3. DEFINITION & SCOPE
Para-wise comments are the written defense/rebuttal on an
appeal/petition/representation filed before higher forum e.g.
Appellate Authority, Courts (High Courts/Service Tribunal) etc.
Para-wise comments are generally offered on the following:
o Departmental Appeals against punishments;
o Representations regarding different service matters i.e. Adverse
remarks in PERs, Seniority, Transfer/Posting;
o Service Appeals
o Writ Petitions 3
4. MAIN COMPONENTS
There are four main components of para-wise comments
o Preliminary objections, if any
o Report on factual position/background of the case
o Point to point reply to assertions made by the
appellant/petitioner
o Prayer
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5. ANALYSIS OF DOCUMENT
Examine the documents/case file carefully
Identify the Issues of law
Identify the Issues of facts
Contention/Relief Sought
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6. KEY POINTS (GENERAL)
Comments are always submitted to higher authority(s)/court(s)
Very courteous and respectful language
Avoid repetition of facts
Annotated form of Comments
No commentary or personal remarks on any decision of the Hon’ble
Courts
Comments to be signed the Head of Department/Office only (unless
authorized)
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7. KEY POINTS (COURT CASES)
Specific format
Indicate the name of Court/Tribunal in block letters
Name of the parties
Address the courts respectfully with such words i.e.
“Honorable Court”, “Learned Tribunal”.
Frequent use of case laws;
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8. DRAFTING OF COMMENTS (1ST PART)
The first part contains preliminary objections
Maintainability of an appeal
Jurisdiction of the Court
Time Limitation
Availed departmental remedy
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9. DRAFTING OF COMMENTS (2ND PART)
2nd part contains report about the facts, leading circumstances
The events must be described in proper sequence
Text to be arranged in numbered paragraphs
Report to be self-contained/explanatory
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10. DRAFTING OF COMMENTS (3RD PART)
3rd part contains point to point reply, addressing the paragraphs of
appeal/petition.
Paragraph will start denying the contention
Reply will be specific & to the point
Complete description to refute the version in the paragraph
No conceding statement.
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11. CONCLUSION
List of supportive cases laws
Prayer to dismiss the appeal/petition
Vetting from the Law Officer
In case the cause of action ceases (death, retirement of appellant),
a brief reply/reply to be submitted instead of para-wise comments.
Specimen para-wise comments
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