A dismissed employee usually arrives at a lawyer three months later, with a strong story and a dead claim. Labour law in Pakistan runs on short, strict time limits, and the first of them starts running the day the thing you are complaining about happens.
First: are you a "workman"?
The Labour Court's jurisdiction runs to workmen as the industrial relations legislation defines them — broadly, employees doing manual, clerical, skilled, unskilled or technical work in an industrial or commercial establishment. It generally excludes people employed mainly in a managerial or administrative capacity.
That single question decides your entire route. Get it wrong and you spend a year in the wrong forum.
- A workman — grievance procedure, then the Labour Court.
- A manager, or an employee outside the definition — ordinarily a civil suit for damages for breach of contract, on a different timeline entirely.
- A civil servant — departmental appeal, then the Service Tribunal. Not the Labour Court.
Your job title is not decisive. What you actually did is. A "manager" with no power to hire, fire or bind the employer is frequently held to be a workman.
Which law, and which province
After the Eighteenth Amendment, labour is largely provincial. Punjab, Sindh, Khyber Pakhtunkhwa, Balochistan and ICT each have their own Industrial Relations Act, and the periods and procedures differ between them. Establishments spanning more than one province fall under the federal statute.
So the first two questions in any labour matter are: which province is the establishment in, and does it operate in more than one? Never assume the deadline you read online applies to your province.
The grievance notice — the step that is skipped
You generally cannot walk into the Labour Court. The industrial relations law requires the workman to first raise a grievance in writing with the employer, within a short period of the cause arising. The employer then has a defined period to decide. Only when they refuse, or the period lapses, does the Labour Court open.
The practical points that decide cases:
- Serve it in a provable way. By hand against a signed acknowledgement, or by registered post or courier with the receipt kept. An undated letter handed to a supervisor proves nothing.
- Date it correctly. The clock runs from the date of the grievance — the termination, the withheld wages, the demotion — not from the day you decided to act.
- State the relief. Reinstatement, back wages, dues, whatever you want. A grievance that only complains is weaker than one that asks.
- Keep it factual. This document is read by the court before anything you say later.
In the Labour Court
The Labour Court is presided over by a judge and follows a summary procedure — it is meant to be quicker and less formal than a civil court, and it can generally do things a civil court cannot: order reinstatement, award back wages, and set aside a punishment.
The broad sequence: the application is filed, notice goes to the employer, the employer files a reply, issues are framed, both sides lead evidence and are cross-examined, arguments are heard, and an award follows. An appeal generally lies to the Labour Appellate Tribunal.
An important evidential point: in a termination case, the burden of showing that a proper inquiry was held and the dismissal was lawful usually rests on the employer. Many dismissals fail simply because no show-cause notice was issued, no charge sheet was framed and no inquiry was held.
Build the file before you file
- Appointment letter, contract, and any staff handbook or service rules.
- Salary slips and bank statements showing what you were actually paid — this is what quantifies back wages.
- The termination letter, or evidence of a verbal dismissal: the date, who said it, who was present, the moment your access or attendance was cut off.
- Any show-cause notice, charge sheet or inquiry record — and note their absence, because that absence is your best point.
- Attendance, leave and performance records.
- Your grievance notice and proof of its service.
Claims that are not really Labour Court claims
- Unpaid wages alone may be pursued before the authority under the Payment of Wages Act, 1936, which is often faster.
- An injury at work falls under workers' compensation and social security, not an ordinary termination claim.
- Harassment goes to the Ombudsperson under the workplace harassment legislation, and can be pursued alongside a labour claim.
- EOBI pension and social security contributions have their own institutions and their own complaint routes.
Two warnings
First, do not sign a full and final settlement under pressure on your last day. Read it. Once signed, it is very hard to reopen. Ask for time; "sign now or nothing" is itself worth recording.
Second, resigning is not the same as being dismissed. A resignation extracted by threat can be challenged as a constructive termination, but that is a harder case than an ordinary dismissal — so if you are being pushed to resign, take advice before you write the letter, not after.
This article describes labour procedure in Pakistan in general terms and is not advice on any particular dismissal. The applicable statute, the forum and above all the time limits differ between the provinces and the federal regime. Speak to an employment advocate immediately — the grievance deadline is short and it does not pause while you decide.