Dear friends,
At the call of our Federation a mass signature campaign address to the Cabinat Secretary, Chairman of the Empowered Committee for 7th CPC has been adopted by our Association. Please get a print out of the following draft and send it with your signature in duplicate for onward transmission through the proper channel:-
To,
The Cabinet
Secretary,
Chairman,
Empowered Committee of Secretaries, Cabinet Secretariat,
Rashtrapathi Bhawan,
New Delhi 110001.
(Through
Proper Channel)
Sub:
Upgradation of Pay for AO/Sr.AO
Sir,
I--------------------------------------------------member
of P&T Audit Officers’ & Sr.
Audit Officers’ Association submits the memorandum for the kind consideration
of Empowered Committee of Secretaries. The AOs and SAOs, who are the cutting
edge of the IA&AD, have been denied their genuine demand. The only
appreciable thing that the 7th CPC has done for the IA&AD is the
recommendation to upgrade the GP of `Rs. 4,800 to ` Rs.5,400 (from level 8 to 9
as per 7th CPC recommendation in Para No.11.12.140) on completion of four years
in the cadre of AAOs. The 7th CPC treats the cadre of SAOs as the feeder cadre
for induction into IA&AS. It also notes that both SAOs and the entry level
pay of IA&AS for induction into IA&AS are equal. 7th CPC notes that
SAOs and Direct entry IAAS cadre are in the same Grade pay. None the less, it
concludes that the SAOs are a feeder cadre to the IA&AS despite being aware
that the Entry level grade pay and that of the SAOs are the same. It
conspicuously ignores that, the grade pay, by its very definition, determines
the relative position in the department. Thus, it is our considered submission,
Sir, that the cadres of the SAOs and the JTS cadre of I.A.A.S are relatively
placed at the same position. SAOs are indeed the feeder cadre for STS Cadres
such as Dy.Accountant General/ Dy.Director of Indian Audit and Accounts
Department and not to the JTO. Thus the present practice of inducting the SAOs
to the entry Cadre of IA&AS is indeed an injustice as they cannot be
‘promoted’ to the same relative position in the department. When they got
promotion or when they got upgraded they need to be inducted into Group A cadre
at the higher level. This is supported by the fact that the Entry Cadre of
IA&AS in the JTS does not supervise the Audit/Accounts officers and
Sr.Audit/Accounts officer in IA&AD. JTS officers are treated as
probationers and they learn work from the department during that tenure and are
posted against the post of A.Os/Sr.A.Os only. In fact, the Junior Time Scale
(JTS) officers as well as the SAOs are supervised administratively by the
Sr.Time Scale (STS) Officers only. The AOs/Sr.AOs cadre is a technical cadre.
They are the back bone of this department in handling the work scientifically,
in respect of public accountability mechanism. In many of the audits these
cadres have a better cutting edge than the Chartered Accountants. This cadre
absorbs the developments in audit functions as well as accounts function in the
international arena and they are in the process of continuously developing
their domain knowledge for the purpose of discharging their functions.
Comparing this cadre with the entry Cadre of IAAS and to next level Cadre of
Sr.Time Scale Cadre is against the canon of natural Justice. The Globalization
of Indian economy and consequent entry of foreign Chartered Accountants firms
and Tax Consultancy services and exposure of the Supreme audit Institution of
India, to the Global/Regional Audit Institutions has resulted in the
technological upgradation of the department with additional content to
Audit/Accounting activity, to meet the Global Competition. The introduction of
the Voucher Level Computerization (VLC), the time bound implementation of the
Ghosh Committee recommendations on the Government Accounting System, the introduction
of online audit system of the Computerized Accounting data presented by the
auditee Institutions, the introduction of New Company bill, the development in
Audit Assurance standards, Reporting standards, introduction of Financial
Accounting Standards, Scheme Reviews, Performance Audit and the undertaking of
the Audit of Panchayat Raj Institution and Urban Local Bodies as recommended by
11th finance commission has resulted in enormous technical upgradation and
resulting in additional workload on the cadre of Accounts/Audit officer
particularly due to the absence of appreciable increase in the cadre strength.
The additional skills acquired have to be recognized and compensated
adequately. The C&AG, when his opinion was sought under article 148 (5) regarding
CCS (CCA) Rules, 1965- classification of posts of Sr.AOs consequent upon
notification of Central Civil Services (Revised Pay) Rules, 2008, on
31.03.2009, opined, “We have no objection to the revised classification of
posts as proposed in the draft order forwarded with the above U.O. Note. We
may, however, also refer to the correspondence resting with the D.O. letter of
Shri.V.N.Kaul, former C&AG vide No.58-CAG/2002/24-GE/01 dated June 13, 2002
to Shri.A.K.Agarwal, the then Secretary, Ministry of Personnel, Public
Grievances & Pensions (Department of Personnel & Training), and stated
that this department fully supports inclusion of the posts of Sr.AOs in the
Group ‘A’ posts. However, in view of the large magnitude of the cadre of Sr.AOs
in this department as well as Finance & Accounts Departments of the
Government of India, this classification would present some practical
difficulties in the initial states of implementation of this decision. This
department would, therefore, need some time to streamline procedures for
implementation of new classification of Sr.AOs. We accordingly propose that a
general purpose proviso may be built in the body of the proposed order that
gives departments an opinion to propose exclusion of certain posts or
categories of posts from the groups to which they would ordinarily relate to.
This department would like to urge emphatically that no specific exceptions
should be built in the body of Government Order or otherwise, to deny, per-se,
Group’A’ status to Sr.AOs of this department unilaterally”. This fact needs
specific consideration of the Government while fixing the pay levels to AOs and
Sr.AOs. It is our request that this aspect may also be brought to the attention
of the Government while commenting on the recommendations of the CPC. It is our
considered opinion that the injustice is repeatedly perpetrated because of the
insistence on treating the SAOs as Group B Gazetted officers. Audit
Officers/Senior Audit Officers deal with the auditee organizations at a fairly
high level and the lack of appropriate status hinders their functional
effectiveness. They have to come to this level after passing a very rigorous
and difficult examination and a tough selection procedure. They constitute the
backbone of the Indian Audit Department. . The category of these officers
constitutes the fifth rung in the hierarchy of the Indian Audit and Accounts
department. The Fourth CPC and the successive pay commissions have done great
injustice to this category of Officers by not giving them the appropriate scale
of pay and Status. In view of the unique position assigned by the Constitution
of India to Audit, similar demands, if any, made by other departments will not
be on the same footing. Retaining these cadres in the lower level, while their
peers in other departments are placed in the higher cadre results in treating
equals in an unequal manner which is contrary to Article 14 of the Constitution
of India. Under Article 148(5), the conditions of services of the persons
working under the C&AG of India should be fixed in consultation with him.
On 7-4-2011 a letter was sent by the C&AG to the DOPT seeking their consent
for classifying the Senior Audit & Accounts Officers/Sr Divisional Accounts
Officers (in PB-3 Grade Pay of Rs. 5400/-) as Group A in terms of Government of
India Gazette Notification dated 9-4-2009. The refusal to reclassify these
cadres as Group ‘A’, therefore, constitutes an infringement of Article 148(5)
of the Constitution of India. Further, the Status of Sr.AOs of the Indian Audit
and Accounts Department has also been examined by the Honourable Bench of High
Court of Delhi in the Writ Petition (Civil) 2698/2013 filed by the All India
Audit and Accounts Officers Association Versus Union of India and others. The
High Court held “Accordingly, the impugned order of the CAT dated 10.12.2012,
as also the Office Memoranda of the Central Government dated 11.4.2011,
17.6.2011 and 7.7.2011, which deny the petitioners classification as Group A
officers along- with the attendant benefits, are liable to be set aside as
unreasonable and arbitrary given the clear textual mandate of the relevant
rules. Thus, the classification of Senior Audit and Senior Accounts officers as
Group ‘A’ officers is mandated under the applicable rules.” This fact has been ignored
by the CPC. It has failed to treat the SAOs on par with the Group A officers
with out any valid ground for placing them on a lower level. Based on their job
content and judicial decisions including Arbitration award of extending parity
between Central Secretariat and IA&AD the AOs and Sr.AOs of the Department
should be equated with Under Secretary and Deputy Secretary of Central
Secretariat in pay Level and status. Even as per the arguments of the 7th CPC
for denial of upgradation of pay scales demanded by this Association, the AAOs
are the feeder cadre for AOs/SAOs. This has placed the AAOs (who completed four
years of service in AAO cadre) and the AOs (on functional promotion as AO from
the cadre of AAO) at level 9 creating an anomalous situation affecting the
vertical relativity of cadres. This further justifies our demand that the AOs
and the SAOs need be placed at a level next higher to the level of AAOs. Since
7th CPC itself agrees that AAO is the feeder cadre of AOs. As the promotion
from AAO to AO is a functional one and involves higher duties and
responsibilities. On this basis also our demand for higher scales and level
stands validated and has to be considered. Taking into the consideration the,
pay scales need to suitably modified and fixed at level 11 for AOs and Level 12
for Sr.AOs. I, Sri/Smt. ......................................... therefore,
urges that the above facts may be considered favourably in respect of the pay
scales of AOs and Sr.AOs of Indian Audit and Accounts Department while firming
up the conclusions for approval of the Cabinet on the recommendations of the
7th CPC. It is the hope of every AO/SAO of IA&AD that the Empowered
Committee of Secretaries would mitigate and not let the injustice continue.
Place:
Date :
Signature Name of the Member Name of the
Association
