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1aplication the Chief Justice of Pakistan for help and justice. 00196782-12-12-2011-again-being-loaded-on16-07-2012 (1)

1aplication the Chief Justice of Pakistan for help and justice. 00196782-12-12-2011-again-being-loaded-on16-07-2012 (1)

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Published by Khalid Mahmood

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Published by: Khalid Mahmood on Dec 23, 2013
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12/23/2013

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1 Page (Attached Herewith 37 Documents Consisting Of 52 Leaves/62 Pages )
 [Type text] [Type text] PTO 
YOUR HONOR (The most honorable Chief Justice of Pakistan, Islamabad).
This is the fourth time I am sending this application to Your Lordship. 1- On January 28, 2011, I sent this application to your honor by Post under registered cover from GPO, Lahore. 2- On February 01, 2011, I sent this application to your honor by Post under registered cover from GPO, Lahore. 3- On 17-05-2011, I sent this application to your honor from Bahawalpur GPO. This time I sent
at your Lordship’s Official Residential address in Islamabad as well as in Quetta.
Sir, Now I am sending this application to your honor on Email address: Email:mail@supremecourt.gov.pk It is most humbly requested that my case may kindly be taken up at the earliest as things are getting from bad-to-worse for me not only economically but also otherwise with the passage of time. Thanking your honor in anticipation, Yours obediently,
Khalid Mahmood, MBBS
R/O:Room # 35,Doctors Hostel, Abbas Manzil,Near District Courts, Bahawalpur. Mob #:0334-6871505 khalidmahmood13@gmail.com Dated 07-09-2011 PTO
 
2 Page (Attached Herewith 37 Documents Consisting Of 52 Leaves/62 Pages )
 [Type text] [Type text] PTO 
To The Most Honourable Chief Justice of Pakistan, Islamabad. Subject:
APPEAL AGAINST THE JUDGEMENT OF MR. MUHAMMAD AYUB MALIK, MEMBER-III OF THE PUNJAB SERVICE
TRIBUNAL, LAHORE IN APPEAL NO. 937 OF 2009 (ATTACHED HEREWITH-01). Dr. Khalid Mahmood
 (Room No. 35 Abbas Manzal) Doctors Hostel
Near District Courts Bahawalpur… APPE
LLANT
VERSUS
1.
 
The Secretary Health, Government of the Punjab, Lahore. 2.
 
The Chief Secretary, Govt. of the Punjab, Lahore.
RESPONDENTS My Lord,
Kindly allow me to present my case myself before Your goodself NOT ONLY because I have already spent more than Rs. 100,000/-
paying the lawyer’s fees
and in running about here and there in spite of being jobless, almost broke and penniless BUT ALSO because the respected Member Punjab Service Tribunal (M.P.S.T) has mentioned in (Point 7) of his judgment that observations / Charges
against me levelled / made by the Secretary Health Punjab in the “Dismissal from
service order dated 13-06-
2001” were not rebutted by my learned council. Earlier
in Point 5 of the judgment, MPST finds the contentions- (a statement of beliefs
and opinions which are yet to be proved according to advanced Oxford learner’s
dictionary) of my lawyer had no force
 –
 a subjective view, of course, of MPST. So, here, I most respectfully ask of Your goodself to allow me to present submissions before your good honor. My submissions will be under the following headings: 1.
 
I will REBUT the charges against me levelled by the Secretary Health Government of the Punjab in the
“DISMISSAL FROM SERVICE ORDER” DATED
 13-06-
2001”
 
 
3 Page (Attached Herewith 37 Documents Consisting Of 52 Leaves/62 Pages )
 [Type text] [Type text] PTO 
(ATTACHED HEREWITH-2) and will (INSHAALLAH) prove it UNLAWFUL (based on OPINIONS formed by the Secretary Health Punjab on the wrong and prejudicial input from the Inquiry Officer, the Director Health Multan, and the Director Health Bahawalpur- Dr. Fazal Mahmood). 2.
 
I will rebut the Secretary Health Punjab letter dated 03-04-2009,written in compliance of the orders of Honorable Lahore High Court dated; 09-03-2009 (declaring my request i.e to RE-VISIT my case REASONABLE and DIRECTING the concerned authority / authorities to make decision on my applications to the Secretary Health Punjab dated 12-07-2001 and the Chief Secretary Punjab dated; 20-08-2003). Instead of considering and re-visiting my case, the Secretary Health Punjab in his letter dated 03-04-2009 ca
lled my request “
TIME BARRED
” –
 which I believe amounts to contempt of Lahore High Court order dated 09-03-2009. Though the spirit of this letter of the Secretary Health Punjab dated 03-04-2009 is hostile and as I have already written amounts to contempt of Lahore High Court Order dated 09-03-2009 but I being an OPTIMISTIC see a POSITIVE point in this also i.e. the Secretary Health Punjab has HALVED the charges against me i.e. according to this 03-04-09 letter of the Secretary Health Punjab (written in compliance of Honorable L.H.C order dated 09-03-2009) the charge against me is,
I quote.
 
“2. Dr. Khalid Mahmood was proceeded under PCS (E&D) rules 1999 on the
charge of willful absence from duty w.e.f 11-11-
1999.” (
Attached herewith_03). While according to the Secretary Health Punjab order dated 13
th
 June, 2001 (i.e. dismissal from service order) I was proceeded against under the provisions of PCS (E&D) Rules 1999 on the charge of misconduct i.e. willful absence from duty w.e.f. 11-11-1999 / non-compliance of transfer orders (Point 1 of dismissal from service order dated 13-06-2001). (Attached herewith 02).
In his “report and comments”, the Senior Law Officer (SLO)
Govt. of the Punjab, Health Department on behalf of the Secretary Health Punjab and Chief Secretary Punjab sent to MPST in 2009 has also HALVED the charges against me. In the very first sentence under the heading of PRELIMINARY OBJECTIONS,
the SLO writes and I quote:
 
“The penalty of dismissal from service under E&D rules

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