Protest lodged on Property Returns

.
Two organizations, viz. NOINO & BVKS have jointly submitted a protest letter to the ED(P) on the issue of filing of property returns. The letter is reproduced below:
.
22.12.2010.
.
The Executive Director (Personnel),
L.I.C. of India.
.
Respected Madam,

Re: Submission of Property returns
.
We, the undersigned, representing two organizations viz., NOINO & BVKS(Bharatiya Vima Karmachari Sena), wish to draw your attention to the circular issued by your goodself on the above subject on 3.12.2010. The circular makes it mandatory for all Class I Officers of the Corporation to submit their Annual Property returns. In this context, we would like you to consider the following points:-
.
1. The circular dated 3.12.2010 invokes the circular dated 25.04.2008 which in turn invokes the circular dated 23.8.1996. We fail to understand why the need is felt intermittently & what has led the management to invoke the circular at this juncture.
2. We also fail to understand as to why it has been made compulsory only for the Class I Officers to file the property returns when the earlier circulars clearly mentioned that all employees except Class IV employees should file the same. The circular dated 23.08.1996 refers to the Staff Regulations as amended in 1995 which clearly says that all Class I, II, III employees should file the property returns. Whether the Staff regulations have been suitably amended to include only Class I Officers? We feel that this is discriminatory & defies logic. We may make it very clear that it is not our demand that Class II/III employees should also be asked to file the property returns. We are simply saying that application of rules should not be selective. In fact, we feel that it is not necessary to call for the filing of property returns from any employee irrespective of Class & cadre for reasons specified in point no. 8 of this letter.
3. We find it highly objectionable that the management has decided not to consider such officers for promotion who fail to comply. Promotions should be purely based on merits, i.e. performance skills, knowledge, experience, qualifications, & behaviour with peers & superiors. Filing or not filing of property returns has nothing to do with promotions & hence should not be linked with the same. The management should immediately withdraw such a condition.
4. The prescribed limit of Rs. 10000/- for transaction of movable property is absolutely ridiculous & needs to be enhanced substantially.
5. It is also not clear why the date for filing returns has been changed to 31st December instead of 30th April as prescribed earlier. We are raising this point because there seems to be no logic in changing the dates & if there is one, we do not know it because of lack of transparency on the part of the management.
6. Ostensibly, the logic for filing property returns is to guard against (or to put a check to) any person indulging in corrupt practices & thus having disproportionate assets to his income. Whether all Class I Officers will indulge in such corrupt practices? There are various checks & balances in our system & we would do well to concentrate on improving our internal system & that the procedural aspects including accounting procedures are being scrupulously followed.
7. The origin of corruption is just not any position but the mind & hence selective application of any rule should be avoided.
8. What real purpose does the filing of property returns serve? This is so because:-
a. The employees filling-in the returns may not give correct information.
b. Even if the correct information is given by a supposedly corrupt person, the information will remain in the custody of the Corporation. The sealed cover would be opened only in the case of any official investigation. Thus, it would not be possible for anybody to know before-hand whether the person has disproportionate assets to his income.
.
In view of all these points, we demand that the above circular should be amended suitably & the condition of linking to promotion should be removed forthwith.
.
The last, but not the least, time and again we feel that such important move /decisions are being implemented unilaterally by the management without consultations with the representative Organizations/Unions. We strongly oppose it and demand that any important decisions be implemented only after the consultations with the representative Organizations/Unions.
.
Yours faithfully,
Sd/- Ganesh Kamath, GS, NOINO
Sd/-
Gopal Shelar,Working President, BVKS
.