Welcome to Scribd, the world's digital library. Read, publish, and share books and documents. See more
Download
Standard view
Full view
of .
Save to My Library
Look up keyword
Like this
0Activity
0 of .
Results for:
No results containing your search query
P. 1
75981485-18-12-2011

75981485-18-12-2011

Ratings: (0)|Views: 1 |Likes:
Published by Khalid Mahmood
app,HCJ Pakistan for justice and help
app,HCJ Pakistan for justice and help

More info:

Published by: Khalid Mahmood on Apr 19, 2012
Copyright:Attribution Non-commercial

Availability:

Read on Scribd mobile: iPhone, iPad and Android.
download as DOCX, PDF, TXT or read online from Scribd
See more
See less

04/19/2012

pdf

text

original

 
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 coverfrom GPO, Lahore.2- On February 01, 2011, I sent this application to your honor by Post under registered coverfrom 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.pkIt is most humbly requested that my case may kindly be taken up at the earliest asthings are getting from bad-to-worse for me not only economically but also otherwisewith 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.comDated 07-09-2011PTO
 
2 Page (Attached Herewith 37 Documents Consisting Of 52 Leaves/62 Pages )
 [Type text] [Type text] PTO 
ToThe 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. 937OF 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.
RESPONDENTSMy Lord,
Kindly allow me to present my case myself before Your goodself NOT ONLYbecause 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 andpenniless 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 submissionsbefore your good honor. My submissions will be under the following headings:1.
 
I will REBUT the charges against me levelled by the Secretary Health Governmentof 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 onOPINIONS formed by the Secretary Health Punjab on the wrong and prejudicialinput from the Inquiry Officer, the Director Health Multan, and the DirectorHealth Bahawalpur- Dr. Fazal Mahmood).2.
 
I will rebut the Secretary Health Punjab letter dated 03-04-2009,written incompliance 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 theconcerned authority / authorities to make decision on my applications to theSecretary 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 HealthPunjab in his letter dated 03-04-2009 ca
lled my request “
TIME BARRED
” –
which Ibelieve 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 ishostile and as I have already written amounts to contempt of Lahore High CourtOrder dated 09-03-2009 but I being an OPTIMISTIC see a POSITIVE point in thisalso 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 incompliance 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 theprovisions of PCS (E&D) Rules 1999 on the charge of misconduct i.e. willfulabsence from duty w.e.f. 11-11-1999 / non-compliance of transfer orders (Point 1of dismissal from service order dated 13-06-2001). (Attached herewith 02).
In his “report and comments”, the Senior Law Officer (SLO)
Govt. of thePunjab, 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,
theSLO writes and I quote:
 
“The penalty of dismissal from service under E&D rules

You're Reading a Free Preview

Download
/*********** DO NOT ALTER ANYTHING BELOW THIS LINE ! ************/ var s_code=s.t();if(s_code)document.write(s_code)//-->