The City School 26th May,

2022
31 Industrial Area Without
Prejudice
Gurumangat Road, Gulberg III
Lahore, Pakistan.

Attn:

Dr. Farzana Feroz

MD

Mr. Aurangzeb Feroz

CEO

Sub: LEGAL NOTICE

We represent Mr. Bilal Jan s/o Naeem Jan (the “Client”) and on his
instructions we are hereby serving you the Legal Notice as follows:

1- That our Client resides in Lahore and holds a reputable qualification of

Master Degree (Leadership/Management/Buisness Administration) or
Equivalent. Apart from that our Client has a 10 years of experience in
multiple industries and is known for his dignity and hard work which is
evident from his previous exceptional services.

2- That in October of the year 2020 our Client was selected on merit to
serve in position of a Assistant Regional Director in your School at
Lahore Branch and since then he is performing his duty vigilantly, up to
the mark and has provided well credited services to the School e.g.
“Formulates the strategic plans, coordinate, plans and develops
business expansion projects, Supports the reginal director to eliminate
any potential barriers, facilitate the School heads, liaises closely with
the GMAs, ensures budgetary compliance in relation to
schools/Departments in the region etc, so on. Albeit due to your
internal organizational issues and negative attitude of the staff, the
same was managed so well.

3- That your School’s administration issued an appointment letter/

confirmation of services (the “Letter”) dated 8th June, 2021 which
clearly states the terms/ conditions and other employment rules
regarding the position of our Client.
4- That prima facie perusal of the Letter reveals that our Client was appointed
w.e.f. 12th April 2021 as Assistant regional Director in your school and on annual
package (CTC) of Rs. 5,564,856/- (Five million five hundred sixty-four thousand eight
hundred fifty-six only).

5- That our Client is performing all of his duties as per the job description assigned to him
and satisfactions to the heads of the departments of your School and as per
responsibilities assigned to him time to time. Our Client's up to mark performance has
earned him recognition in your eyes that you rely on him too much and most of the tasks
are awarded to him with time.

6- That our Client is still associated with your school and performing his duties well under
your employment but you are not paying his Salary regularly since last two months. It is
pertinent to mention here that the HR sends the payrole schedule to the accounts
department and then the concerned department generates the relevant list of the payroll
and it comes on 20th of every month in the data and when our Client came to know that
his salary/payroll didn’t mention in the data/material of the computers of the School in a
last month then he informed to the authorities of the School and they didn’t give any
response on time which resultantly our Client perished because of his
non-payment of salary.

7- That our Client visited your office from time to time for payment and even called you
many times but You refused to pay and resultantly a lump sum amount of Rs.
……………….. is pending on your part which our client spent while doing work in your
school.

8- That it was due to your ulterior motives and mala-fide intentions that
you never communicated a word back to our Client after the lapse of
two months which for your information refers to the confirmation of
giving the actual pay with extra amount and interest by the rules and
laws set by the Honorable Superior Courts.

9- That the conspiracy that was choreographed earlier by you and

hatched later that on _______after a lapse of two months you still did
not communicate to our Client and this heinous action shows your real
intentions behind it that our Client would resign from the School and
you wouldn’t have to pay the salary to our Client.

10- That it is quite clear through your actions that you’re forcing and
intimidating our Client to leave and resign from the position
tantamount to the breach of laws at one hand and completely goes in
adverse with the business ethics and norms.

11- That it is because of your unscrupulous and unprofessional

attitude that the reputation along with physical, mental and emotional
health of our Client is at stake.
In light of the above mentioned you are in breach of the certain laws
including but not limited to

the following:

A. That you have breached the provisions of Contract Act and hence are
liable under the law of Contract for payments of the salary and the
damages because of harassing mentally to our Client together with
cost of funds including but not limited to the cost of this legal notice
and consultation fee etc.; and

B. That you are grossly negligent in making payment/salary and such

negligence amounts to recklessness and hence you are liable to pay
full two months’ salary with interest and damages to our Client under
the law of torts.

Therefore, in view of the above, you are being served with this Legal Notice
under the law of Contract and Principles of master and servant relationship.
You have 7 days ipso facto from the issuance of this Legal Notice to accept
and fulfill the righteous either to make the payment of Outstanding Amounts
and Damages plus liquidated damages, cost of funds and damages suffered
by our Client amounting to Rs. ______________/-
(__________________________________________). For that matter it is incumbent
upon you to know that in case of any such non-compliance it is mandatory
for you to fulfill the legal demand of full salary with interest…….. as laid in
the laws and evident from your Letter. You are therefore given a chance to
refrain from your illegal actions and serve this Notice or in other situation
grant a triple salary with interest in lieu thereof to our Client in order to
comply with the immediate effect of the termination. Hence you are
beforehand once and for all times warned to stop your wild goose chase and
do not dare approach our Client with your illicit actions. It shall specifically be
noted that in case of the lack of compliance with this legal notice on your
part our Client has given us clear instructions to file the suit for damages by
initiating legal proceedings at your risk and costs

Without prejudice to the above said you are further directed to resolve the
matter in the form of positive answer as to how you intend to proceed with
our Client. Nothing herein contained shall be deemed to constitute a waiver
of any of the rights of our Client or his nominees/representatives. The
contents of this legal notice are not exhaustive and we reserve our rights to
raise further issues/points. This legal notice is limited to breach of
employment rights of our Client.

We have retained a copy of this Legal Notice for record and future reference
should the same be necessary.

Sincerely yours,

Mahnoor Nazir
Advocate High Court
For

Zia & Shah

CC:

Syed Moazzam Ali shah

Advocate Supreme court

HR Department of City School