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12th March 1932 and who, by virtue of selection was deemed to
be the most suitable officer for that office, applied for
promotion to the rank of Executive Engineer.
9.
That, the petitioner's application was not granted,
the Engineer most senior in the Public Works Department being
promoted.
10.
That, consequent upon this promotion a redistribution
of the Executive Engineers of the Department was made and the
Waterworks Construction Office was placed in charge of a subs-
tantive Executive Engineer who was neither conversant with
modern Waterworks design and construction nor in possession of
the experience necessary to administer that office.
11.
That, owing to staff changes made necessary by the
incidence of leave, this officer had been in nominal charge of
the waterworks Construction Office for only two short periods,
aggregating seven months, between 12th March 1932, the date
from which the vacancy was retrospective, and 13th March 1937
when he was promoted to Assistant Director of Public Works.
12.
That, consequently, the responsibilities for the
administration of the works under construction, the formulation
of the policy and the preparation of Waterworks schemes, have
devolved upon the petitioner since 12th March 1932, a period of
over 5 years to the present time.
13.
That, the conception of the scheme for the recently
approved extensions of the waterworks, as set forth in Sessional
Paper No. 3 of 1937, is the work of the petitioner and the
responsibility for the design and execution of the works,
involving an expenditure of over three million dollars, is now
being borne by him.
14.
That, the responsibilities of the petitioner, since
12th March 1932, have been and are continuing to be, those of
an Executive Engineer, there being no substantive Executive
Engineer, qualified by training and experience, to undertake the