Ram up to the date of his superannuation.

In the year 1988, Sh. Sho Ram was dismissed from service on the alleged charge of participation in an illegal strike. Sh. Sho Ram was working as a conductor and contended that he never participated in the strike.

In the year 1988, Sh. Sho Ram raised an industrial dispute before the Industrial Tribunal. On 19 December 2011, the Hon’ble Industrial Tribunal held that the workman was not entitled to any relief. Being aggrieved by the Award dated 19 December 2011, as passed by the Hon’ble Industrial Tribunal, the workman filed a writ petition [W.P.(C) 2081/2012]  before the Hon’ble Delhi High Court. It may be noted that on 31st January, 2012 Sh. Sho Ram attained the age of superannuation.

Anuj Aggarwal, & Ashutosh Dixit, Advocates, counsel of Sh. Sho Ram (workman) contended that Sh. Sho Ram never participated in the strike and the termination of service of Sh. Sho Ram was in violation of Section 33 of the Industrial Disputes Act, 1947.

Hon'ble Mr. Justice C. Hari Shankar, Delhi High Court, accepted the submissions made by the counsels of Sh. Sho Ram and declared that the dismissal of Sh. Sho Ram from service was illegal. The Hon’ble Court directed the D.T.C. to pay full salary to Sh. Sho Ram up to the date of his illegal dismissal from service. The Hon’ble Court further directed the D.T.C. to pay all the retiral dues to Sh. Sho Ram within a period of 4 weeks.

http://advocateanujaggarwal.com/admin/img/Finalist/2018092715380230622018%20HC%20-%20Sho%20Ram%20vs.%20DTC.pdf

CAT - Provisionally accept the E-Dossier of the shortlisted candidates

2018 – Central Administrative Tribunal (C.A.T.) – Appointment on the post of Special Educator (Primary), M.C.D. (Post Code 15/17) – CAT, vide Order dated 25 September 2018, directed the Delhi Subordinate Services Selection Board (D.S.S.S.B.) to provisionally accept the E-Dossier of the shortlisted candidates – The shortlisted candidates, who were applicants in the Original Application [O. A. No. 3647/2018], possessed all the requisite qualifications except Central Teacher Eligibility Test (TEST) qualification

http://advocateanujaggarwal.com/admin/img/Finalist/2018092715380213772018%20-%20CAT%20-%20E%20dossier.pdf

Delhi High Court – Subsistence Allowance – Rule 116, Delhi School Education Rules, 1973 - Direction to a private unaided unrecognized school to pay subsistence allowance to its teacher – Held, “subsistence allowance in law is a natural entitlement of every employee subject to the ignominy of suspension.” [Simmi Kathpal vs. Hanuman Mandir Public School and Ors; W.P. (C) 6840/2017; Date of decision: 28th August, 2018]

On 28 August 2018, Hon’ble Delhi High Court directed a private unaided unrecognized school to pay subsistence allowance to its teacher. The teacher was kept under suspension for more than 2 years but was not paid any money on account of subsistence allowance.

Anuj Aggarwal, Ashutosh Dixit and Kshitij Arora, Advocates, appearing for the petitioner/teacher, argued that it is a statutory duty of school, including unrecognized school, to pay subsistence allowance to its teacher who is suspended from service. Accepting the submissions, Hon'ble Mr. Justice C. Hari Shankar directed the school to pay subsistence allowance to the teacher. It was, inter alia, noted by the Hon’ble Court as under:-

“The petitioner has, in fact, had to run from pillar to post, for the past three years, in order to ensure payment of subsistence allowance to her which, in law, is a natural entitlement of every employee subject to the ignominy of suspension. Subsistence allowance, it has to be noted, is essentially intended to tide the employee over the period of suspension, so that, she or he is able to prosecute the proceedings against her, or him and is not left with no means of sustenance, being “out”, so to speak, of a job.”

The contention of the respondent/school that writ petition is not maintainable against a private school was also rejected.

http://advocateanujaggarwal.com/admin/img/Finalist/2018090315359889522018%20Del%20Single%20-%20SIMMI%20KATHPAL.pdf

After 28 years litigation, the true owner gets the possession of property back from unauthorised occupants – Delhi High Court rejects the contention of Adverse Possession

On 17 August 2018, the Hon’ble Delhi High Court gave possession of property, situated at Kashmiri Gate, back to its true owner after 28 years of litigation. The suit for possession [Suit No. 652/1990] was filed by the owner - Shri. Ram Chander in the year 1990 before the Hon’ble Tis Hazari Court. The said civil suit was dismissed on 24.04.1997 on the ground of adverse possession. Thereafter, Shri. Ram Chander filed an appeal [RFA No. 314/97] before the Hon’ble Delhi High Court in the year 1997. The said appeal was finally decided on 17 August 2017 in favour of Shri. Ram Chander.

Anuj Aggarwal & Kshitij Arora, Advocates, appearing for Shri. Ram Chander argued that the trial court has committed a grave error because trial court has wrongly held respondents/defendants to be owners by adverse possession simply on account of respondents/defendants being in continuous and uninterrupted possession but without any finding with respect to assertion of the hostile title.

Accepting the submissions, Hon’ble Mr. Justice Valmiki J. Mehta, Delhi High Court, held that “Trial Court has held respondents/defendants as owners by holding 'respondents/defendants were openly and continuously without interruption' in possession of the suit property, and which in law is not sufficient because not only the possession has to be open and continuous but the possession has to be hostile to the true owner and there has to be an assertion of ownership title in the person who claim adverse possession to the knowledge of the true owner and the world at large, and which is clearly as per the evidence led by the respondents/defendants missing in the present case.” The Hon’ble Delhi High Court also passed money degree in favour of Shri. Ram Chander which reads as under:-

“Money decree is accordingly passed and in favour of the appellant/plaintiff and against the respondents/defendants for arrears at Rs.900, pendente lite and future mesne profits at the rate of Rs. 25 per month, to be increased cumulatively by 15% every year and these amounts will be chargeable at 6% per annum simple.”

http://lobis.nic.in/ddir/dhc/VJM/judgement/17-08-2018/VJM17082018RFA3141997.pdf

http://www.advocateanujaggarwal.com/notejudgement.php?courtid=2

2018 CAT – Interim relief - CAT directed the DSSSB to provisionally accept the Offline Application Forms of the overage women candidates seeking appointment on the post of Primary Teacher in MCD, Delhi

2018 Central Administrative Tribunal (CAT) – Interim relief - CAT directed the Delhi Subordinate Services Selection Board (DSSSB) to provisionally accept the Offline Application Forms of the overage women candidates seeking appointment on the post of Primary Teacher in MCD, Delhi.

http://advocateanujaggarwal.com/admin/img/Finalist/2018072915328817472018%20CAT%20-%20Surekha%20&%20Ors..pdf

2018 - Central Administrative Tribunal directed the Delhi Subordinate Services Selection Board (DSSSB) to issue admit cards to the candidates who had filled the offline forms for appointment on the teaching posts.

2018 - Central Administrative Tribunal directed the Delhi Subordinate Services Selection Board (DSSSB) to issue admit cards to the candidates who had filled the offline forms for appointment on the teaching posts.

http://advocateanujaggarwal.com/admin/img/Finalist/2018072915328811752018%20CAT%20-%20Neelam%20&%20Ors..pdf

2018 Central Administrative Tribunal - Clerical mistake in filling the application form cannot be a ground for denying the admit card for written examination for appointment on the post of the Post Graduate Teacher (PGT)

2018 Central Administrative Tribunal - Clerical mistake in filling the application form cannot be a ground for denying the admit card for written examination for appointment on the post of the Post Graduate Teacher (PGT)

http://advocateanujaggarwal.com/admin/img/Finalist/2018072915328806922018%20CAT%20-%20Mohammad%20Mohsin.pdf

Delhi School Tribunal directs an aided school to comply with DST’s Order or else the Manager of the school will be prosecuted under Section 27 of the DSEA, 1973

Delhi School Tribunal (DST) on 10.05.2018, in Execution Petition No. 37/2017, directed the Commercial Senior Secondary School to comply with DST’s Order dated 05.05.2017, passed in Appeal No. 71/2016, failing which the Manager of the school will be prosecuted under Section 27 of the Delhi School Education Act, 1973.

Commercial Sr. Sec. School, Darya Ganj, Delhi is a Government-Aided-School. The school terminated the service of Mrs. Abha Gupta, PGT (Commerce) in the year 2014 by way of refusal of duties. Being aggrieved, Mrs. Abha Gupta challenged her termination before the Delhi School Tribunal (DST). Vide Order dated 05.05.2017, in Appeal No. 71/2016, the DST decided the Appeal in favour of Mrs. Abha Gupta and directed the school to reinstate her in service will all the consequential benefits. Since the School failed to comply with the directions, Mrs. Gupta was constrained to prefer an Execution Petition before the DST.

DST rejected the contention of the school that they have complied with the order and declared that school has failed to grant annual increments and therefore not complied with the order. DST finally directed the school to comply with Order dated 05.05.2017 failing which the Manager of the school will be prosecuted under Section 27 of the Delhi School Education Act, 1973. It may be noted that Section 27, inter alia, provides punishment for a term up to 3 months imprisonment.

http://www.advocateanujaggarwal.com/admin/img/Finalist/2018051515263944132018%20DST%20-%20Execution%20-%20Abha%20Gupta.pdf

Denial of retrospective/antedating the promotion on the post of Deputy Manager (Technical) in IPGCL & PPCL, held illegal

2018 - Delhi High Court - Denial of retrospective/antedating the promotion on the post of Deputy Manager (Technical) in IPGCL & PPCL, held illegal - The stand of Indraprastha Power Generation Company Limited (IPGCL) & Pragati Power Corporation Limited (PPCL) of it being an autonomous body and therefore not being bound by all the DoPT’s Office Memorandums, rejected – Direction issued to IPGCL & PPCL to reconsider the claim of antedating the promotion of 4 Deputy Managers (Technical) in view of DoPT’s Office Memorandum dated 13 April 2010 – Further directed to grant all the consequential benefits in case the petitioners are found eligible – Ajay Kumar Sinha vs. Indraprastha Power Generation Company Limited (IPGCL) & Pragati Power Corporation Limited (PPCL) – W.P. (C) No. 2997/2016, Decided on 16 April 2018, Hon’ble Mr. Justice Sunil Gaur, Delhi High Court.

http://www.advocateanujaggarwal.com/admin/img/Finalist/2018042215243965122018%20Del%20Single%20-%20Ajay%20Kumar%20Sinha%20vs.%20IPGCL.pdf

A Yoga Teacher cannot be removed on the alleged ground of medical unfitness by a private school – Delhi School Tribunal directed reinstatement with costs of Rs. 1,10,000/-

On 08.03.2018, Delhi School Tribunal (DST), Delhi declared that a Yoga Teacher cannot be removed from service on the alleged ground of medical unfitness by a private school. The decision was rendered in Appeal No. 90/2017 entitled “Sunita Sahi vs. Sachdeva Public School”.

Anuj Aggarwal, Advocate, counsel for Ms. Sunita Sahi, argued that the termination of service of Ms. Sunita Sahi on the purported ground that she is unable to carry out her yoga duties constitutes a stigmatic termination of service and, therefore, it was obligatory for the school to conduct an inquiry and comply with the principles of natural justice. It was further argued that since Sachdeva Public School failed to comply with the principles of natural justice, Ms. Sunita Sahi, a confirmed yoga teacher, was entitled to be reinstated in service.

Accepting the submissions made by Anuj Aggarwal, Advocate, the DST declared that the action of terminating the service of Ms. Sunita Sahi by Sachdeva Public School was illegal and Ms. Sunita Sahi was held entitled to be reinstated in service. It was further held that in case Ms. Sunita Sahi could not perform the duties of yoga teacher due to medical reasons, then she should be assigned some other administrative duties. The Appeal preferred by Ms. Sunita Sahi was allowed with cost of Rs. 1,10,000/-.

CAT declares that a candidate can submit her Scheduled Caste Certificate after the cutoff/last date prescribed by DSSSB for appointment on the post of Teacher (Primary) in MCD

On 08.03.2018, the Central Administrative Tribunal (CAT), Delhi declared that a candidate can submit her Scheduled Caste (S.C.) Certificate after the cutoff/last date prescribed by the Delhi Subordinate Services Selection Board (DSSSB) for appointment on the post of Teacher (Primary) in MCD. The decision was rendered in O. A. No. 944/2015 entitled “Jyoti vs. Govt. of NCT of Delhi & Ors.”.

Anuj Aggarwal, Advocate, counsel for Ms. Jyoti, argued that a S.C. candidate is S.C. by birth and S.C. certificate merely certifies a pre-existing fact. He further argued that necessitating upon a certificate dated prior to cutoff date would be arbitrary and it has no rationale objective to be achieved. DSSSB had prescribed 15.01.2010 as the cutoff/last date for submitting the application forms whereas SC certificate was issued to Ms. Jyoti on 04.04.2011 by the Delhi Government.

Accepting the submissions made by Anuj Aggarwal, Advocate, CAT declared that the rejection of the candidature of Ms. Jyoti by the DSSSB for appointment on the post of Teacher (Primary) in MCD on the ground that she procured the SC certificate after cutoff/last date, was illegal. CAT further directed the DSSSB to forward the dossier of Ms. Jyoti for appointment on the post of Teacher (Primary) to the concerned MCD.

Delhi High Court – Land acquisition proceedings get lapsed in case Award is passed by the Collector 5 years prior to the commencement of the Land Acquisition Act, 2013

On 30.01.2018, the Division Bench of the Hon’ble Delhi High Court held that the land acquisition proceedings get lapsed in case Award is passed by the Collector 5 years prior to the commencement of the Land Acquisition, Rehabilitation and Resettlement (LARR) Act, 2013. The said judgment was passed in “Naresh Chandra Rastogi & Ors. vs. Govt. of NCT of Delhi & Anr.” [W.P. (C) 5706/2017].

Anuj Aggarwal, Advocate argued that in view of Section 24 of the LARR Act, 2013, where Award is passed by the Collector 5 years prior to the commencement of LARR Act, 2013 and where either the physical possession of the land has not been taken or the compensation has not been paid/tendered, then the land acquisition proceedings stand lapsed.

The Hon’ble Delhi High Court accepted the submission made by Anuj Aggarwal, Advocate and declared that that land acquisition proceeding initiated by Delhi Government with respect to the land situated in the revenue estate of Village Khanpur, Tehsil Mehrauli, New Delhi, stood lapsed. The Award in the case was passed by the Land Acquisition Collector on 16.07.1987.

http://www.advocateanujaggarwal.com/admin/img/Finalist/2018021815189636292018%20Del%20DB%20-%20NARESH%20CHANDRA%20RASTOGI.pdf

2017 – CAT directed the DSSSB to accept the application forms of candidates who have not passed Central Teachers Eligibility Test (CTET)

http://www.advocateanujaggarwal.com/notejudgement.php?courtid=3

CAT declares that the candidates who have done two years Diploma in Education (DEd) are entitled for age relaxation for the post of Teacher (Primary)

On 11.01.2018, the Central Administrative Tribunal, Principal Bench, New Delhi (CAT) in “Ms. Suman Rohilla vs. GNCTD & Ors.” [O.A. No. 2541 OF 2015] vide Order dated 11.01.2018, declared that the candidates who have done two years Diploma in Education (DEd) are entitled for age relaxation for the post of Teacher (Primary) in MCD.

In terms of the judgment passed by the Hon’ble Delhi High Court in Writ Petition (Civil) No. 7297/2007 titled “Sachin Gupta & Others v. DSSSB”, decided on 28.08.2008, the candidates who had completed “Certificate Course in ETE” in the year 2006 or 2007 or 2008, were entitled to appear in the examination by giving them age relaxation up to 32 years for male candidates and 42 years for female candidates.

Anuj Aggarwal, Advocate, counsel for Ms. Suman Rohilla, argued that although it was not specifically directed by the Hon’ble High Court in Sachin Gupta’s case (supra) that candidates who completed “Two Years Diploma in Education” in 2006 or 2007 or 2008, would be permitted by the DSSSB to appear in the examination by giving them age relaxation up to 32 years for male candidates and 42 years for female candidates yet the applicant, and other similarly placed candidates, are entitled to age relaxation up to 32 years for male candidates and 42 years for female candidates and denial of such age relaxation to the applicant, and other similarly placed candidates, would be irrational, arbitrary and discriminatory and thus violative of Articles 14 & 16 of the Constitution of India.

Accepting the submissions made by Anuj Aggarwal, Advocate, CAT declared that the candidates who have done two years “Diploma in Education” in 2006 or 2007 or 2008 are also entitled for age relaxation for the post of Teacher (Primary) in MCD. CAT further directed the DSSSB to grant one time age relaxation to Ms. Suman Rohilla and forward her dossier for appointment to the concerned municipal corporation.

http://www.advocateanujaggarwal.com/home.php

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CAT declares - Candidate who has not studied English in B.A. but has done MA (English) is qualified to be appointed as TGT (English)

On 03.01.2018, Central Administrative Tribunal (CAT) declared that a candidate who has not studied English as a subject in B.A. but has done MA (English) is qualified to be appointed as TGT (English).

The candidature of Ms. Rinku Singh, who appeared in Delhi Subordinate Services Selection Board (DSSSB) examination for appointment on the post of TGT (English), was rejected by the DSSSB on the ground that she had not studied English as a subject in all the years of graduation. Being aggrieved by her rejection of candidature, Ms. Rinku Singh filed an Original Application [O.A. No. 2950/2016] before the Central Administrative Tribunal, Principal Bench, Delhi (CAT).

Anuj Aggarwal, Advocate, counsel for Ms. Rinku Singh, argued that Ms. Rinku Singh has done M.A. (English), which is a higher qualification, and was, therefore, better qualified that the qualifications prescribed in the Recruitment Rules for the post of TGT (English) in Director of Education, GNCTD.

CAT’s Bench, comprising of Hon'ble Mr. Justice Permod Kohli [Chairman] and Hon'ble Ms. Praveen Mahajan [Member (A)], accepted the argument of Mr. Anuj Aggarwal, Advocate and declared that Ms. Rinku Singh was qualified for being appointed on the post of TGT (English) and directed the DSSSB to forward her dossier to the Directorate of Education, Govt. of NCT of Delhi, for appointment. CAT further held that Ms. Rinku Singh was entitled to all the consequential benefits including seniority and pay fixation.

http://www.advocateanujaggarwal.com/home.php