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Maj (Retd) Muhammad Ali Munim Deputy Manager (Security), JPCL, Jamshoro

Sultan Muhammad Zafar General Manager (TH) GHCL 197-Wapda House, Lahore, Subject: SHOW CAUSE NOTICE UNDER CLAUSE 5 (IV)(B) OF WAPDA E & D RULES, 1978 Letter # CEO/GHCL/Admn/PF-1834/9959-61 dated 27th December 2012 refers 1) It is submitted that regarding my attachment with office of General Manager (Thermal) Wapda House Lahore, I have filed a Constitutional petition No. 761/2011, wherein the Honble High Court of Sindh (Circuit Court) Hyderabad has been pleased to suspended on 6th September 2012 the orders of GM (Thermal) dated 04-09-2012 and orders of JPCL dated 05-09-2012. Consequent to it, there have been different hearings in the said case from 6th September 2012 until 28th November 2012. The order dated 6th September 2012 passed in my Constitutional Petition by aforesaid Honorable Court are still in the field & operative as these were neither revoked nor recalled specifically. 2) It is regretted to state that despite the presence of aforesaid Court Orders, I was ordered by the department on 28th November 2012 to be relived from duties at JPCL Jamshoro and with the direction to report for duty in office of GM (Thermal). The said direction by the department was again in the violation of Court Orders as stated in Para # 1 here-in-above. 3) I received a show cause notice from the department vide their letter # CEO/GHCL/Admn/PF-1834/9959-61 dated 27th December 2012; wherein I have been asked to show cause as to why I did not join the duty in (reported) violation of aforesaid letter. 4) As I consider, perceive and believe that office order dated 28th November 2012 is unconstitutional, ultra vires; and against the Court Orders; hence I did not comply with the instructions. 5) Further, it is added and humbly brought to your kind notice that since my family is settled in Jamshoro, I have to travel in between Lahore & Jamshoro. Moreover, one of my daughters is studying in Pakistan Navy Engineering College Karachi; who is likely to go abroad for study. Presently she is living in a hostel over there and my persistence absence from my house will cause serious hazards to her education and even to the education of my other seven school/college going children at Jamshoro. 6) It is therefore humbly supplicated that keeping in view the above, instant Show Cause notice be cancelled/withdrawn in order to reduce the hardship and family sufferings.

Maj (Retd) Muhammad Ali Munim