STARVED OF JUSTICE

   I,  the undersigned, Ms Kothakota Ashalata hereinafter referred  to as the petitioner  aged 44 yrs  d/o Mr. Kothakota Prabhakar r/o rented flat 403 Gharonda Veera Apts., Padmaraonagar, #6-1-108, secunderabad-500 025, Andhra Pradesh, India, do solemnly oath the following petition in chronological order to conduct an enquiry and eventually   file a writ petition against 

Respondent No:1  The Assistant General Manager, Sri Y Ranganathan State Bank Of Hyderabad, Habsiguda branch Hyd-7, A.P. ;
Respondent No:2 The Manager Relations  S. Pasupathi State Bank Of Hyderabad, Habsiguda branch Hyd-7,A.P.;
Respondent No:3 The Deputy General Manager B.Vithal Rao presently Ms Hamsni Menon, State Bank Of Hyderabad, Begumpet Zonal Office(S)  Hyd-16;
Respondent No:4 The General Manager (operations), Sri C V Krishna Kumar, SBH Head Office, Gunfoundry, Hyd-500001.

Respondent No:5 The General Manager (Inspections) Sri R Muralikrishna Rao, SBH Head Office, Gunfoundry.

Respondent No:6 The Deputy General Manager (Inspections) Sri S Sunder, SBH Inspection Dept., Head Office, Gunfoundry. 

30-09-1986      The petitioner recruited through the BSRB   and posted as a Typist/Clerk to SBH Icrisat Branch Patancheru Medak Dist. A.P. Instances  wherein the petitioner was subjected to cruelty and discriminaton. She was allotted office order to handle over 50 ledgers alone and that too standing during the four business hours while dealing with the posting of cheques/withdrawals and such other work. The Union branch secretaries would callously respond a two syllables Get Out or Go Home or Donot Work. The petitioner would weep inconsolably at such cruel treatment and suffered from severe joint pains and  back pain. It is to point out that the petitioner has earnestly and diligently struck at her office work even doing overtime and returning home late into the night i.e. 8.30p.m. or so. The SBH had not raised any objections at the time of her recruitment. Thereafter too, the SBH had not had any controversial issues with the petitioner. However the petitioner was inhumanely discriminated in regard to her Transfer in Medak Dist., wherein the petitioner had worked at three branches namely Icrisat Branch(30-09-1986 to 09-05-1995); Ramachandrapuram branch (10-05-1995 to 10-11-2000) and Zaheerabad branch (11-11-2000 to 03-09-2002). There had also been an incident wherein the lady branch manager named Nirmala had once instructed the security guard to lock the main door and disallow her from exiting well after working hours. Thereafter the petitioner was coerced to sign typed paper and denied the right to information about her career.

09-05-1995    The petitioner was redesignated as Data Entry Computer Operator (DECO) after qualifying from a written exam conducted by the bank and posted as ALPM Operator cum DECO to Ramachandrapuram Branch. The selection of DECO caused friction and disharmony among the staff and the seniors felt cheated of the special allowance.  At the Ramachandrapuram branch the petitioner was shocked to find the customers in inebriated conditions resorting to filthy and abusive languages . There were also instances of sexual harrassments and the same is irrelevant in the present context. However the branch secretary and others were sober towards her until one Ramaraju Manager Accounts reported  at the branch   and turned out prejudices antagonised and framed false charges against the petitioner for whatever vile reasons to create a scope  for exploitations out of her vulnerability.  The said Manager was habituated to disallow the petitioner from discharging her duty and send her home  without a valid or good reason or any notice  until the Union Office intervened that too only after repeated visits to the Head Offices and Union Offices and after inconsolable weeping.

10-11-2000  However the injustice of transferring the petitioner to Zahirabad branch located on the borders of Karnataka and Maharashtra while all her batchmates were being promoted or transferred towards branches in city is vindicative of the discrimination and hatred shown towards the petitioner for  whatever  baseless  grudge held by the perpetrators of such callous shown to the petitioner. At the Zahirabad branch the petitioner was mentally tortured with abusive threats by the acting branch manager Krishnamurthy who would not allow her to work  and he would simply snatch the registers from the petitioners hands abusing filthy words without any cause for provocation. Prior to him the branch manager Mr Thakur was alright but she was denied access to computer eventhough designated as the computer operator and was loaded with manual work such as the despatch work, the govt. challans scrolls that would exceed 100 on an average and that needed to be tallied, the transfer scroll, balancing of ledgers and miscellaneous. The petitioner was commutting long distance and was exposed to all pollutions industrial, traffic and noise pollutions that effected her health condition besides improper inadequate diet.

In March 2002 the letter no:F/357 dt 14/3/02 signed by the Branch Manager Subhash Kulkarni of Zahirabad branch to the AGM Reg-III seeking eligibility to release the salaries of the petitioner held in sundry deposit account has so far been ignored and kept in cold storage with malicious intent to deprive her monetary benefits and thus torment her. From 2002 till date the leave records and the mentioned salaries are kept in pendency exceeding the normal timeframe ignoring all her representations. However since then all the corelated benefits were deprived to her and she was unjustifiably discriminated over the pretext that the leave record was not set right. The Habsiguda branch failed to set right the leave position and indulged in random and whimisical deduction of salary in a fanciful manner. The representations dt.13/2/03; 08/10/02;30/11/02;12/12/03; 02/1/04;12/4/04;14/9/04;29/9/04;12/6/04 vie reg a 3696);10/2/05;vie SP EE626554147 IN t15/3/05;27/5/05;08/6/05;11/10/05 (acknowledged by the present AGM);20/6/05'11/11/05;24/11/05(ack by the Mgr Accts)were submitted by the petitioner but till date kept in pendency with malicious intent to torment her. The Establishment Clerk named Shanti would audaciously reply to the petitioners queries about her increment stating that the petitoner should be satisfied that she is being paid salary as if the bank is offering charity to the petitioner and not extracting work.

April 2002 The letter dt18/4/02 vide RlF1342 dt20/4/02 to the Chief General Manager; RL AD F1343 dt20/4/02 to the Asst Genl Mgr SBH Zonal Office (S) did not evoke any response but the petitoner had to succumb to coercions, conditions, threats and abuses. The letters dated 18/4/02 & 16/8/02 offered a detailed complaint against the bank official Krishnamurthy who was the then acting Branch Manager at Zahirabad branch and who indulged in perverse and abusive harrassment towards the petitioner for whatever vile reasons. The NSC's of the petitioner held as securities against the Overdraft account were misplaced at the time of maturity and caused undue delay in their realisation. Despite several representations to the higher authorities and the Associations, the said Offices simply did not bother to conduct an enquiry or respond to her genuine grievance.

In August 2002 the petitioner was diagonised with uterine fibroids which again gave the Managers an opportunity to harrass her. She was confined in the cabin and put embarrassing questions about gynic conditions even after she had submitted all the medical reports.The letter dt16/8/02 sent vide RL AD B5517 dt17/8/-2 to SBH Zahirabad branch and RL AD B5516 dt17/8/02 to the Ch Genl Mgr Ranjit Singh Nanda also proved a vain effort to seek solutions from the higher authorities because the petitioner had to submitt leave letters as condition to the transfer order issued to the Habsiguda branch and the letter dt 14/3/02 signed and forwarded by the Br Mgr Subhash Kulkarni Zahirabad branch to the Reg-III Zonal Office has also not got any response/action. The petitioner is clearly subjected to monetary loss thus attacking her livelihood.

  
Sept 2002 The petitioner's complaint letter dt20/09/02 vide courier reciept no HYD93718 dt21/09/02 about the incident on 18/9/02 and the fanciful intervention of Managers from other Section/Deptarment to orally instruct and the disharmony caused without cooperation of work from the substaff. The disturbance caused at the petitioner's counter by other staff.

February 2003 The lethargic & lackaidisical nature of the Manager's incharge to a grievance of serious and genuine nature. The letter dt24/2/03 vide RL AD G2392 dt27/02/03.There was this constant common problem with the ATM machine in its initial stages of installations that provoked regular and several complaints from several customers.

April 2003 The inhumane and sadistic harrassment by the Security Guards towards the petitioner in particular is expressed in her complaint letter dt15/4/03 vide courier reciept HYD7864622 dt16/4/03.The sadistic mischief by some Security Guards to switch off the lights, fan, & aircooler that too during summer and thus disturb the petitioner from her work and indulge in threatening arguments.

May 2003 The letter dt23/5/03 offers the disturbance and intervention caused by customer's and other section staff to handle papers/cheques kept on the petitioner's counter. The improper mingling and handling of papers (cheques, passbooks etc.) kept on the petitioner's desk and the violent gesture of throwing them around while indulging in verbal attacks is totally unwarranted and uncalled for. Yet the bank staff do not bother to intervene and check the unlawful menace. It is a clear case of deliberate harrassment and discrimination shown towards her.

July 2003 The aggressive and violent nature of few customers accustomed to preferential treatment/service by predecessors at the counter is revealed in her complaint lr. dt08/7/2003 sent vide Reciept No:HYD7425946 dt11/7/03. Here again a few customers begin to demand priority and resort to violent handling of papers kept on the desk and such physical aggressive gestures are not checked by the Security Guards or others.

Aug 2003 The grudgeful nature of a few substaff as complained in the letter dt11/8/03 or 21/8/03 vide reciept no HYD7878367 dt19/8/03. Always refusal to attend work at the counter by the substaff and thereafter indulge in threatening arguments. The letter dt16/8/03 sent vide RL AD4343 dt20/8/03 to the AGM SBH Zonal office Begumpet reveals the habitual nature of the Officials to disallow the petitioner from discharging her duty and who all are unempowered to do so. The preplanned disturbance caused by a few customers to gherao the counter, or turn her into a scapegoat and begin to threaten the petitioner without any relevance or any cause for provocation. Because the petitioner's work is corelated with the Officer's and others work to impart service to the customer.

Sept 2003 The letter dt16/9/03 vide RL AD2714 against one Bharath Kumar Reddy who had intentionally misbehaved is a customer who had opened his account introduced by a SBH employee. Thereby the customer acquainted with the bank employee who had offered introduction in the account opening form was instigated to sexually harrass her. The customer named Bharath Kumar deliberately bent his head between her chest and the monitor to view the his account displayed and there was unnecessary physical contact. The customer ought to transact over the counter and not indulge in unnecessary physical contact.

May 2005 The letter dt18/5/05 against the Security Guard who had also choosen 10th Jan.'05 to harrass the petitioner in a similar manner but the previous AGM Y S Patil was not prejudiced to interfere with her personal matters or any concocted cock & bull story governing on her birthday i.e. the 10th January to restrain her unlawfully from work alike the present Respondent No1, 2 & 3 who all are politically biased and with an ulterior motive to restrain her from work on the 10th January. Conclusively it is to point out that the petitioner had faced a threat on 10/01/05, caused by the said security guard K S N Charyulu but he was not encouraged by the previous AGM. There is clearly a motivated bias to discriminate and harrass the petitioner only on the 10th January i.e. her birthday. The biased security guard without any cause blocked the petitioner's path from entering the banking premises and indulged in verbal attack without any cause for provocation but with malicious intent to humiliate and harrass her. The said Respondents have misused and abused their position by resorting to unlawfull dismissal after framing false allegations and thereafter their denial to restraint the petitioner physically from discharging her duty.

June - July 2005: The petitioner had also served legal notice dated 27/06/05 sent vide RL AD A3600 dt29/6/05 to the Respondent No:1 and under certificate of posting to Respondent No:5 (the General Manager (Operations), H.O. Gunfoundry in regard to the arrears on pay hike and corelated emoluments deprived to her through the enclosed legal notice dt27/6/05. But she was threatened of dire consequences and restrained from work. Ultimately the petitoner was coerced into submitting a withdrawal letter dt27/7/05 that she would not file a legal case in the matter.

Oct 2005 The Responent Nos1 & 2 are habituated to call the petitioner into the cabin and probe into her personal life enquiring about her marital status etc. The factual reality is that the petitioner is a single divorcee out of a two month old arranged marriage to Gregory Jesudass in 1989 and is staying alone since then out of circumstances and not out of choice. Thereby the petitoner has always responded stating that her personal life is a vacuum. The factual reality is that the petitoner has spent all her young age commutting long distance exposed to all pollutions and has an unblemished and spotless reputation spending her leisure time with her pets and she is also a member with the Blue Cross of Hyderabad.

Nov. 2005: The letter dt05/11/05 sent vide courier reciept noHYD1776863 dt08/11/05 wherein a mob was set upon the petitioner when she was denied access to the computer by the Manager with a premeditated plan to create ruckus in the banking hall. The petitioner was turned into a scapegoat because the related Managers denied her access to the computer while misleading the customers at the counter that she was wilfully delaying and refusing to work. Also she was harrassed to be misled about the Dipavali holiday on 31/10/05 instead of 01/11/05 by the staff.

The letter dt07/11/05 is a series of an organised crime act and reveals the premeditated conspiracy to create a nuisance at the counter in connivance with other biased staff. The challan remitters shouting about the delay caused. Please note that the petitioner alone cannot be held responsible for the movement and passing of the challans and if deliberately delayed by the passing official or the substaff in its movement. But as a DECO facing the customer's the petitioner was being turned into a scapegoat to damage her career life and create bad impression. All the petitioner's complaints laments the rowdism and excessive pressure at work deliberately caused to mentally torment her. The petitioners counter was far away from the signing officials seat besides the cash counter was at another end. There was deliberate delay caused in signing by the officials or in the movement by the substaff thus turning the petitioner seated at the counter into a scapegoat. A show of deliberate mis management to create a bad impression.

On 11th Nov 2005 in total disregard to the petitioner's age one Venkataiah a retired RTC employee remitter of (regn recpt no:164638 for P.Srinivas) r/o 1-3-83/391D/7 Kavadiguda Secunderabad deliberately passed obscene comments about her physique stating in slang telugu that there is no meat on her body. However nobody had intervened to support the petitioner even after her complaint with the Respondent No:1. There is evidently sexual harrassment unabated and unchecked. It is the petitioner's performance of work that should matter and not the size of her breasts or her slim physical structure commented in a direct or indirect manner. The said person also indulged in rowdism and threatened the petitioner of dire consequences on the road. 

In total disregard to her age there have been several incident wherein the petitioner was physically collided against by men both public and staff, as if accidentally. But there was an always amused laughter by a group of persons nearby both staff and others watching the dashing against her. There is evidentally sexual pervertism and inhumane jeering instead of support. The harrassments are not merely sexual but vehemently sadistic perverse and grudgeful.

The letter dt13/11/05 is the reply to the memo F/1/298 dt12/1/05 and again a conspiracy hatched by the Mgrs to damage her career life in a consequential and preplanned manner. The letter also complains against one Texo Tailors who is friendly with some staff at the habsiguda branch so as to connive and cause nuisance at the counter to harrass the petitioner with false allegations.

    
Nov 2005 The Respondents   began to fabricate, discriminate and falsely allege over petty matters pertaining to the petitioner's discharge of service and began to issue memo F/1/298 t12/11/05. To which the petitioner had suitably replied.

On 14/11/05 an office order shifting the petitioner to the despatch section was issued. The petitioner acknowledged and continued her work as the Despatch Section Clerk. However in her complaint letter dt19/11/05 vide regd AD1701 dt21/11/05 is clear indication of discrimination to deny her access to the computer.

December 2005: Thereafter the letter dt22/12/05 to the Genl Secretary AIBEA vide courier receipt nos:HYD182034 & 182035 dt04/1/06 and copy to the AIBOA had also not evoked any response till date. The AIBEA has deducted the yearly subscription and also the strike day salary but evidently a breach of trust and contract when they have failed to represent her grievance and offer justice is clear indication of discriminatory and stepmotherly treatment towards the petitioner.

On 27/12/2005 the complaint letter duly acknowledged by the Respondent No:1 was not taken into cognizance and neither action or enquiry conducted upon.
 On 27th Dec.'05 the Respondent No:2 reacted boisterously in a violent manner when the Petitioner had complained against the Term Deposit Section Clerk Sridhar of the 1998 batch that he had refused to renew her receipt and was replying in a rude manner prompting her to complain. In view of the recurring frauds in the branch the petitioner was naturally anxious that the computer generated number was not incorporated and thereby orally complained to the Respondent No:2. Initially he ignored her but afterwards began to abuse saying shut up & get out. Even before the petitioner could respond or complete her sentence he pounced on her to assault but he was withheld by other staff. Whether as a staff or a customer the Respondent No:2 is responsible to attend to the grievance instead he ran out of the bank exit calling out to the petitioner to challenge him on the road. However, the petitioner remained unprovoked and calm. She pointed out that she is not a rowdy to indulge in fist blows that too with the opposite sex. The petitioner on the contrary was reticent and considered the incident as a obscene and shameful to the bank as a whole.

Thereafter the Respondent No:1 & 2 began to vent their grudge on her by fabricating charges. On 30th Dec.'05 the petitioner was persistently called into the cabin over an unrelated issue in the midst of a load of deskwork. She was forced to work overtime to complete the task due to constant disturbance caused by the Respondent Nos:1 & 2.The false allegation that she refused to work is a sham because the section record books and register vindicate the work entered by the petitioner in her handwriting, thus contradicting the false charges by the Respondent nos:1 & 2. Ironically, none of the immediate sections officers namely, Sitaramulu, Venkatadri or Ramesh complained and were satisfied with her work and full of praise.

January 2006: Once again suddenly on the 9th January 2006 at 3p.m. the Respondent No:2 called the petitioner inside his cabin and put a bombshell that he will not allow her to sign in the attendance register  tantamounting to unauthorised dismissal of the petitioner. The petitoner yet again remained calm and unprovoked. She expressed her resentment to be disparagingly discriminated and sought time to be represented by the Association leaders. She had also sought a written explaination routed through proper channel. But all her  decent entitlements were denied and on the 10th Jan.'06 the Respondent nos:1 & 2 didnot allow her to sign the attendance register. They began to instruct the security guard to physically throw her out of the desk chair. Thereafter the petitioner putforth her grievance to the higher authorities and the AIBEA (union). However there has not been any favourable intervention. There is evidently breach of trust and contract on the part of the AIBEA represented by the branch secretary Koteshwar Rao and the joint secy. Raghavan when they simply failed to represent her or intervene when the Respondents had resorted to unlawfull strategies to dismiss the petitioner from earning her livelihood, for whatever bias or grudge held. There is evidently a step motherly treatment shown towards the petitioner by the Union leaders eventhough they have deducted the yearly subscription and the strike day salary.

Thereafter the petitioner had shelled out Rs.1000/= to engage an advocate V S Yadav to serve a legal notice dt13/01/06 sent vide regd RL AD 3214 dt13/01/06 to the Respondent No:3 and RL AD 3212 dt13/1/06 to the Respondent No:1. However the Respondents had the audacity to disrespect the judicial system and responded taking their own time that too with two memos addressed to the petitioner instead of actual reply to the legal notice. At the same time the Respondents have misused and abused their positions by marking absent against the name of the petitioner in the attendance register. The presence of the petitioner in the branch premises on  10/1/06; 12/1/06 and other dates can be viewed from the video recordings recorded by the camera placed near the single window counter as well as the withdrawals transacted by the petitioner. As the petitioner does not have an alternative source of income she had filed a petition seeking legal aid or councellor on 19/01/2006. But again the Respondents had the temerity to respond in their own time exceeding the prescribed timeframe and to deny their unlawful restraint imposed on the petitioner with malicious intent to torment her. The above said Advocate began to demand a huge fees for filing of the petition. So the petitioner had to approach the Andhra Pradesh State Legal Services Authority and they simply failed to offer the legal service.

March 2006: To continue with their malafide exercise of authority by the Respondents on the 15th March 2006, it is to further submit that the petitoner was allowed to sign in the attendance register by the Manager Accts Vasanth Kumar  who said that he was on sick leave and  did not object the petitioner from signing over the false remark and the unlawful restriction placed by the Respondent No:1 & 2. But suddenly another Officer named Satyanarayana who is not related or authorised in any way intervened and began to bias and influence the Mgr Accts Vasanth Kumar to restrict the petitioner from signing the register or working at the branch. This Satyanarayana eventhough unrelated and unempowered began to threaten the petitioner of dire consequences and informed the petitoner to get the orders from the Court to sign and work at the branch. Thereafter the said Mgr Accts simply snatched away the attendance register. Thereafter yet again the petitioner was repeatedly told to approach the Respondent No:1 in the cabin without a  representative from the branch association. They began to harass the petitioner to submit leave letters from 09/01/2006 as a condition. The recorded conversation in her cellphone in parts clearly spells the condition imposed on the petitioner contradicting their reply to the notice or copy of the petition by the Legal Services Committee/Authority. It was a humilaiatory and inhumane treatment of the petitioner at the habsiguda branch. It is crystal clear vindication of the sexually perverted and sadistic outlook nurtured towards the petitioner and to subject her to dance to their whims and fancies by making a mockery of her vulnerability. They attempt to malign her reputation or damage her career life and cause abject monetary loss is evident in the atrocious and outrageous behaviour to show extreme leniency and then the sudden violent act of snatching the register from her hand. The sexually motivated teasing is mild to sadism in an organised manner to mock at the petitioner and turn her into a laughing stock. On the other hand the step motherly treatment of the AIBEA (Union) towards the petitioner is evident that the Association has failed to respond to her complaint dt10/1/06 or represent her even after acknowledging the same. However the AIBEA has deducted the yearly subscription and the strike day salary from the petitioner's account which is a breach of trust and contract.

April 2006: Again, another stage was set up to harass and humiliate the petitioner. A letter no:F/Inspecn/926 dt25/04/2006 signed by the Deputy General Manager Rajni Mishra was received asking her to personally visit the said DGM Rajni Mishra. The outcome of the personal discussion was positive and the petitioner was allowed to sign the attendance register on 13-05-06 but without allotting any work or counter to her. However from 15th May %u201906 the next working day she was physically threatened and unlawfully restrained from signing the attendance register. Thereafter the petitioner yet again mailed more than three letters to the said DGM Rajni Mishra and the General Manager (Op) Head Office vide regd posts RL AD%u2019s  4210 & 4211 dt15/5/06 and 1899 dt23/6/06.   

June 2006:  Thereafter the petitioner had also telephonically complained to the police to conduct a criminal investigation based on her written complaint letter dt13/4/06 to the Director General Of Police in view of the high ranking positions held by the errant bank officials. However the police simply failed to initiate any kind of action whatsoever. Thereby the petitioner was yet again subjected to injustice without any recourse to justice and the bank officials alongwith the Association leaders blocked all kinds of recourse available misusing their posts and hindering justice to the petitioner.  

   Thereafter the petitioner had also submitted representations to the A.P.State Women's Commission as per regd.no:29/06       dated:16/1/06       ,the A.P.State Legal Services Civil Court Premises, Hyd as per acknoledgement dt24/01/06        ;the A.P. State Legal Services Committee in the High Court Building premises as per the acknowledgement dt19/01/06         ; the Regnl Labour Commissioner (Central) Vidyanagar ack dt28/2/06;the National Law Trust as per ackn dt08/03/06        ;the DGP's Office, lakdikapool as per ack. dt13/4/06      ;the Cyberabad Police Commissioner's Office as per ack dt01/06/06      ;the Primie Minister's Office vide fax dt18/3/06 & 15/4/06 ack PM-Id No-6/03/2006-PMP-3/1651107 dt24/4/06;the Collector's Office R.R.Dist.as per ack. dt12/06/06. The suppression of her case is vindicated from the pendency of her case languishing in cold storage at the stated offices since January 2006. What is worst is that the media esp. the news channels have been totally rude and hostile to even look into the injustice done by the State Bank Of Hyd.

The petitioner had also approached the State Information Commission under the RTI Act to clarify her case status at the A.P. State Legal Services Committee and the Cyberabad Police Commissioner's Office, but she has been harrassed and denied the same till date. There is clearly suppression of her case. 

 Last but most important is the representation signed by several staff resenting the hazardous pollution from the toilet and the old diesel generator. There can be serious airborne infections hazardous to health of weaker stamina under the bad working conditions. Please note that most of the staff were forthcoming to sign the representations when affected with a common problem but to feign ignorance otherwise.

The criminal complaint letter dt13/4/06 submitted to the DGP's Office seeks for criminal investigations against the Respondents for the attempted assaultative threats and robbing the livelihood of the petitioner.

September 2006:  However on the 9th September 2006 she had recieved a phone call to offer her statement at the MRO Uppal's office. But on her suggestion that the Revenue Inspector meet her at the Habsiguda branch of the SBH, the said Revenue Inspector obliged. It was then that Prem Kumar Chief Manager Credit Division and the Revenue Inspector together gave her the Transfer Order to Inspection Dept. Head Office in Gunfoundry against her acknowledgement with a remark about her complaint lrs dt10th Jan.'06. The petitioner has not till date succumbed to the conditions enforced unlawfully by the Respondent Nos:1 & 2. The said Respondents had violated and misused their positions by refusing to issue her the Transfer Order and resorted to blackmailing tactics that she should submit sick leave letter from the day that they had unlawfully restrained her from signing the attendance register or discharging her from working at the Habsiguda branch. Thus the said Respondents have robbed her of her salary from that day and even after reporting at the Inspection Dept on the 12th Sept.'06 the matter about her salary and emoluments are in pendency. Here again, the petitioner has submitted her joining letter dated12/09/06 wherein she had also opportuned to remind about her long pending emoluments and the settlement of leave record.

Again in her letter dt21/09/06 duly acknowledged by the Chief Manager Inspection Department Sri Ahilandeshwar, the GM(Op) Sectt., Head Office, the Respondent No:4 and the AIBEA (Union), she had stressed about the work load undertaken and overtime done at the previous branches and also about the long pending emoluments unsettled and unpaid.

Again in her letter dt26/09/2006 sent vide SP EE624794417IN dt26/9/06 to Ms. Rajni Misra, the Deputy General Manager Inspection Department, Head Office Gunfoundry, the petitioner had lamented about the delay and non payment of her salary for the month of September. The petitioner had also stated the rising cost of living and  the unsettled entitlements due to her since 2002.

October 2006: Yet again in her three letters sent vide SP EE 623060922IN dt13/10/06 to the DGM Ms Rajni Misra are dated as follows: 1)12/10/06, the petitioner had lodged a complaint against one head guard P. Radhakrishna who had abused in filthy words such as 'bitch'. There is way of enquiring but the demeaning and deliberate perverse scene to undermine the petitioner and damage her stand as a computer operator with the State Bank Of Hyderabad.(2)12/10/06 reminding about the long pending emoluments overdue since 2002 and the unsettled leave record. Also the outrageous atrocity and injustice done by the Respondents Nos:1 & 2 to rob her of her livelihood. The same letter was also submitted to the GM (Op) Sectt. Head Office Gunfoundry. (3)13/10/06 about the non-participation in the forthcomming strike held on the 27th October 2006 alongwith the lamentation about the injustice done by the Respondents Nos:1 & 2 and also the long overdue emoluments. The same was also duly acknowledged by the AIBEA (Union).

Once again the petitioner has posted a letter dt20/10/06 vide SP EE624725059IN dt20/10/06 to the DGM Ms Rajni Misra aprising about the work and overtime done at the previous branches. Also reminding about the long pending emoluments and also non payment of the salary for October 2006.

In her lr dt30/10/06, the petitioner had expressed her grievance about the discomfort caused due to lack of toilet in the Department located on the first floor. The only toilet on the second floor has damaged and broken toilet without bolts on the inside.  

December2006: In yet another letter dated 26/12/06 addressed to the DGM Inspection Deptt., Ms. Rajni Misra and copies duly acknowledged by the Chief Manager, Inspection Deptt., The G.M.(Op) Sectt., The P.S. to The G.M. (Operations) and the GM (Insp) Head Office complaining against one Official named Chandramohan designated AO about his probing into the petitioner%u2019s personal life and also discriminating her. The letter also reminded about the long pending emoluments entitled to the Petitioner.

Right from the start she did not have a proper counter or seat. The petitioner had to persistently ask for a counter and chair. Also she was denied access to a computer but given miscellaneous manual work of noting files in an index register. It was crystal clear that the said official Chandramohan was bent upon presenting a bad image of the petitioner to the Higher Authorities by denying her a proper work section or a computer.  

January 2007: At last the petitioner received a letter no: F/INSP/GR.VII/4739, dt16/01/07 signed by the DGM (Insp) displaying the concocted leave balance calculated based on the outrageous atrocity and injustice meted out by the Respondents No:1 & 2. The petitioner, therefore despatched a letter dated 19/01/07 vide speed post SP EN621422782IN dated 23/01/07 to the DGM (Insp) grieving about the concocted leave versions putforth by the Respondents No:1 & 2. The petitioner also reminded about the long overdue entitled emoluments unpaid since 2002.  Consecutively, the petitioner received a copy of a letter no:F/INSP/GR.VII/5004A dated 27/01/07, originally addressed to the DGM, Zonal Office(Secunderabad) informing the petitioner to deal directly with the DGM Z.O.(S), Begumpet about the leave balance.

March 2007: The petitioner yet again despatched a letter dated 27/03/07 addressed to the DGM Zonal Office (Secunderabad), Begumpet and copies to the DGM Inspection Department, Head Office, Gunfoundry vide RL AD 5052 dated 28/03/07 and copy to the Secretary, AIBEA, Head Office Premises, Gunfoundry vide RL AD 5053 dated 28/03/07 and a copy to the General Manager (Operations) H.O., Gunfoundry about the long overdue emoluments since 2002 and correction of the leave record because of the outrageous and atrocious injustice done by Y Ranganathan and S. Pasupathi while working at the Habsiguda Branch in 2006.

June 2007 : The petitioner was regularly harassed by the Department A.O named Chandramohan and thus she was compelled to pen her grievance as per letter dated 13/6/07 addressed to the Respondent No:6.

Suddenly a letter no:Insp/Gr.VII/1016 dated 09/06/07 was given to her regarding sanctioning of increment due as per the details mentioned in the aforesaid letter. Following which a part payment of arrears of Rs23428/= (gross) was released as per lr no:F/INSP/GR.VII dated 14/06/07 alongwith annexure of calculation sheet.

July 2007 : The petitioner submitted letter dt 27/07/07 to the Respondent No:7 seeking personal details and other information as originally incorporated in her service file with the Bank. There has not been any response to the letter till date.

Sept. 2007 : Suddenly without any prior notification an amount of Rs8966/= was deducted from the salary paid for Sept. 2007 against the head %u201Cother%u201D without any specific detail. The petitioner submitted a letter dated 27/09/07 to the Respndent No:6 vide RL AD A 9553 dt 28/09/07 enquiring the same. The Respondent No:6 responded in letter No:INSP/GR.VII/3240 dated 01/10/07 specifying the recovery of 12 days salary under the Extra Ordinary leave on loss of pay counting for service was given.

October 2007 : The petitioner was compelled to lodge a police complaint dated 25/10/07 when one Mr Iyappu Parda Saradhi,  Chief Manager of the Personnel Department Head Office alongwith the Security Guard J Krishnaiah had wilfully took the opportunity to put their arms around her waist and push her. The above stated Bank Official had also threatened to disallow the petitioner from withdrawing her money from her Account.   Also another Chief manager named Surendrachary of the Banking Hall had deliberately indulged in physical contact by placing his hand on the petitioners shoulder and thus provoking a scene. The stage was set in a premeditated plan to provoke and misbehave with the petitioner for whatever ulterior motive. The petitioner working at the Inspection Department had merely gone to the Main Banking Hall to withdraw her salary. A group of motivated bank personnel conspired to harass and misbehave with the petitioner. Thereafter the petitioner had represented her grievance through emails dated 26/10/07 to the related Department of the  Reserve Bank Of India and the Grievance Cell of the State Bank Of Hyderabad. But till date there has not been any response instead a Memo in this regard was adversely issued to her, clearly vindicating the grudge, senseless politicization and vile motive against the petitioner.      

Nov. 2007 : The petitioner had availed leave from 05/11/07 to 30/11/07 as per leave lr dt05/11/07 vide RL AD 2811 dt03/11/07 mainly to prepare for bank exam. But failed to do so due to excessive discriminatory harassments. The IIBF (The Indian Institute of Banking & Finance, Chennai) and Iway Sify allotted her a venue in the city outskirts and there again created confusion about the correct exam centre. Again an amount of Rs9096.10 was recovered from the salary paid for November 2007 without any specific details.

December 2007 : Based on the letter dated 17/12/2007 submitted by the petitioner addressed to the Respondent No:6 and copies to the Respondent Nos: 5 & 4, a letter no:F/GR.VII/4437 dt 22/12/07 specifying the leaves was given to the petitioner. The leaves as specified were fabricated by two days even when the petitioner had attended her bank job on 08/12/07 and 11/12/07.

A letter dt 24/12/07 vide SP EN626921189In dt24/12/07 was submitted to the Respondent No:6 and copies marked to the related PS %u2019s of the MD%u2019s Office, The Chief Genl Manager, Respondent Nos: 4 & 5 and to the AIBEA (Union).  Thereafter a lr no:F/INSP/GR.VII/4473A dated 26/12/07 and without the enclosure was given to the petitioner. Also a falsely alleged letter no :F/INSP/GR.VII/4474 dt27/12/07 full of concocted bias about the %u201Cpunctuality%u201D was given to the petitioner. The related Department Official Chandramohan was habituated to pass false remarks against the petitioners name in the attendance register even when she would go out to the toilet or the Main Branch. This bank official got habituated to remark and harass only the petitioner as evident from the Attendance Register.

The petitioner served a legal notice dated 27/12/07 through the Advocate V S Yadav r/o Plot No:123C Bank Colony RKpuram to the Respondent Nos: 4, 5,& 6  and for which there has not been any response. The said Advocate has also cheated the petitioner and has not bothered to respond or proceed further thus offering an incomplete job. Thus the petitioner is starved of justice. Her genuine grievance is suppressed for want of reliable advocates. It is appalling that advocates holding a noble and responsible profession ought to be biased and motivated to cheat a client and deny justice.

January 2008 : However, the Respondent No:6 has begun to harass the petitioner with Memos4465 & 4466 dated 29/12/07 framed with bias, laced with prejudice and malice.  The Respondent No:6 continued with the biased harassment discriminating the petitioner and serving letter nos:4618 & 4619 dt03/01/08 instead of releasing her salary or the increment arrears long overdue. The petitioner has suitably responded to the malafide adverse Memos in her letters dated 02/01/08 and 06/01/08 sent vide SP EN626921970IN dt 07/01/08 to the Respondent No:6 alongwith her leave letter from 08/01/08 due to sudden illness. A copy of the same was also sent vide SP EN 626921966IN dt07/01/08 to R.P. Sinha, The Chief General Manager, SBH, Head Office, Gunfoundry. The same also duly acknowledged by PS%u2019s of the Respondent Nos: 4 &5.

The petitioner resumed her work from 23/01/2008 at the Inspection Department Head Office and yet again was constantly harassed by the Respondent No:6 and the Accounts Officer Chandramohan. They have also instructed the related Office Administration Department to stop payment of her salary for the month of January 2008.

Whenever the petitioner enquirys about her salary, increment arrears or the leave position they fail to reply but continue to harass her with fabricated and exaggerated allegations.    

Conclusively, it is to submit that the Respondents being aware about the petitioner's single status decided to exploit the vulnerability by unauthorised dismissal and thus cheat her of her salary. It is to pray that the aggrieved petitioner should be paid backdated wages alongwith all consequential benefits in the State Bank Of Hyderabad, Habsiguda branch and  offer full opportunity to conduct a probe. It is also to seek wages from 09/01/2006 wherein she was unjustifiably and unlawfully restrained from discharge of her work. It is also to seek payment of the annual increment pending since 2002 and other corelated emoluments due for payment. The Respondents are abusing and misusing their positions to cheat the petitioner of her livelihood. The malafide exercise of authority  to restrain her from discharging  service as a Computer Operator from the 9th January '06 tantamounts to unlawful and unethical dismissal without a highly cogent material is unorthodox to merit acceptance. The drastic and extreme threat by the Respondent no:2 to physically throw her out in the absence of relevant material much less due of any prior proper legal notification and verification, and the exercise of authority has to be treated as a personal ipse dixit and cannot be justified on mere ipse dixit, suspicion, whims, fancies of the said Managers. It has become a routine practise to impose conditions alike blackmail and cause monetary loss by way of loss of pay. The honourable court may summon the staff at the Habsiguda branch namely Prem Kumar (Chief Mgr-Credit Divn), Sitaramulu, Ramesh, Venkatadri (Section Officers, Gyan Kumar, Pushpalata and others as witnesses to malafide exercise of authority. It is to seek your offices to direct the Law Enforcement Officials to initiate criminal proceedings against the Respondents Nos 1 & 2. The petitioner has been punctual, regular and competent in her performance  and the same can be ascertained. The petitioner's action have not been any different from that of her other colleagues yet she was picked to be inhumanely discriminated. The Respondents and other vested interested were unable to incapacitate the petitioner and thus cause loss of pay. Thereby the unauthorized and illegal dismissal without a proper and legal notification prior to the 9th or 10th Jan.%u201906.

The petitioner has suffered monetary loss but even after being allowed to work at the Inspection Department from 12/09/2006, the aforesaid Bank Officials have been constantly harassing her and trying to tarnish her career image. Despite being designated as a Computer Operator, she has not been allowed access to computer or allowed to work on it. Most of the time she has been discriminated and loaded with manual and excess of paper work. Suddenly in the month of December 2007 the Respondent No:6 has orally informed about recoveries  from her increment arrears yet to be paid. It is totally against the principles of law to apply whimsical deductions and recover loss of pay from the increment arrears kept wrongfully pending by the related Bank when they ought to have paid the same immediately after a reasonable time towards sanction and other procedural delays. Instead the entitled emoluments were deliberately kept in cold storage and neglected despite several representations and reminders by the petitioner. It is entirely the Banks fault to withhold the petitioner%u2019s entitlements since 2002.

Keeping in view of her age and the loss of the only source of income it is to claim suitable compensation for the humiliation and monetary loss suffered by the petitioner as deemed fit.

Presently the petitioner is desperately looking for legal advocacy and filing of the writ petition against the State Bank Of Hyderabad. But starved of justice due to want of reliable and reasonable advocates.

PETITIONER : MS KOTHAKOTA ASHALATHA R/o Flat-403 Gharonda Veera Apts Padmaraonagar Secunderabad-25, A.P.
Cell Ph No:9985018029/9912885413