Thursday, November 25, 2010

Objections/Proposals on cadre restructuring submitted by the AICEIA to CBEC



1. The proposal lacks any vision or far sight and all that has been done is to ensure systematic and time bound promotion to direct recruit Group A officers and a largess to their blue eyed boys- the Appraisers. The limited benefit made available to Inspectors of Central Excise in certain cadre zones are only incidental in the scheme.

2. The proposal fails to realize the problems faced by the Inspectors of Central Excise. The major problems being
(a) Disparity in promotion among the 15 seniority zones of Central Excise Inspectors.
(b) Disparity in promotion vis-à-vis Preventive Officers & Examiner
(c) Unfair ratio between Central Excise & Customs that grossly discriminates Superintendents of Central Excise for promotion to the post of Assistant Commissioner
(d) Skewed ratio for Group B Gazetted Executive to entry level Group A posts

3. Though the proposal in Chapter 6 asserts that there is an acute stagnation in the Group B level, no mechanism has been evolved to remove the same. For the sake of records, it is pointed out that the Inspectors of Central Excise recruited in the year 1972/73 are yet to be promoted as Assistant Commissioner and it is not the 1976 batch as stated in the report.

4. The present proposal would widen the disparity among the Central Excise seniority zones as evident from the table below. At present the gap between the best case and worst case is 10 years. (North East 1986 & Delhi1996). This proposal would widen the gap to 15 years. (please see table in Annexure A). While Inspectors of 2002 batch gets promoted in 7 out of 15 cadre zones, Inspectors in 8 Zones would lag behind as follows. The situation is acute in 5 zones.

Zone /  Batch getting promoted  /  Gap between other 8 zones
Shillong   1988 (part)  15 years
West Bengal 1992 (part) 11 years
Tamil Nadu 1992 (part) 11 years
Kerala 1993 (part) 10 years
UP / UTTRANCHAL 1993 (part) 10 years
Andhra Pradesh 1997 (part) 6 years
Rajasthan 1997 5 years (wrongly mentioned,only part of 1994 batch will be promoted)
Bihar/ Jharkhand 1998 (part) 5 years.

This huge disparity would de-motivate & demoralize officers in this zone and doom their prospects permanently and would lead to prolonged unrest.

Proposed to create another Customs Commissionerate

On examination of the proposals for reorganization of Customs Zones, it has been observed that although Amritsar Customs (P) commissionerate does not qualify on revenue parameters, yet the Board has proposed to create an additional commissionerate at Ludhiana by bifurcating it on the premise that:
“.The reorganization of Customs (P) formations cannot be done on the basis of quantifiable parameters and the same has to be done keeping in view the vulnerability of geographical regions over which these formations exercise jurisdictions. Customs (P) Commissionerates should be so organized that their main focus remains Customs Preventive work and it does not get diluted by any revenue collection related functions.”                         
Para vi on page 53 of the Proposals

Similarly, the Tuticorin & Tiruchirapally Commissionerates under the Chennai Customs (P) Zone have been retained despite not fulfilling the criterion of revenue / work-load parameter on the ground that :“Being Customs (P) Formations, the existence of the two Commissionerates need not be justified on the basis of quantifiable parameters such as number of Bills of Entry and Shipping Bills etc. These two Commissionerates cover the entire highly sensitive coastline (except the coastline falling within the jurisdiction of Chennai Customs Zone) of the State of Tamil Nadu.”
Para iv on page 52 of the Proposals

Creation of new Customs Commissionerate at Ludhiana and retention of the Customs (P) Commissionerates at Tuticorin & Tiruchirapally is a very welcome step. However, it is shocking and appalling to observe that the same analogy has not been applied in the case of Jodhpur Customs (P) Commissionerate which alone exercises jurisdiction over the highly sensitive and vulnerable 1077 KMs long Indo-Pak border (as against the 561 KM long international border of Punjab state), andis area-wise by far the largest (3.42 lac Sq. KMs, as against the 0.50 lac Sq. KMsarea of Punjab), topographically inaccessible and inhospitable desert / semi-arid jurisdiction spanning across the entire state of Rajasthan.

It would be pertinent to mention here that Jodhpur Customs (P) Commissionerate was initially created for preventive functions, but the workload of this Commissionerate has significantly increased in the recent times. Apart from attending to the Customs Preventive functions, Jodhpur Customs (P) Commissionerate is also handling the work of examination & assessment of import & export consignments, examination & supervision of a large volume of factory stuffed containers for export as well as clearance of passengers at the International Airport, Jaipur and Land Customs Station at Munabao (Barmer).

The LCS, Munabao and International Airport, Jaipur and 8 new ICDs have become operational / functional much after the last restructuring in 1997 and no additional posts have been sanctioned / created for these formations. All this additional workload is being handled by reallocation of Staff on the basis of old sanctioned strength. Numerous letters have been written by the Commissioner of Customs, Jodhpur to the Board for augmenting the Staff strength by sanctioning additional posts for these highly sensitive formations (copy enclosed) and the urgent requirement of additional staff has also been reiterated time and again by our Inspectors’ Association, but to no avail.

Therefore, based on the same analogy, as applied in the case of bifurcation of Amritsar (P) and retention of Tuticorin & Tiruchirapally Commissionerates, the case of Rajasthan for carving out / creation of another Customs Commissionerate merits equal consideration, if not more.

Thanks, comrade Kousik Roy for rightly pointed out/inclusion of our genuine demand of one more customs commissionerate in the OBJECTIONS/PROPOSALS ON CADRE RESTRUCTURING submitted to CBEC. Work done by comrade Sudhir Tiwari & BL Meena  in the matter is also appraisable.



Good Luck to your presentation.

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