1(Attached herewith are 37 Documents consisting of 52-leaves/62-pages) 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 underregistered cover from GPO, Lahore.2- On February 01, 2011 I sent this application to your honor by Post underregistered 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 aswell 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 theearliest asthings are getting from bad-to-worse for me not only economically but alsootherwisewith 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
2(Attached herewith are 37 Documents consisting of 52-leaves/62-pages)
Dated 07-09-2011
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 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 inspite of being jobless, almost broke and penniless BUT ALSObecause 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 HealthPunjab 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
3(Attached herewith are 37 Documents consisting of 52-leaves/62-pages)
and opinions which are yet to be proved according to advancedOxford learner’s dictionary) of my lawyer had no force – asubjective view, of course, of MPST. So, here, I most respectfullyask of Your goodself to allow me to present submissions beforeyour good honor. My submissions will be under the followingheadings:
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 on OPINIONSformed by the Secretary Health Punjab on the wrong andprejudicial input from the Inquiry Officer, the Director HealthMultan, 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 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 to theSecretary Health Punjab dated 12-07-2001 and the Chief Secretary Punjab dated; 20-08-2003). Instead of considering andre-visiting my case, the Secretary Health Punjab in his letterdated 03-04-2009 called my request “TIME BARRED” – which Ibelieve amounts to contempt of Lahore High Court order dated09-03-2009. Though the spirit of this letter of the SecretaryHealth Punjab dated 03-04-2009 is hostile and as I have alreadywritten amounts to contempt of Lahore High Court Order dated09-03-2009 but I being an OPTIMISTIC see a POSITIVE point in thisalso i.e. the Secretary Health Punjab has HALVED the chargesagainst me i.e. according to this 03-04-09 letter of the SecretaryHealth Punjab (written in compliance of Honorable L.H.C orderdated 09-03-2009) the charge against me is,
I quote.
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Origional & Final Application
APP. TO Honouirable Chief Justice of Pakistan for justice.
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