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Final Application

Final Application

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Published by Khalid Mahmood
app, to H, C,J, Pakistan for justice and protection
app, to H, C,J, Pakistan for justice and protection

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Published by: Khalid Mahmood on May 06, 2012
Copyright:Attribution Non-commercial

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10/02/2013

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1/58(Attached herewith 37 Documents consisting of 52 leaves/62 Pages)
 To The Most Honourable Chief Justice of Pakistan,Islamabad.Subject:
APPEAL AGAINST THE JUDGEMENT OF MR.MUHAMMAD AYUB MALIK, MEMBER-III OF THEPUNJAB SERVICE
TRIBUNAL, LAHORE IN APPEAL NO.
 
937 OF 2009 (ATTACHED HEREWITH-01).Dr. Khalid Mahmood
(Room No. 35 Abbas Manzal) Doctors HostelNear District Courts Bahawalpur… APPELLANT
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 Yourgoodself NOT ONLY because I have already spent more thanRs. 100,000/- paying the lawyer’s fees and in running abouthere and there in spite of being jobless, almost broke andpenniless BUT ALSO because the respected Member PunjabService 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 fromservice order dated 13-06-2001” were not rebutted by mylearned council. Earlier in Point 5 of the judgment, MPST findsthe contentions- (a statement of beliefs and opinions which areyet to be proved according to advanced Oxford learner’sdictionary) of my lawyer had no force a subjective view, of course, of MPST. So, here, I most respectfully ask of Yourgoodself to allow me to present submissions before your goodhonor. My submissions will be under the following headings:
PTO
 
2/58(Attached herewith 37 Documents consisting of 52 leaves/62 Pages)1.
I will REBUT the charges against me levelled by the SecretaryHealth Government of the Punjab in the “DISMISSAL FROMSERVICE ORDER” DATED 13-06-2001” (ATTACHED HEREWITH-2) and will (INSHAALLAH) prove it UNLAWFUL (based onOPINIONS formed by the Secretary Health Punjab on the wrongand prejudicial input from the Inquiry Officer, the DirectorHealth Multan, and the Director Health Bahawalpur- Dr. FazalMahmood).
2.
I will rebut the Secretary Health Punjab letter dated 03-04-2009,written in compliance of the orders of Honorable LahoreHigh Court dated; 09-03-2009 (declaring my request i.e to RE-VISIT my case REASONABLE and DIRECTING the concernedauthority / authorities to make decision on my applications tothe Secretary Health Punjab dated 12-07-2001 and the ChieSecretary Punjab dated; 20-08-2003). Instead of consideringand re-visiting my case, the Secretary Health Punjab in hisletter dated 03-04-2009 called my request “TIME BARRED” –which I believe amounts to contempt of Lahore High Courtorder dated 09-03-2009. Though the spirit of this letter of theSecretary Health Punjab dated 03-04-2009 is hostile and as Ihave already written amounts to contempt of Lahore HighCourt Order dated 09-03-2009 but I being an OPTIMISTIC see aPOSITIVE point in this also i.e. the Secretary Health Punjab hasHALVED the charges against me i.e. according to this 03-04-09letter of the Secretary Health Punjab (written in compliance of Honorable L.H.C order dated 09-03-2009) the charge againstme is,
I quote.
“2. Dr. Khalid Mahmood was proceeded under PCS (E&D) rules1999 on the charge of willful absence from duty w.e.f 11-11-1999.” (Attached herewith_03).While according to the Secretary Health Punjab orderdated 13
th
June, 2001 (i.e. dismissal from service order) I wasproceeded against under the provisions of PCS (E&D) Rules1999 on the charge of misconduct i.e. willful absence fromduty 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).
PTO
 
3/58(Attached herewith 37 Documents consisting of 52 leaves/62 Pages)
In his “report and comments”, the Senior Law Officer(SLO) Govt. of the Punjab, Health Department on behalf of theSecretary Health Punjab and Chief Secretary Punjab sent toMPST in 2009 has also HALVED the charges against me. In thevery first sentence under the heading of PRELIMINARYOBJECTIONS,
the SLO writes and I quote:
“The penalty of dismissal from service under E&D rules 1999 was imposedupon the appellant (i_e. on me) on the charge of un-authorizedabsence vide order dated 13-06-2001. (Attached herewith_04). Your lordship, your honor can see that the chargesagainst me in the “Dismissal from the service order” dated; 13-06-2001 are TWO in number i.e. willful absence from dutyw.e.f. 11-11-1999 / non-compliance of transfer orders. I was illthen. I could not fight except writing an application to theSecretary Health Punjab on 12-07-2001 to re-visit my case andagain on 20-08-2003 to the Chief Secretary Punjab to re-visitmy case. (Attached herewith-05-06 respectively).But in 2009 when I could arrange some money tofight for my rights and went first to honorable LHC whichgraciously declared my request (to revisit my case)REASONABLE and DIRECTED the concerned authorities tomake decision on my appeals against 13-06-2001 “Dismissalfrom Service Order” of the Secretary Health Punjab, theauthorities immediately went on back foot and halved thecharges against me i.e. NO MENTION OF THE NONCOMPLIANCE OF TRANSFER ORDER” was made
either by TheSecretary Health Punjab in his letter dated April 03,2009
(written in compliance of the orders of Honorable LHCorder dated 09-03-2009-attached herewith 07)
or by theSenior Law Officer of Health Department
Lahore in his“reports and comments” on behalf of The Secretary HealthPunjab and Chief Secretary Punjab sent to Member PST in theend of 2009. Your lordship, I request Your goodself to look into this.
What I
 
understand is
 
: the transfer order was from the
PTO

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