The Post Judgment Scenario : OROP

Whether or not the IESM litigation on OROP is to be considered a closed chapter would be for the petitioners to decide. The specific challenge to the policy dimensions on OROP, as laid down in the Government of India letter dated Nov 2015. could certainly be construed as done and dusted after the very clear rulings on it as contained in judgment of the Hon’ble Supreme Court.

From what was known to ESM not directly involved with the IESM petition, it never appeared that the arguments had focused so much on how much the implementation vide Govt letter dated Feb 2016 actually conformed to provisions of the letter dated Nov 2015, the stress having been on targeting the latter. There is still no comprehensive record available whether specific anomalies created by the letter dated Feb 2016 were included in arguments except for the much discussed issues of “One Rank Many Pensions”, “Automatic vs periodic review”, “date/year of implementation” or “max or avg of min and max”.

My own past perceptions of the way OROP campaign had unfolded over the years as well as the issues that had needed to be addressed had been blogged on. During the closing days of the petition and after the recent judgment, I’ve gone over some of the past posts and found them still relevant:

• There’s a need to rise above OROP as a slogan. If there is an issue of disparity and unfairness around the pensionary awards of ESM and attention needs to be focused on those, then a slogan or a mission chant does become a productive and unifying rallying point. However there is a constant need to be aware the wording or, in this case, letters of the slogan do not limit the wider scope of the objective of ensuring justice for ESM. A past blog post had touched on this aspect ➡️ Beyond The OROP "Slogan"

• There is a requirement to examine the logic of quantifying the service of older ESM on the basis of rational and constant measures and to accept that “Rank”, even in combination with QS, is not a logical sole parameter for establishing pension parity. In that respect the sentence in the judgment to the effect that “those having the same rank are not part of a homogeneous group” takes on another profound dimension in other contexts as well. These issues have been mentioned repeatedly in the past on this blog. This post provides a reasonable summary of the concept ➡️ The Hazards Of Ignoring The Non-One-ness Of "One" in OROP

• There is a need to examine all issues relating to ESM pensions in totality, not just from the OROP point of view. These could include anomalies of previous pay commissions, AVS Committee, and those caused by 7CPC. NFU is still outside purview of any discussions on pensions other than separately, in a hypothetical sense. ➡️ LOOKING BACK AT 6 CPC PENSIONS THROUGH THE OROP AND 7 CPC PRISM

• From the time of release of OROP tables in 2016, there has been a need to critically examine how the actual implementation complied with the Government's own definition of letter dated Nov 2015. That is an exercise that can still be performed and not necessarily through litigation. My own views of 2016 may not appear as unfounded as they might have done at that time ➡️ First Impressions Of The OROP Tables 

The Possible Way Forward

There are some distinct areas that need the attention of ESM bodies, leading interlocuters, services HQs, TRIPAS and, of course, DESW and MOD. These issues can be resolved through rationalisation of past policy decisions that have resulted in anomalies. The following list could be expanded upon through feedback and online interactions:

• Retrospective implementation of awards such as MACP needs to be considered by way of policy decisions brought about through consultations between IESM bodies, services HQs and MOD. If need be, obtaining some kind of binding legislative approval could be included in the overall approach. The first requirement in such reasoning is to arrive at a consensus on the need for equity in respect of current pensions of veterans who had retired in the past.

• There is a need for clarity and agreement on the concept of “equal remuneration for equal work” and, equally importantly, the basis of defining “equal work”. Let us never forget that a pension received in the present is a deferred wage and it should be the same for the same amount of service rendered, whether now or in the past. 

• Policies in this regard need to be amended through the consultative approach I have suggested. Thus “Equal Pension For Equal Service/Work” could have been the title of the approach but OROP can now be reformatted to include that wider approach instead of there being a move to change the title. 7 CPC even cited the principle of “Inter Temporal Equity” in respect of pensions. Though mechanics of implementing 7CPC fall well short of the cited principle, there is room for rationalisation and OROP could evolve into something approaching “ITE”.

• Future-proofing of pension-parities is most desirable to prevent needless generation of grievances and resulting recrimination. The 7 CPC Matrix is actually a perfect concept for bringing about the previously mentioned “Inter Temporal Equity” in regard to pensions provided placement of older ESM in “levels” as well as at “Increment Stages” of the matrix conforms to the rational definition of “equal work”. The matrix not only needs to follow some form of “notional progression”, it also needs to define progression brought about by MACP or, possibly, NFU. The past post is just an example. Progression on these lines, as suggested in the past, needs to be defined for all levels related to ESM ➡️ Some Notions Of Progression 

This may also be an opportune time to recognise the tremendous work load on the administrative machinery in formulating and executing policy decisions. There is a need to acknowledge the hard work done by civilian personnel  at many levels to make pension awards workable. There is no room for suspicion, resentment or hostility towards those sections of Government of our country in case some perceived injustice, real or otherwise, afflicts pensionary awards.

Some Issues To Remember About OROP and Pension Fixations In 7CPC

All veterans are aware that there are a number of litigations on pensionary matters presently pending in AFTs, Hon'ble High Courts and the Hon'ble Supreme Court. Considering the large numbers involved, it would be futile even to attempt to list them all.

However, this blog-post was felt necessary after having come across some rather alarming and disturbing online posts by commentators who have been quite central to online debate on these matters, starting right from the era of Rank Pay litigation.

More than the wording of these online comments, it is the sentiment and reasoning underlying the posts that give rise to a feeling of unease. These issues affect a large number of ESM, so hubris on account of one's own views and/or of a rather vested approach of being guided by sanctity of pensionary awards of only a select class, can't contribute towards generating awareness or suggesting remedies in consultative fashion for a resolution.

Most aspects have already been touched upon in the past. But now, as the OROP litigation moves towards a decisive phase, it could, perhaps, be useful to not lose sight of some features of the complex issue as listed in this brief and far from comprehensive list. Following the links provided, it may be possible to arrive at a more complete picture rather than through brief interactions on social-media:

• The tell tale signatures of disadvantages in OROP to some rank-QS combinations need to be looked at analytically👉 in this blog post 

• How the stress on just "One Rank" in OROP and ignoring the even more crtical need of a "notional progression" for OROP fixation can cause non-redressal of anomalous fixations for some QS-rank combinations 👉 as outlined here. 

• There may be a need to examine how truthful and rational the methodology of OROP fixation was even in terms of using the "average of minimum and maximum" rather than the maximum value of pension of a QS-rank combination in 2013 and to try to arrive at an understanding of the glaring gaps that show up in graphical data 👉 shown in this blog-post. 

• Equally important is a need for esteemed interlocuters to re-examine their apparent endorsements of what some notings on files seem to assert while justifying the non-revision of OROP. The actual situation indicates those assertions could have less than valid application in many cases 👉 as explained here.

 

7 CPC Concordance Tables And Their Effect On Pay Parity Status: Lt Col

(Updated): This has been elaborated upon in very many blog posts, on this blog and else where. The following annotations made on the 7CPC concordance table for Lt Col are an attempt to illustrate how the absence of a direct co-relation between Notional Pay and QS makes an equitable parity impossible between pensions of older retirees and pensions of those retiring after 01 Jan 2016. This is particularly significant for ranks that are attained on time-bound basis viz., Lt to Col (TS) at present.

{Edit: These issues have become even more relevant now in view of some documents, obtained through RTI by an eminent blogger and posted by him online, in which an assertion has been made by CGDA that with the implementation of 7CPC, to quote the document, "The notional pay formula brings all past pensioners to current rates, almost as if they were serving under VIIth CPC". In the case of Officer veterans, who retired before 31 Dec 2004, in ranks which are nowadays time-bound, the veracity of such assertions does need a circumspect examination. They may well have just grounds to "clamour for" a relook at the whole matter of pension fixations under OROP and now 7CPC}

 Essentially, why the method of using formulas for notional pay between successive pay commissions can’t deliver on principle of “equal remuneration for equal work” is that it does not normalise notional pay across CPCs by not keeping in view how fast, in terms of QS, a Lt Col serving or retiring past 01 Jan 2016 reaches an increment stage in the 7CPC matrix compared to a pre December 2004 Lt Col retiree.

This becomes very clear in the case of Lt Col(TS) retiree of pre 16 Dec 2004 era and Lt Col of VI CPC and Lt Col of VII CPC. All the three are time-bound ranks. What the concordance table implies, in effect, is that if an Officer retired in rank of Lt Col(TS) after serving for around 30 years in regime of 4 CPC, or about 25 years during regime of V CPC, then the notional pay of those Lt Col veterans would be equal to pay of a Lt Col with about 16 years of service, now also a time-bound rank, during regimes of VI and VII CPC.

In other words, with the Concordance Tables, an Officer who retired during period of 5 CPC as Lt Col (TS) in November 2004 or earlier with a service of 28 to 29 years, would have his 7 CPC notional pay fixed from 01 Jan 2016 equivalent to the pay of a Lt Col in January 2016 having a qualifying service of approximately 16 to 17 years, in spite of both being time-bound ranks.

The concordance table and notional pay method do not even begin to touch upon the issue of how notional pay of a Lt Col of IV and V CPC with more than 26 years of service, based on parity and equity principles cited in VII CPC report, would in fact need to have his “notional pay” fixed at par with a Col (TS) of VI and VII CPC with equal service. {Edit: But in light of very recent legal developments, it may be in order to stop seeking pension parity with pension of a specific "rank". Ranks, as mentioned previously, are not a "constant" construct. They alone can't provide a true measure of entitlement of a deferred wage or provide a basis of parity for time-bound ranks. Parity of pension for Officers of a specific type of commission who retired in time-bound ranks of their era of service has to be based on broad principles cited in the pay commission report itself and on constant, defining measures of service rendered by such veteran officers in the past viz., the type of their commission and their QS in their time-bound rank}

In the present case, parity is not maintained even in the same rank based on years of service.

Formulas applied from one pay commission to the next one can lead to a reasonably rational fixation of the 7 CPC notional pay for most cases. But in the case of armed forces veteran officers who had retired prior to 31 Dec 2004, unless another formula is applied for the pay-rank-QS combination existing prior to 16 Dec 2004 and the same combination post that date, this notional pay fixed by this manner of merely using formulas for pay from one pay commission to the next will always fall well short of what an equitable notional progression would have brought about as suggested in (please click to access —->) this table.

A Few Queries On Concordance Tables For Pensioners In Rank Of Major

It has been nearly 21 months since some issues were raised in the previous blog-post, with the example of the rank of Lt Col, as to how the concept of notional pay would need to be applied for those who had retired prior to 01 Jan 2006, especially many of those armed forces officers who had retired prior to implementation date of phase-I recommendations of AV Singh Committee. 

True to expectations, the Concordance Tables, that were finally released about four months ago, raised a few doubts as to whether the tables had approached the matter from point of view of resolving existing anomalies and that of ensuring parities between pensions of older and current pensioners, a principle that was strongly endorsed by VII CPC itself. Aspects of fairness and equity thus continue to remain an issue. 

What may appear to be infirmities or incongruities, leading to possible apprehensions of an award not being fully equitable, can best be examined in concordance tables applicable to pensioners in armed forces officer ranks which are now time-bound. The most significant example would be Concordance Tables for the ranks of Major, Lt Col(TS) and Lt Col. An extract of Concordance Table for the rank of Major is placed as follows: {The full set of tables is viewable on DESW PCDA web-site through this link }

The first example is the Concordance Table for the rank of Major. 

The first thing for pre 2006 (I'll repeat here, 2006) Major retirees to note is that the maximum notional pay of Rs. 118100/- in the last column should, by all logic, correspond to the 7CPC pay of a Major with about 25 years of QS, even though no Officer with that QS would be in the rank of Major nowadays. 

That means the highest pay of 14850/-+975/- of a Major retiree in the period 01-01-1996 to 31 Dec 2005 corresponds to the equivalent 2016 notional pay of 101900/-, which when referring to the matrix should be the pay of a Major of 2016 having a QS of about 20 years. Now those Major retirees of the period 01-01-1996 to 31 Dec 2005 who were drawing a basic pay of 14850+975 at the time of retirement can compare their own QS at retirement with the figure of 19 ~ 20 years at which their fixed "notional pay" of 101900/- would be earned by someone serving/retiring as Major in 2016 or later.

The question arises whether or not first three columns of basic pay (01/01/86 to 31/12/95, 01/01/96 to 31/12/2005 and 01/01/2006 to 31/12/2015) as well as the fourth column for "pay range from 01/01/2006 to 31/12/2015, have attempted to take into cognizance the equivalence of qualifying service rendered by retirees in that time-bound rank in the three distinct time-frames mentioned above. At first glance, it does not appear to be the case. 

At all stages of the concordance table, has any consideration been applied to qualifying service of a Major who retired in the period 01/01/1996 to 31/12/2015 vis-a-vis the qualifying service of the Major drawing that so called "notional/equivalent" pay for the period 01/01/2006 to 31/12/2015? The table, with no reference to qualifying service, equates the starting pay of Major with a service of 11 years at the beginning of the scale for the period 01/01/96 to 31/12/2005 with the starting pay of Major with a service of approximately 6 years for the period 01/01/2006 to 31/12/2015.  

The table also does not appear to provide for the fact that a Major from the period 01/01/2006 to 31/Dec/2015 would be in the pay-band of Lt Col starting at a QS of app 13 years on time-bound basis and that the parity based equivalence of the older Maj Pensioner from the period 01/01/1996 to 31/12/1995 would be the corresponding pay of Lt Col with equivalent service in period 01/01/2006 to 31/12/2015.

Therefore the title  "Corresponding Level wef 01/01/2016" at top of the table is based on the rather ambiguous premise that any value in any particular column "corresponds" to juxtaposed values in the same rows in other columns. It is like saying 5 apples of 1996-2005 correspond to 8.6 oranges of 2006-2015.

The relevance of the argument for basing pension equivalence/parity, in the case of ranks which are time-bound, on rational notions, as against accountancy tables, can be discerned in logic advanced in this old blog post.

More to follow on tables applicable to Lt Col (TS) and Lt Col.

The Notional Pay Based VII CPC Pension Formulation : Lt Col And Equivalent Ranks

It is quite possible that theorizing on outcomes, based on bare assumptions, can lead to grossly inaccurate and misleading views on how re-formulation of VII CPC pensions would shape up.

The increment based formulation as recommended by VII CPC, now having been modified to a calculation based on notional pays in successive pay commissions, could resolve a lot of anomalies related to OROP provided it is implemented keeping firmly in view how OROP and the VII CPC matrix need to form part of a whole.

The scope of this blog post is restricted to the retirees in rank of Lt Col for the sake of simplicity. The intention is to illustrate how the qualifying service of a retiree, a concept central to OROP, needs to be taken into account during any exercise involving fixation of pensions in the VII CPC matrix.

Some key issues arise :

• Notional pay of most VI CPC Lt Col retirees as determined by the notional pay method will, in all probability will be in order as no major changes have taken place between Vi and VII CPCs in terms of service such as service required for promotions, rank structure etc.  

• Lt Cols who retired before 01 Jan 2006, especially those who retired prior to implementation of AV Singh Committee (Dec 2004), are likely to have more qualifying service than those who retired after 01 Jan 2006 and as a consequence have less pension for the same qualifying service applicable in the case of a Lt Col retiring after implementation of VII CPC. All affected know Lt Col rank became applicable on time-bound basis at a qualifying service of 13 years with effect from 16 Dec 2004.

• For fixing the VII CPC notional pay of pre 01 Jan 06 Lt Col retirees, some mechanism may have to be found to make sure their VII CPC notional pay finally arrived at should not be less than the VII CPC notional pay of a VI CPC Lt Col retiree with equal qualifying service.

• Then, there is the old issue of the need of parity of pensions of older Lt Col retirees with pensions of Col(TS) with equal qualifying service, if they had put in a service of 26 years or more.

Full clarity will emerge only when detailed instructions are issued on re-formulation of VII CPC pensions of armed forces veterans. The following table is meant to illustrate how the re-formulation should proceed :

{Update: With the recent release of orders for calculating "Notional Pay", a detailed revision of this blog-post has become necessary. An update will follow}

Some Notions Of Progression For Pension Fixation

Some time ago, I had come across a reference to "notional fixation" in pay-bands applicable to Major for determining the OROP pensions of older pensioners in Major rank, considering no one retires in Major rank anymore due to speedier time-bound promotions. Similar concerns apply in the case of fixation of 7 CPC pensions.

The concept of "notional fixation" was excellent but the rider about restricting the "progression" to a Major's pay-band didn't appeal so much. I had given my opinion, for what it was worth, in a previous blog-post.

To repeat myself, when it comes to time-bound ranks, pension parity needs to be based firstly on the nature of enrolment/commission and the cadre, then on "time" i.e. qualifying service and only after that on the "rank" which is not a constant measure of service rendered in the case of time-bound ranks. Attributes of time bound ranks have changed over the years. In their case, the true measure of service rendered is, well, the service rendered, in number of years. Here's a link to this concept. Again, it applies to 7 CPC as much as OROP.

While working on the co-relationship of qualifying service with stage and level numbers of the 7 CPC Matrix in the previous blog post, it became apparent that the "notional progression" can't be a uni-directional one, leading vertically downwards in the same pay-band.

Such a "notion" budgets for imaginary increments but not the enhancements in grade pay that automatically come with time in reality. So, for a correct "notional progression", the progression has to be downwards and sideways based on what actually happens to those currently serving.

The following example indicates the manner of progression of pay for time-bound ranks which provides a rational basis for fixing 7 CPC pensions of older pensioners.

A critical and basic requirement for the validity of such a downward-sideways progression is, if the older pensioner had been in service after 16 Dec 2004, would he or would he not have been eligible, based on the QS in the extreme left column, for time-based progression to the next higher level shown in the progression path in the table. If the answer to that is in the affirmative, then fixing his pension in the lower pay-band would be a straight-forward case of discrimination.

Even though implementation of 7 CPC pay fixation is reportedly being held in abeyance, the principles of pension parity, as illustrated in the following table, would still be valid regardless of any enhancements in pay levels that might come about):

{Edit}: A little clarification appears in order. The notional progression as suggested in the table needs to be governed by some constraints. 

Notional pay, hence pension, of an older retiree in a certain rank must progress to the level suggested in the table provided currently serving Officers in the older retirees' cadre and with the same type of commission progress on basis of time, i.e. length of service alone, to the higher level as shown.

The progression would, by and large, be applicable up to the rank of Major in most types of commission. But progression to the notional level of current level of Lt Col at service of 13 years may exclude those types of commissions with which Officers do not currently progress automatically to rank of Lt Col at a service of 13 years.

Similarly, notional progression to pay, hence pension, of Col(TS) at a QS of 26 years, as suggested in the table, would be justified for those types of commission with which Officers currently get the rank of Col(TS) after completing a service of 26 years.

A Straight Forward Set Of Pension Parity "Equations" For 7 CPC : Maj, Lt Col, Col(TS) Pensions {Pre Dec 2004 Retirees}

{Matrix Figures Updated}

At the present moment, there is no sign of any movement on implementation of 7 CPC recommendations regarding pensions of armed forces veterans.  {Edit: The 7 CPC recommendations were subsequently implemented using a inter-CPC formula based "notional pay" method instead of using increments, which too did not attempt to normalise fixation of "notional pay" based on qualifying service.}

If and when some orders are issued, these are likely to be only for fixing pensions by multiplying either VI CPC or OROP pensions by 2.57. Multiplying VI CPC pensions by 2.57 is likely to yield January 2016 pensions nearly equal to or less than OROP combined with the January 2016 DR.

In a scenario like that, with OROP anomalies still not sorted out, it may be hoping for the impossible to expect rationalization of the good old 20 years Major and 26 Years Lt Col pension anomalies.

Enough has been posted about that. Here is a brief summing up, as a kind of "impossible to realize wish-list", in the form of two "equations":

P_{L11;i(8--->20)} = P_{L12A;i(1--->13)} for older ( pre Dec 2004) Maj pensioners.

P_{L11;i(21--->28)} = P_{L12A;i(14--->20)} = P_{L13;i(12--->18)} for older ( pre Dec 2004) Maj and Lt Col pensioners with PCs.

P ---> Pension corresponding to a specific increment-stage cum matrix-level combination.

L ---> 7 CPC Matrix Level.

i ---->7 CPC Matrix index number increment stage for level.

As an example, the first equation states pension calculated for level 11 increment stage 9 should equal the one for Level 12A index increment stage 2, but won't.

Pensions corresponding to appropriate cells can be calculated based on the pay in the matrix as follows and then checked for the requisite but eternally elusive parity as per equations above (even though implementation of 7 CPC pay fixation is reportedly being held in abeyance, the of principles of pension parity, as illustrated in the following tables, would still be valid regardless of any enhancements in pay levels that might come about):

{Update: With recent, May 2017, amendments to IOR (multiplication factors), the figures displayed in different “levels” may changed and will be are now updated in a subsequent this blog-post. as and when amended Matrix is made available. The suggested manner of parities for pre 2016 retirees in time bound ranks still remains relevant}

Pay Band à	15600-39100	37400-67000
Grade Pay -à	6600	8000	8800
Level –>	11	12A	13
1	69400	121200	130600
2	71500	124800	134500
3	73600	128500	138500
4	75800	132400	142700
5	78100	136400	147000
6	80400	140500	151400
7	82800	144700	155900
8	85300	149000	160600
9	87900	153500	165400
10	90500	158100	170400
11	93200	162800	175500
12	96000	167700	180800
13	98900	172700	186200
14	101900	177900	191800
15	105000	183200	197600
16	108200	188700	203500
17	111400	194400	209600
18	114700	200200	215900
19	118100	206200
20	121600	212400
	125200
	129000
	132900
	136900

Even though such charts have been prepared and shared in dozens of other formats, based on the above considerations a rough indicator of the manner in which 7 CPC pensions need to be calculated is as follows:

Pay Band	15600-39100			37400-67000
Grade Pay	6600			8000		8700
Entry Pay (EP)	25980			45400		48900
Level	11			12A		13
Qualifying Service	Increment Stage		Increment Stage			Increment Stage
6	1	69400
7	2	71500
8	3	73600
9	4	75800
10	5	78100
11	6	80400
12	7	82800
13	8	85300 (Pay of level 12A should apply for calculating 7 CPC Pensions)	1		121200 ✓
14	9	87900 (Pay of level 12A should apply for calculating 7 CPC Pensions)	2		124800 ✓
15	10	90500 (Pay of level 12A should apply for calculating 7 CPC Pensions)	3		128500 ✓	1	130600
16	11	93200 (Pay of level 12A should apply for calculating 7 CPC Pensions)	4		132400 ✓	2	134500
17	12	96000 (Pay of level 12A should apply for calculating 7 CPC Pensions)	5		136400 ✓	3	138500
18	13	98900 (Pay of level 12A should apply for calculating 7 CPC Pensions)	6		140500 ✓	4	142700
19	14	101900 (Pay of level 12A should apply for calculating 7 CPC Pensions)	7		144700 ✓	5	147000
20	15	105000 (Pay of level 12A should apply for calculating 7 CPC Pensions)	8		149000 ✓	6	151400
21	16	108200 (Pay of level 12A should apply for calculating 7 CPC Pensions)	9		153500 ✓	7	155900
22	17	111400 (Pay of level 12A should apply for calculating 7 CPC Pensions)	10		158100 ✓	8	160600
23	18	114700 (Pay of level 12A should apply for calculating 7 CPC Pensions)	11		162800 ✓	9	165400
24	19	118100 (Pay of level 12A should apply for calculating 7 CPC Pensions)	12		167700 ✓	10	170400
25	20	121600 (Pay of level 12A should apply for calculating 7 CPC Pensions)	13		172700 ✓	11	175500
26	21	125200 (Pay of level 13 should apply for calculating 7 CPC Pensions)	14		177900(Pay of level 13 should apply for calculating 7 CPC Pensions)	12	180800 ✓
27	22	129000 (Pay of level 13 should apply for calculating 7 CPC Pensions)	15		183200 (Pay of level 13 should apply for calculating 7 CPC Pensions)	13	186200 ✓
28	23	132900 (Pay of level 13 should apply for calculating 7 CPC Pensions)	16		188700 (Pay of level 13 should apply for calculating 7 CPC Pensions)	14	191800 ✓
29	24	136900 (Pay of level 13 should apply for calculating 7 CPC Pensions)	17		194400 (Pay of level 13 should apply for calculating 7 CPC Pensions)	15	197600 ✓
30		141000(Pay of level 13 should apply for calculating 7 CPC Pensions)	18		200200 (Pay of level 13 should apply for calculating 7 CPC Pensions)	16	203500 ✓
31		145200(Pay of level 13 should apply for calculating 7 CPC Pensions)	19		206200 (Pay of level 13 should apply for calculating 7 CPC Pensions)	17	209600✓
32		149600(Pay of level 13 should apply for calculating 7 CPC Pensions)	20		212400(Pay of level 13 should apply for calculating 7 CPC Pensions)	18	215900 ✓
33						19