From : MES-470044 Sudhir Kumar, JE (QS&C) C/O Garrison Engineer (south) Meerut Cantt To, Shri S R Amin, Under

Secretary to the Govt of India Ministry of Defence Sena Bhawan B wing New Delhi (Through Proper Channel)

Dated

Jan 2012

DISCIPLINE : SHRI P KRISHNAN AE B/R AND OTHERS HQ CWE MAHARAJPUR, GWALIOR IN RESPECT OF CA NO : GE(I) R&D/GWL/15 OF 05 : PROVN OF CEMENT CHEQUERED TILES ON ROAD REPAIR

(AF) 2004-

1. Reference your letter No C-13011/D(vig-II)/2011 dated 09 Nov 2011 received through GE (South) Meerut vide their letter No C-108/Disc/915/E1C dated 04 Jan 2012. 2. Since my replies to SHOW CAUSE NOTICE submitted by me vide my application dated 06 Jan 2009 (wherein I had submitted photocopy of Pages of Military Engineer Services Standing Orders-1995 which clearly fix the responsibility of purchase voucher of materials with Engineer-inCharge i.e AGE), has not been agreed and I have been dragged to face Inquiry by ignoring orders, instructions and policy issued by E-in-Cs Branch New Delhi which also reveal that ground executives are only responsible for execution of work at site as well as for purchase voucher of materials incorporated in the work, it is requested that photocopy of following documents may please be forwarded to me for furnishing or modifying my reply to the charges as mentioned in Annexure-I and Annexure-II to Govt of India Ministry of Defence Sena Bhawan, B Wing, New Delhi letter No C-13011/D(Vig-II)/2011 dated 09 Nov 2011:(a) Copy of MES Standing Orders/Instructions or Policy letter issued by Engineer-in-Chief Branch New Delhi under which JE (QS&C) or Surveyor cadre people has been made responsible (or can be held responsible) for checking of fake purchase voucher or any other voucher of material incorporated in the work. (b) (c) Copy of Contract Agreement No : GE (I)R&D/GWL/15 of 2004-05. Copy of paid RARs and paid Final Bills of subject Contract Agreement .

(d) Copy of Board of Officers (BOO) as convened by Chief Engineer vide Convening Order No C-10000/comp/Agra/585/E1C dated 30 May 2007 and its findings and recommendations including replies to observations. (e) (f) Copy of Devaluation Statement. Copy of following Site documents :(i) (ii) (iii) (iv) Copy of Sample Approval Register. Copy of Site Order Book. Copy of Work Diary. Copy of Stage Passing Register.

(g) Copy of Purchase Vouchers of Chequered cement concrete tiles and other items submitted by the contractor duly defaced by Engineer-in-Charge alongwith the copy of covering letter under which the same work submitted to AGE office and then to GE office after its verifications by Eingineer-in-Charge. (h) done Photocopy of pages of MB wherever Purchase Vouchers and Measurements of work of chequered cement concrete tiles are recorded in MB. or

(j) Copy of STEs letter for STE observations, its replies to STE by GE (I) R&D Chief Engineer R&D Delhi and settlement letter issued by STE CC Lucknow.

(k) Copy of original complaint due to which Memorandum of Charges has been served upon me. Contd2

-2(l) Copy of charges framed against other officers & individuals viz GE/AGE/JE (Civ)/AEE (QS&C) and other JE (QS&C) involved in the subject case may also please be provided for my reference please. (m) Case files containing complete correspondence of subject contract.

3. However, my replies to the charges mentioned in Annexure-I and Annexure-II of the Memorandum, are being submitted separately for which I shall reserve my right to re-submit or modify my reply based on other facts revealed from the documents requested by me in para-2 above. Thanking you,

Yours faithfully

Sudhir Kumar, MES-470044 JE (QS&C) C/O Garrison Engineer (south) Meerut Cantt Copy to :Jt Dte Gen (Dis & Vog) E1D Engineer-in-Chief Branch Kashmir House IHQ of MOD (Army) DHQ PO New Delhi-110011 Shri P K Chakrabarti, Dy Secretary Central Vigilance Commission Satarkta Bhawan, GPO Complex Block A , INA New Delhi HQ CECC PIN- 900450 C/O 56 APO HQ CE Bareilly Zone PIN-900496 C/O 56 APO HQ ADG (OF & DRDO) Secunderabad against me. HQ CE R&D Probyn Road Delhi-54 GE (I) R&D Agra It is requested that the documents mentioned in para 2(a) to 2(m) may please be provided to me for furnishing (or modifying) my statement of defence against charges framed for information please.

From : MES-470044 Sudhir Kumar, JE (QS&C) C/O Garrison Engineer (south) Meerut Cantt To, Shri S R Amin, Under Secretary to the Govt of India Ministry of Defence Sena Bhawan B wing New Delhi (Through Proper Channel MEMORANDUM

Dated

Jan 2012

1. Reference above Memorandum issued vide your letter No C-13011/D/(vig-II)/2011 dated 09 Nov 2011 received through GE (South) letter No C-108/Disc/915/E1C dated 04 Jan 2012 and further to my application dated 10 Jan 2012(copy enclosed for ready reference). 2. Parawise replies to above referred Memorandum, are submitted as under please :Para 1 :- Contents of this para are noted with receipt of following documents please :(a) (b) (c) (d) Copy of Annexure-I Copy of Annexure-II Copy of Annexure-III Copy of Annexure-IV 01 (one) sheet unsigned copy 01 (one) sheet unsigned copy 01 (one) sheet unsigned copy 01 (one) sheet unsigned copy 01 (one) sheet signed photocopy

(e) Copy of Central Vigilance Commission Office Memorandum vide their letter No 007/DEF/07412282 dated 23 Mar 2011.

Para 2 :- My Written Statement of Defence to the above said Memorandum, is enclosed herewith as Appendix A to Appendix C as desired please. It is also submitted that in addition to my Written Statement , I also wish to appear before Inquire Authority in person and desire to be heard in person and want to explain and plead my case against the charges framed against me in Annexure-I & II of the Memorandum. Para 3 :- Noted please. Para 4 :- In this connection my submissions & request under my replies against para-2 above, may please be referred. I once again submit that I wish to be present before Inquiry Authority & desire to be heard in person. Para 5 :- Noted please. Para 6 :Receipt of the Memorandum as mentioned in para-1 above, is hereby acknowledged with following remarks :Memorandum contains two sheets only wherein first page (containing Para 1 to Para 5) is unsigned and second page (contains para-6) is ink signed please. 3. With reference to the above Memorandum of charges, it is brought out that earlier also, I was served with a SHOW CAUSE NOTICE in the subject case by GE Gwalior vide their letter No C-1075/Gen/411/E1(Con) dated 29 Dec 2008 (refer Annexure A enclosed) and in reply, I had submitted my point wise exhaustive replies and clarifications vide my application dated 06 Jan 2009 (refer Annexure B enclosed for ready reference please) and in support, I also enclosed the photocopy of pages of MES Standing orders issued by E-in-Cs Branch New Delhi which stipulates regarding specific responsibilities & duties of MES executives i.e Garrison Engineer, Assistant Garrison Engineer and JE (Civ) with regard to different stages and activities of execution of work at site. As per MES Standing Orders issued by E-in-Cs Branch New Delhi vide Serial No 16(f) of Para 135 sub Para 135.1 on Page 92 (refer Annexure C enclosed), the responsibility of checking of Bills/Vouchers for proprietary items & other materials paid for in RARs/Final Bill exclusively lies with Engineer-in-Charge only. Contd..2

-2Since I have been served with the above said Memorandum of charges with the reason for processing the RAR to my Superior officer/GE without proper technical check of fake purchase vouchers of PCC chequered tiles purported to be from Mehtab tiles submitted by the contractor, it appears that either my complete exhaustive reply (containing 4 sheets of replies plus 3 sheets of enclosures i.e photocopy of Pages of MES Standing Orders), has not been put up before the concerned authorities at different levels or the same has not been gone through in the light of MES Standing Orders, Instructions and Policy letter issued by E-in-Cs Branch New Delhi by the authorities/Officers concerned. However, if I have been served with the above Memorandum of charges after going through my earlier replies to the SHOW CAUSE NOTICE as mentioned above, the basis (i.e MES Standing Orders, Instruction or Policy letter of E-inCs Branch New Delhi), for fixing the responsibility of proper check of fake voucher of material with the JE (QS&C) may please be intimated alongwith copy of such E-in-Cs Standing Order, Policy letter or Instruction. If possible, copy of Remarks/Noting/Minutes at different levels resulting in serving upon me with the Memorandum of Charges may also please be provided. 4. In addition to the above, it is also requested that photocopy of the documents as requested vide my application dated 10 Jan 2012 (refer Annexure H enclosed), may also please be provided for furnishing (or modifying) my replies against the charges mentioned in Annexure-I & AnnexureII to the above referred Memorandum of charges. In the meanwhile, I am submitting my interim replies to the charges as per Appendix A to Appendix C enclosed herewith. I also submit that I would also like to resubmit or modify my replies or may produce any other documents in my defence, based on the facts revealed from the documents requested by me vide my application dated 10 Jan 2012 on receipt of the same.

Yours faithfully

Encl : i) Appx A to Appendix C (06 Sheets) ii) Annexure A to Annexure H (24 Sheets)

Sudhir Kumar, JE (QS&C) MES-470044 C/O Garrison Engineer (south) Meerut Cantt

2012.

Appendix A to Sudhir Kumar, JE (QS&C), replies vide application No Nil dated 12 Jan STATEMENT OF DEFENCE TO STATEMENT OF ARTICLES OF CHARGES FRAMED AGAINST MES-470044 SUDHIR KUMAR JE (QS&C), VIDE ANNEXURE-I & ANNEXURE-II TO MEMORANDUM ISSUED VIDE GOVT OF INDIA, MINISTRY OF DEFENCE, SENA BHAWAN B WING NEW DELHI LETTRNO C-13011/D(VigII)/2011 DATED 09 NOV 2011.

Respected Sir, 1. In this connection it is submitted that in the subject case I, vide my application dated 06 Jan 2009 (refer Annexure B enclosed), have already submitted my replies to SHOW CAUSE NOTICE served on me by GE Gwalior vide their letter No C-1075/Gen/411/E1Con dated 29 Dec 2008 wherein I, vide Para 3 (b) of my replies to SHOW CAUSE NOTICE had clarified that checking of fake voucher or any other voucher of materials incorporated in the work, is neither the responsibility/duty of JE (QS&C) in MES Deptt nor checking of the same falls under the parameters of technical check of RARs/Final Bills provided for vide Para 139 on Page No 94 & 95 of MES Standing Order issued by Engineer-in-Chief, E-in-Cs Branch New Delhi (refer Annexure C enclosed). In the same Para 3(b) of my replies to SHOW CAUSE NOTICE, I also brought out that the responsibility/duty for checking/verification of purchase vouchers of materials/solely lies with the Engineer-in-Charge only as enumerated vide serial No 16(f) of Para-135, Sub Para 135.1 on Page No 92 of MES Standing Orders issued by Engineer-in-Chief, E-in-Cs Branch New Delhi (refer Annexure C enclosed). 2. In addition to above following documents/instructions on administration of contract matters issued by Engineer-in-Chief Branch New Delhi, regarding quality check of material & verification of purchase vouchers are also referred :(a) Condition 10(A) of IAFW-2249 regarding materials to be provided by the contractor. Condition 10(A) of IAFW-2249 vide sub para-2 clearly stipulates that All materials to be provided by the contractor shall be new and in conformity with specifications laid down in the contract and the contractors shall, if requested by the Engineer-in-Charge, furnish proof, to the satisfaction of the Engineer-in-Charge that the material so comply. Further, condition 10(A) of IAFW-2249 vide Sub Para-2 (Annexure D enclosed again stipulates that the Engineer-in-Charge shall have full powers to require removal of only or all of the materials brought to site by the contractor which are not new and in accordance with the contract specifications or do not conform in character or quality to sample approved by him. In case of default on the part of the contractor in removing rejected materials the Engineer-in-Charge shall be at the liberty to have removed by other means at the contractors expense and risk. The Engineer-in-Charge shall have full powers require other proper materials to be substituted for rejected materials and in the event of the contractor refusing to comply, he may cause the same to be supplied by other means. All cost/Charges and expenses which may attend upon such substitution, shall be borne by the contractor. In view of the above, it is clear that Engineer-in-Charge has allowed to incorporate the substandard chequered cement concrete tiles of local Make in Make-Mehtab tiles specified in the contract. (b) MES Manual on contract -2007, vide section 8 para 8.2(n) (vii) on page 106 & 107 of Manual (Annexure E enclosed), also speaks and elaborates regarding record of materials and purchse voucher inreference to condition 10 of IAFW-2249 and reiterates that quality of materials to be in incorporated in the work at site shall be new and in conformity with specifications laid down in contract and contractor if requested by the Engineer-in-Charge shall have to furnish proof to the satisfaction of Engineer-in-Charge. This Para further stipulates that where Engineer-in-Charge is having doubt regarding quality/genuineness of materials, he should demand purchase voucher of such materials before payment of such materials lying at site. Original purchase vouchers shall be defaced by the Engineer-in-Charge and photocopies shall be kept on record. If Engineer-in-Charge is having any doubt regarding genuineness of purchase voucher the same shall be verified by him.

lieu of

Contd2 Appendix A (Contd) -2(c) As per instructions on Administration of contracts with respect to Record of Materials and purchase vouchers issued by E-in-Cs Branch New Delhi letter No 66546/P8/92/E8 dated 26 Mar 2009 vide Para 2 (Annexure F enclosed), the powers vested in GE are stated to have been restricted for the purpose of avoiding the incorporation of spurious materials in the work only and it should not lead to GE assuming the role of an auditor for checking of Sales Tax/Vat by the contractor for which separate authorities are designated by the Govt. Thus only ground executives i.e GE/ AGE / JE(Civ) who physically inspect the material at site and Engineer-in-Charge (i.e AGE) who deface and verifies purchase voucher of material, can only ensure the quality of material at site through their physical inspection. The JE (QS&C) cannot smell and ascertain the genuineness of purchase voucher of material if the same is genuine or fake because of the reason that JE (QS&C) performs his duties inside the office complex only and he is not entitle to visit and inspect the material or work being executed at site, physically . (d) In this regard, this is also brought out that many contractors do not furnish the purchse voucher of materials for different reasons best known to them, despite insistence by the MES Ground Executives i.e GE/AGE/JE (Civ) for producing the same as also brought out vide Para 1 of E-in-Cs Branch letter No 66546/P-8/29/E8 dated 10 Jun 2011(refer Annexure G enclosed). It may also please be noted that as per this policy letter of E-in-Cs Branch Delhi the necessity of production of purchase voucher has been reviewed by E-in-Cs Branch New Delhi and purchase vouchers of materials are not required nowadays except for the materials being paid as material lying at site and for material in respect of cement , steel major E/M equipment s like Transformers DG Sets, Pumps, Motors, AC & Lift Equipments. (e) The fact of non production of purchase voucher of materials is also revealed during site examination of works by STE Brach (Superintending Technical Examiner Branch) who also observes and insist for production of purchase vouchers of different materials incorporated in the work as the same are not produced before them during site examination of work. Factual notes of contracts prepared & signed by Engineer-in-Charge (AGE), GE and STE also reveal that vouchers have not been produced before STE and hence it also becomes an observation besides other observations during site examination of works. Such obsns of STE Branch clearly show and reveal that the ground executives remain unable to obtain the purchase vouchers of many items before incorporation in the works and even after making payment of RARs to the contractor. (f) MES Builders Association of India (MES BAI) also raises this issue (i.e issue of insistence of purchase vouches by the ground executives) in their periodical meetings held with the E-in-Cs Branch New Delhi and after discussion with MES BAI, E-in-Cs Branch New Delhi reviews orders/instructions/Policy etc on the subject matter. In view of the above, stipulations, my written statement of defence to the article of charges mentioned in Annexure I and Annexure-II is as given in Appendix B and Appendix C here in after please.

Sudhir Kumar, JE (QS&C) MES-470044 C/O Garrison Engineer (south) Meerut Cantt

2012

Appendix B (Annexure-I) Sudhir Kumar, JE (QS&C), replies vide application No Nil dated 12 Jan

WRITTEN STATEMENT OF DEFENCE TO STATEMENT OF ARTICLES OF CHARGES MENTIONED IN ANNEXURE-I OF MEMORANDUM ARTICLE-I
Para-1. In this connection it is agreed that I have served during the period from 10 Dec 2002 to 30 Apr 2005 at GE (I) R&D Gwalior now GE (I) R&D Agra but this being an old case of 5 to 6 years back, I do not remember whether or not, I had processed contract bearing No GE (I) R&D/GWL/15 of 2004-2005 Provn of cement chequered tiles on road repair in front of and around synthetic chemistry lab at DRDE Gwalior). In this connection kindly refer para-2 of my application dated 06 Jan 2009 (refer Annexure B) wherein I have explain that although I am not in position to make/offer much comments/clarifications to the alleged regularities mentioned in SHOW CAUSE NOTICE in the absence of connected documents on subject documents as it being of 3 to 4 years old case. However, I had submitted my replies to the SHOW CAUSE NOTICE keeping in view the nature of allegation (i.e checking of fake purchase voucher of chequered cement concrete tiles which was not my duty and as the responsibility/duty for the same lies exclusively with the ground executive i.e Engineer-in-Charge only as mentioned in MES Standing Orders 1995 issued by E-in-Cs New Delhi), (refer Annexure C enclosed). It is also submitted that since my replies to the above said SHOW CAUSE NOTICE vide my application dated 06 Jan 2009, neither I have been informed with regard to agree or disagree with my replies nor I have been given any opportunity to see and verify any documents like RARs, Final Bill files correspondence of the subject Contract Agreement and other site documents to verify the fact if the same have been checked, signed or processed by me or otherwise. Para-2. In this connection it is submitted that I am unable to confirm regarding Processing of RAR or Final Bill of subject contract by me unless the copy of paid RAR/Final Bill is personally seen by me as it is an old case of 5 to 6 years back. Further, even if the said RAR or Final Bill have been checked and signed by me I strongly deny the allegation because checking of fake purchase vouchers or otherwise is not the duty of JE (QS&C) and the responsibility for checking and verification of any vouchers exclusively lies with the ground executives (or Engineer-in-Charge, AGE) only as enumerated in Military Engineer Services Standing Orders-1995 issued by E-in-Cs New Delhi and other policy letters instructions issued by E-in-Cs Branch New Delhi as brought out in Annexure A to Annexure G enclosed. ARTICLE-II Para-3 In this connection it is brought out that Para 3 is the repetition of para-2 of article-I and states for bringing the matter to the knowledge of my superior officer/GE by me as substandard local make tiles were provided by the contractor. I strongly deny any failure on my part in exercising proper technical check of RARs/Final Bill of subject contract. (a) In this context, the duties and responsibilities of different officers and subordinates i.e GE, AGE, JE (Civ), JE (QS&C) and parameters of technical check given in MES regulations in para 43, 45, 52 and 56 as well as in table F, table M and table N are also referred. The duties and responsibilities have further been elaborated in MES Standing Orders-1995 to fix responsibility and accountability of the individuals vide Para 135 (i.e for ground executives) and Para 139 (i.e for technical check of bills) (refer Annexure C enclosed) which also stipulates parameters of technical check of Bills (or RARs/Final Bills) by JE (QS&C). (b) In addition to above the nature of duty of JE (QS&C) is also to be taken care of while fixing the responsibility for use of substandard local make materials at site by the contactor. These are mentioned below :(i) JE (QS&C) performs his duty under subordination of his superior officer i.e AEE (QS&C) or AE (QS&C) who is also the In charge of contract section and further responsible for GE. (ii) JE (QS&C) has to perform table duty on order of his superior officer by sitting compound only. (iii) JE (QS&C) can never visit the site of work of any contract running under his Garrison Engineer office) in MES Deptt. in the office division (or

(iv) JE (QS&C) has to perform of duty technical check of RARs/Final Bill on order of his superior officer on receipt of signed statement of work done prepared and forwarded by ground executives i.e AGE/JE(Civ) with the knowledge of GE alongwith certain certificates, recovery statements, Deviation orders/Devaluation statement (if any) duly signed by Engineer-in-Charge (i.e AGE), GE and contractor. (v) JE (QS&C), while performing his duties of technical check within the office complex, has in-fact no physical knowledge of actual developments taking place at site of work. Thus JE (QS&C) is not aware with actual ground position and physical status of work at site whether the same has been. executed strictly as per contract specifications

Contd2

Appendix B
or executed with unsound construction with substandard local make materials or executed with new materials or executed with old materials and also whether the work has actually been executed at site or not

(Contd..

(vi) JE (QS&C) has to perform his duty of technical check in terms of and within the parameter Para 139 (Technical check of bills) on page 94 and 95 of MES Standing Orders-1995 (refer Annexure C) which no where include checking or verification of purchase voucher of materials by (QS&C).

of JE

(vii) JE (QS&C) can neither smell nor have any mechanism to detect the genuineness of materials or purchase vouchers if the same is genuine of fake. The first stage of doubt in this regard, only begins in the minds of ground executives (i.e GE/AGE/ JE (Civ) after physical inspection of materials at site whether the same is of quality specified in contract and in case of doubt confirmation for satisfaction of genuineness of materials or purchse vouchers can be ascertained by the Engineer-inCharge through testing of materials from approved Govt Labs or through verification of purchase vouchers from where it has been obtained. (viii) In this connection it is also brought out that merely a genuine purchase voucher of materials produced by contractor, cannot guarantee for incorporation of standard make materials (or materials of specified make) at site by the contractor. Which is only possible through strict and vigilant supervision of ground executives i.e GE/AGE/JE (Civ) at site. In view of above, stipulations it is clarified that a JE (QS&C) whose duty is to perform technical check of RARs/Final Bill by sitting in office compound only and who can never visit the site, cannot be held responsible for use of substandard materials or local make tiles provided at site in violation of contract provisions. In fact, the duty to super wise and get execute the work at site rests or lies exclusively with the ground executives i.e GE, AGE and JE (Civ) as per their duties and responsibilities mentioned in MES regulations & MES Standing Orders-1995 issued by Ein-Cs New Delhi. ARTICLE-III Para-4. The point again pertains to processing of RAR & Final Bull by me for payment without Deviation order/Devaluation statement for use of substandard local make tiles in lieu of specified make tiles. I strongly deny the allegation or any failure on my part as also brought out in my reply to para-2 of ARTICLE-I above. In this connection kindly also refer my replies against para-3 of ARTICLE-II regarding duties and responsibilities of MES ground executives i.e GE/AGE/JE(Civ) and JE (QS&C) and also the nature of duty of JE (QS&C) who performs his duty sitting in office complex only and who can never visits the site. Any failure on my part in processing the payment of RAR without deviation order/devaluation statement for substandard work for use of local make tiles in lieu of specified make which is not enclosed/attached with the RAR received from AGEs office, which is neither initiated by AGE for it check & finalization by competent authorities or finalized, or and also not in my knowledge, is strongly denied. In this connection my earlier replies to SHOW CAUSE NOTICE vide para5 subpara-2(c) vide my application dated 06 Jan 2008 also refers (refer Annexure-B). Para-5 In view of stipulations in para-1, para-2(a) to 2 (f) of Appendix A supported with Annexure A to Annexure G, my statement of Defence to para-1 & part-2 of ARTICLE-I, para-3 of ARTICLE-II, para-4 of ARTICLE-III above, I strongly deny the charge of any lack of devotion of Govt duty and unbecoming of Govt servant on my part as levied against me and therefore, I have not violated the rule 3(1) (i) (ii) (iii) of CCS (conduct) rules-1964 as stated. In view of my above replies and statement of defence I, once again submit that I have unnecessarily been dragged to face the inquiry for none of my fault. I therefore humbly pray to withdraw all the charges framed against me and request that justice be given to me. I shall be highly obliged if the justice is given to me .

Thanking you,
Yours faithfully

Sudhir Kumar, JE (QS&C) MES-470044 C/O Garrison Engineer (south) Meerut Cantt

ARTICLE-I

Annexure-II

Para-1 In this connection my replies to para-1 of ARTICLE-I to Annexure-I are referred please. Para-2 In this connection my replies/statement of defence to para-2 of ARTICLE-I to Annexure-I is referred please. In addition, it is also brought out that approval of sample and quality control for using the materials of specified make or ensuring the genuineness of materials through physical inspection, through test certificates or by getting testing of materials from authorize Govt Lab is the responsibility of ground executives i.e GE/AGE/JE (QS&C) and it does not fall in the duty/responsibility of JE (QS&C) or under the parameters of technical check of bills as per para-139 of MES Standing Order-1995 issued by E-in-Cs. In this connection stipulations in Appendix A supported with Annexure A to Annexure G may also please referred. In view of the above, the stipulations in para-2 of ARTICLE of Annexure-II not agreed hence denied. ARTICLE-II Para-3 In this connection my replies/statement of defence to para-3 of ARTICLE-II to Annexure-I are referred please. Hence the allegation is not agreed and denied. ARTICLE-III Para-4 In this connection my replies/statement of defence to para-4 of ARTICLE-III to AnnexureI are referred please. Hence the allegation is not agreed and denied. In view of my above replies and statement of defence I, once again submit that I have unnecessarily been dragged to face the inquiry for non of my fault. I therefore humbly pray to withdraw all the charges framed against me and justice be given to me I shall be highly obliged if justice is given to me. Annexure-III No comments are offered on documents mentioned at Sl No 1 to Sl No 6, as none of the documents has been provided to me. Annexure-IV No comments are offered on Annexure-IV as the content of Annexure-IV are as NIL.

Yours faithfully

Sudhir Kumar, JE (QS&C) MES-470044 C/O Garrison Engineer (south) Meerut Cantt