Professional Documents
Culture Documents
Respected Sir,
With due veneration and profound regard I have the honour and
presently working as copy clerk to the office of the District & Sessions Judge,
Religious: Islam.
Qualification: B.Com
Yours Obediently,
To
The Director HRD,
P.O. Box 1890,
Islamabad.
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that some posts of Accounts Officer lying vacant under
Yours Obediently,
Islah-ur-Rahman,
Budget & Accounts Examiner,
Khushab.
To
The Director General,
Federal Investigation Agency,
Islamabad.
Respected Sir,
steno-typist lying vacant under your kind control and advertised in Daily
requested that I may kindly be given a chance to work under your kind
control.
Yours Obediently,
Muhammad Imran,
Ahlmad Civil Courts,
Khushab.
Forwarded in original to the Worthy District & Sessions Judge,
Khushab.
16.09.2012 to 31.10.2012
(Shakir Hassan)
Addl. District & Sessions Judge,
KHUSHAB.
AFFIDAVIT
Courts Sargodha.
Deponent
AFFIDAVIT
Sargodha.
Deponent
To
The Honble District & Sessions Judge,
Sargodha.
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that some posts of stenographer are lying vacant under
requested that I may kindly be given a chance to serve under your kind
control.
Religious: Islam.
Qualification: M.A
Yours Obediently,
Tahreem Javed,
Nazir, Sessions Court,
Khushab.
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that some posts of stenographer are lying vacant under
presently working as copy clerk to the office of the District & Sessions Judge,
Religious: Islam.
Qualification: B.Com
Yours Obediently,
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that some posts of stenographer are lying vacant under
requested that I may kindly be given a chance to serve under your kind
control.
Religious: Islam.
Qualification: M.A
Yours Obediently,
Tahreem Javed,
Nazir, Sessions Court,
Khushab.
Respected Sir,
Respected Sir,
dated 01.09.2012.
Respected Sir,
dated 20.11.2012.
Respected Sir,
dated 20.11.2012.
Tahreem Javed,
Nazir Sessions Court,
Khushab.
AFFIDAVIT
Khushab.
Deponent
AFFIDAVIT
Courts Khushab.
Deponent
To
Respected Sir,
hours.
Respected Sir,
get admission in Virtual University for MCS after courts hours. I may
Junaid Alam,
Computer Operator,
Sessions Court Khushab.
To
Respected Sir,
and privilege to submit that I have passed B.Com from University of the
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that I am an M.A (Pol. Sc.) and want to do MCS in evening
Jauharabad Campus)
hours.
me after 4:30-PM.
Karim Nawaz,
Computer Operator,
Civil Courts Khushab.
Senior Civil
Judge
Khushab.
To
Respected Sir,
and privilege to submit that I have passed B.A from AIOU Islamabad in
2007.
Nazir Ahmad,
Stenographer Civil Courts,
KHUSHAB.
Personal Information:
Education:
Experience:
o Interest in cricket
Signature
Muhammad Zubair
S/o Muhammad Sadiq r/o Waqar Alsam Colony, Jauharabad.
Mob: 0301-6344019
Personal Information:
Education:
Experience:
Personal Information:
Education:
FIR No. 251 dated 11.05.2012 u/s 379 PPC at P.S. City Jauharabad.
against the accused that he was present into house, he came outside on the knock
of the door and saw three persons were standing outside the house. He opened the
door and all the three persons entered into house. They also demanded the keys of
the box. Afterwards, they opened the box and steel all the articles which were lying
in the box which were having his wife. As soon as he huge and cried and the people
of the neighnours contained gather there. Thereafter, he left for police station for
registration of F.I.R.
_______________________________________________________________________
The defendant resisted the plaintiff in this suit
parties, jurisdiction, time limitation, quo, non joinder of the necessary parties.
framed.
1. Whether the plaintiff is entitled for the decree as prayed for? OPP
4. Whether the plaintiff has no cause of action and locus standi to file
this suit? OPD
6. Relief.
produced Ex.P1 to Ex.P16, in oral evidence the plaintiff recorded the statements of
Pw1 to Pw4. On the other hand defendant produced oral as well as documentary
both the parties. It does crystal clear that the plaintiff is his __________________. In
support of his version the defendant produced the case law of the subject that is
The above mentioned accused face the trial in case FIR No. 3 dated
Mumtaz of P.S. Khushab are that he alongwith his son was coming from fields to
house after cutting fodder, when they reached in street near their house. Muhammad
Hussain armed with hitch, Ali armed with hockey, Noor Muhammad empty handed
was came there. They raised huge and cried and asked him to teach the lesion of
launching the FIR. The first offender gave hitch blow on his back and the second
blow was given to him by Ali Muhammad on his head. On the receiving the second
blow he fell down on the ground. He was taken to the taken to the hospital by his
son. He was admitted in hospital for 15 days. The initially cases was registered u/s
324/24 PPC later on after the death it was converted into Section 302 PPC. Police
challan against the two accused and well mentioning the name of Noor Muhammad
in Column No.2.
court.
_______________.
The question way the disposal was long and otherwise the question of facts are for
the evidence. Prima facie the termination of receive for the period of 15 years in
service --------- principal clause (17) of termination in ------ vide order dated
09.10.2004. The production has not produced to decide. The fact of decided between
-------- (2004) (PLC 69) of non produced of facts and circumstances as well as time,
facts ------ judge the prayed servant for 3 years and during dated 19.12.91 prayed
yet. After as question of the employer--- of the part of employee taking of the plan of
Monitoring Team to visit the site and submit report on daily basis
the DRO and submitted their apology before the DRO that they
petitioner ban ------ office 1996. The ----- in the said officer was
---on 1.4.96. the pay of the petitioner was published by the worth
leaned trial court while recording the evidence and scanning the
35 years this remand did not justify. Therefore, the learned trial
committed u/s 302 PPC and as sentence to suffer death with the
The office is directed to prepared reference u/s 374 Cr.P.C for the
bail, bail bonds are cancel and they are release fourth with. The
Order:
23.04.2013
evidence so far led against the accused does not connect him with
happily for about one year but thereafter conflict between them
was arose and the defendant ousted the plaintiff from his house
pregnant. Since then the plaintiff is living with her parents and
issued in daily newspaper but besides this fact he did not attend
her version the plaintiff herself appeared before the court as Pw1
and got examined her father namely Muhammad Din as Pw2. She
dowry articles are concerned the list attached with the plaint is
flimsy in nature and the plaintiff is entitled to recover the articles
caused firing arm weapon. The prejudicial of his from the heart to
the same moment but --------. The Doctor has conducted the post
mortem of the dead body of the deceased and handed over the
them before I.O in police station who took the mere possession of
the articles and recorded the statements. The I.O deposited the
articles with the Moharrir for keeping the same in Malkhana for
save custody and I.O left for sight inspection, he inspected the
police station, deposited the recorded articles with the Moharrir for
as these are necessary for the just decision of the case if these
application.
seen with the assistance with the learned counsel for the parties.
did not in any connect the fact of the case for permanent
appellant u/s 337/F-4 and convicted him for R.I for 2 yeas with a
used the excess telephone ------- to him and the bill of the period is
Officer in the relevant head. Since the Audit Para relates to 2001
to 2005 and plan back old, the D.A.C committee was directed for
Khushab for four years and the house was remained in his
the leaned counsel for the appellant in the order impugned neither
he showed ----- base of the learned counsel for the appellant. The
of these pws
The petitioner has filed this application for grant
reputation.
02.05.2013.
each and every date fixed for this petition and shall also join the
pre arrest bail registered against them in case FIR No. 2 dated
the petitioners that the petitioners have been booked in this case
was affected from them. He also argued that during the physical
To
The X.E.N Provincial Buildings,
Sargodha.
MEMO:
With reference to letter No. 10659/A.R/F dated 27.03.2013 of
the Honble Lahore High Court, Lahore, bearing Endst No. 527/C.8 dated
responsible officer to attend the meeting at the given date and time alongwith
relevant record.
Respected Sir,
and Jang.
stenographer.
Respected Sir,
and Jang.
Tahreem Javed,
Nazir to the Court of D&SJ,
Khushab.
Today the case is fixed for the production of evidence of
the plaintiff but again the plaintiff has not produce the same and
to the plaintiff he has not produce the same. Today it was fixed
for the prosecution evidence with last opportunity but today again
adjournment without any cogent reason. Since the suit has been
filed six year ago and no cogent reason has been advance for the
plaintiff u/s 17 (3) CPC the suit is dismissed for want of evidence.
compilation.
Basing the evidence comes on record, by learned
PP for the state, learned counsel for the defence argued that there
obligation with the contention that both parties were enter into
was agreed between them that plaintiff will pay Rs. 2000000/- to
cause of death was due to shock and hem bridge resultantly, due
accused petitioner in the case registered against them vide FIR No.
words.
from his ---------- and shouted them. After hearing his shout they
--------- him and ask him to give the keys of the room due to fear he
gave them keys. Thereafter they both took him to the room and got
opened the boxes and took the cash amount of Rs. 50000/- and
some valuable articles. They both took the same and tie the
complainant with rope and moved from the place. FIR Ex.PA was
Wajay Taker, who while appearing before the I.O stated that he
has seen the accused while coming in the street during the night
which they pleaded not guilty and prayed for the commencement
of trail.
After framing the charge the case for fixed for the
and again but none of them appeared before the court thereafter
all the coercive measures were adopted and ultimately the non
received un-served with the report that all the accused moved
the case did not appeared before the court at any date. There is no
progress of the case. The accused has been facing agony of trial
since long. They are no more required by the police. They are
of Pakistan.
The cause of initiation of this departmental inquiry is
Mr. Kazim Hussain, Reader of the said court. The stay was sought
date fixed. He apply for the copy of said order in the copy branch
Khushab on 14.05.2013 but the copy branch did not delivered the
probe into the matter, then the application for inquiry has been
the FIR are that the injured/complainant and alleged eye witness
were going from their fields to the house and when they reached
he raised huge and cry and asked the injured that he has not
spare him alive and stimulusly fired with his 30 bore pistol which
hitting the injured on his left thee. He fell down. He was taken to
the hospital and got admitted him to the hospital and he rushed to
the police station to get FIR lodge where S.I registered the FIR on
statement recorded u/s 342 Cr.P.C did not put the vital question to
and thus seat of injuries of the injured. Pw1 injured deposed that
that the accused had come to the place of occurrence from the
terminology
To
The Honble District & Sessions Judge,
Khushab.
Respected Sir,
With due veneration and profound regard I have the honour and
presently working as copy clerk to the office of the District & Sessions Judge,
Religious: Islam.
Qualification: B.Com
Yours Obediently,
To
The Honble District & Sessions Judge,
Khushab.
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that I have come to know from a reliable resource that
some posts of Assistants (BS-15) & Junior Clerks (BS-11) are lying vacant in
(advertisement attached).
the above mentioned posts. It is further humbly submitted that I have joined
duty stenographer to the court Mr. Sajid Mehmood Gondal, learned Civil
District & Sessions Judge, Khushab. It is humbly requested that I may kindly
Yours Obediently,
Honble Sir,
preparation of papers.
from your honour learned predecessor Mr. Muhammad Tanvir Mir, the
Yours Obediently,
Respected Sir,
humbly requested that I may very kindly be allowed short leave from
kindness.
Yours Obediently,
Islah-ur-Rehman,
Budget & Accounts Examiner,
Sessions Court, Khushab.
NO OBJECTION CERTIFICATE:
a) Name: Islah-ur-Rahman.
b) Fathers Name: Muhammad Hussain
c) Post held presently: Budget & Accounts Examiner (BS-11).
d) Office/Department: Judiciary Khushab.
e) Post applied for: Accounts Officer (SPS-8).
Certified that the above candidate has been permitted to apply for the said post
and that:-
d) There is noting on record of this Department, which may render him ineligible
for the post and that his/her record of service is satisfactory and no
(Signature)
Appointing Authority
Stamp of the
Dated: __________ Appointing Authority or authorized
Officer on his behalf.
To
Respected Sir,
very kindly be granted two days causal leave for not feeling well due to
may very kindly be allowed short leave from 01:30 p.m. to 03:30. p.m.
kindness.
Yours Obediently,
Islah-ur-Rehman,
Budget & Accounts Examiner,
Sessions Court, Khushab.
CERTIFICATE
five children). One child is above the age of 12 years and the remaining
four are less than 12 years but greater than one year.
Azhar Hussain Shah Ex. Superintendent Sessions Court, Attock Now residing at House No.
103/A New Satellite Town Jauharabad.
VS.
The Honble Appellate Authority through its representative, the worthy Registrar, Lahore
High Court, Lahore.
Appeal U/S 4 of Punjab Service Tribunal Act, 1974 against the order dated
01.07.2005 conveyed through notification No. ----------- dated ------------ by means of which
the Honble Respondent, the appellant was dismissed from service by imposition of major
penalty enumerated in the Section 4B of Punjab Civil Service E & D Rules, 1999 for charge
of inefficiency, misconduct and corruption within the meaning of Rule 3 A B C without any
PRAYER IN APPEAL:
To accept this appeal and set aside the impugned order dated 01.07.2005 and
FACTS
That the appellant was served upon the charge sheet dated 29.01.2002 by Mr.
Pervaiz Mehmood Mian, the then learned District & Sessions Judge Rawalpindi/Inquiry
Officer for the allegation that the appellant while posted as Senior Clerk/Reader in Civil
Courts Noorpur Thal, a civil suit titled as Chargh Ali etc vs. Mher Ali instituted on
22.05.1996 and wrote kafeyat as well as prepared decree sheet showing the suit decided in
favour of plaintiff and against the defendant on 06.06.1996 in view of the statement of the
defendant with his counsel and accordingly order was passed by Mian Muhammad Younas
the then learned Civil Judge/accused officer and the appellant stated to leave been
transferred from Sub Division Noorpur Thal to District Headquarter Khushab through joint
charge sheet dated 29.01.2002 mentioned above for the charges of inefficiency, misconduct
and corruption within mentioning of rule 3 A B C of E & D Rules 1999 against the
appellant, the co-accused Mian Muhammad Younas, the then learned Civil Judge and
Muhammad Saleem the then Ahlmad. That the appellant submitted the reply of the charge
sheet within stipulated period by which all the charges mentioned above against the
appellant were vehemently denied and the appellant claimed himself to be innocent. After
the said charge sheet the reply of the appellant was produced before the learned Inquiry
Officer. The learned Inquiry Officer recorded the statements of Ijaz Hussain Shah Senior
Clerk as Pw1, Gulzar Khan Reader as Pw2, Tariq Javed Shah, Superintendent as Pw3,
Naseem Ahmad, Ahlmad as Pw4, Zafar Ullah, Reader as Pw5, Zain-ul-Abadin as Pw6,
Muhammad Mumtaz complainant as Pw7 while the evidence of prosecution was closed by
the prosecutor on 22.05.2002 whereas learned Inquiry Officer examines Mazhar Abbas
Record Keeper as Dw1, Habib Khan Ahlmad as Dw2, Muhammad Saleem Ahlmad as
Dw3/co-accused, Muhammad Hussain Shah COC as Dw4, Jahan Khan, Ahlmad as Dw5,
Muhammad Yousaf, Stenographer as Dw6, Sajjad Hussain Shah, Clerk Advocate as Dw7,
Azhar Hussain Shah, appellant as Dw8, Muhammad Ashraf, stenographer as Dw9 and the
appellant closed the evidence on 14.06.2002 before the learned Inquiry Officer.
That learned Inquiry Officer was transferred and the inquiry was entrusted to
Mr. Abdul Slam Khawar the than learned Member Inspection Team, Lahore High Court,
Lahore who recorded the statements of Mushtaq Hussain Burana Advocate as Dw10/A, Mr.
Namat Ullah Ghai Advocate as Dw11/A Mr. Waryam Khan copyist A/C Office Noorpur
Thal. On the transfer of Mr. Abdul Islam Khawar, learned Member Inspection Team, Lahore
High Court, Lahore, Mr. Muhammad Khalil Chaudhary the learned District & Sessions
Judge posted as Member Inspection Team, Lahore High Court, Lahore who served upon the
appellant with show cause notice stating therein as to why major penalty of dismissal from
service may not be imposed upon you for the charges leveled against the appellant further
more the appellant submitted reply of show cause notice by which the allegations were
denied by the appellant and claimed to be innocent and requested to exonerate the appellant
from the charges and requested the appellant to reinstate in service with all back benefits. On
dissatisfying with reply of show cause notice Mr. Muhammad Khalil Chaudhary the then
dismissal from service the of appellant submitted the entire record/proceedings alongwith
his report dated 13.01.2005 to the Honble Lahore High Court, Lahore/Authority as required
Justice/Authority was pleased to serve the final show cause notice on 09.06.2005 as to why
major penalty should not be imposed upon the appellant with the direction to appear before
Rao Sultan Ali Thair the then learned District & Sessions Judge, Khushab on 20.06.2005 for
personal hearing as well as to submit reply of notice before the said learned District &
Sessions Judge Khushab the appellant submitted the reply of show cause notice on
14.06.2005. Rao Sultan Ali Tahir the then learned District & Sessions Judge,
Khushab/Personal Hearing Officer after personal hearing, submitted the report to the
Honble Lahore High Court, Lahore but the appellant is still unaware.
That on receipt of personal hearing report, the appellant was dismissed from
service vide order of the Honble Chief Justice and Judges communicated through
service appeal under rule 15/16 of Punjab Civil Servant E & D Rules 1999 on 26.07.2005
before the Honble Lahore High Court, Lahore/Authority. That the service appeal of the
appellant was fixed for hearing on ------- but unfortunately no proceedings were conducted
by the Honble Lahore High Court, Lahore on each and every date mentioned above. The
service appeal of the appellant was not heard till to date. After 10.06.2011 no fresh date for
hearing of service appeal of the appellant was either fixed nor any notice for appearance has
been received to the appellant till to-date meaning thereby that a period more than eight
years and --------months has elapsed. The appellant is facing financial hardships as well as
mental agony. Service appeal is being filed before this Honble Service Tribunal in the
GROUNDS:
learned District & Sessions Judge Khushab/Preliminary Inquiry Officer submitted in writing
that file titled Chiragh Ali etc vs. Mehr Ali was misplaced by him, which was traced after a
laps of about three years. Therefore, he (Muhammad Saleem Ahlmad) could not consign the
admitted that the file in question remained misplaced for a long period, due to which, he
could not got consigned the file tilted Chiragh Ali etc vs. Mehr Ali into the record room.
from any illegal act done by Muhammad Saleem Ahlmad and Mian Muhammad Younas
Civil Judge/co-accused.
That the appellant had not been involved by Ahlmad & Civil Judge for
question and also not leveled any allegations for corruption against the appellant. So the
charges against the appellant have not been proved by the prosecution.
That the appellant could not be held responsible for any illegal act done by
Muhammad Saleem Ahlmad & Mian Muhammad Younas Civil Judge/co-accused in view of
settled principle of law that a man tell a lie but document not. Reliance is placed on
inquiry against Mian Muhammad Younas Civil Judge/co-accused, the appellant was placed
in the list of Pws but learned Inquiry Officer while issuing joint charge sheet, the appellant
was considered as accused which was beyond the competency of learned Inquiry Officer. So
the name of the appellant as accused is against the E & D Rules 1999.
That the statements of Pws on oath clearly exonerate the appellant from the
charges, and as such the appellant is entitled to re-instate in service with all back benefit.
report alongwith 2nd show cause notice which was mandatory and essential, so that the
impugned order dated 01.07.2005 being not sustainable in eyes of law is liable to be set
aside. Reliance is placed on PLD 1981 SC 176 & 1986 SCMR 1436.
stipulated period of 90 days by learned Inquiry Officer as per rule 9 of E & D Rule, 1999 but
learned Inquiry Officer had completed the inquiry proceedings within a period of more than
about 3 years, meaning thereby that learned Inquiry Officer violated the process of rule ibid.
Moreover, the appellant faced mental agony more than 3 years and as such the inquiry
proceedings are liable to be vititiated and the appellant is entitled to re-instate in service.
and surmises as well as sweer violation of E & D rules, 1999. So the appellant is entitled to
exonerate from charges and re-instatement in service with all back benefits.
offence of misplacement of judicial record and consigned the same after a period of about 3
years without any illegal justification, but the learned Inquiry Officer has recommended
minor penalty against the said Muhammad Saleem Ahlmad/co-accused while recommended
major penalty against the appellant which is very harsh and excessive which is liable to be
set aside. However minor penalty upon the appellant could meet the ends of justice for the
charge of only inefficiency. Reliance is placed on 2005 SCMR 1617 and PLJ 2006 SC 400.
That the appellant during his whole service about 23 years had not faced any
complaint/inquiry except the present one. Moreover, during such a long period, the appellant
was not communicated any adverse remarks meaning thereby that the appellant has blotless
a good service record could not be imposed with extreme major penalty of dismissal from
service. Minor penalty could meet the ends of justice for a single fault in whole service.
Reliance is placed on 2006 PLC (CS) 766 (FST), NLR 1987 TD, 167 & PLJ 2006 TRC 265.
That the service appeal as required in rule 15/16 against the impugned order
dated 01.07.2005 was preferred before the Honble Lahore High Court/appellant Authority
on 26.07.2005 that is well within time of 30 days, but the same had neither heard nor
disposed off till todate. A period of more that 8 years has elapsed. Moreover, after June,
2011 no fresh date has been fixed for hearing to todate. So this appeal u/s 4 of the Service
Tribunal Act, 1974 is being filed before this Honble Tribunal with the application for
condonation of delay.
In view of the above submissions, it is humbly prayed that this appeal may
kindly be accepted by condoning delay of more than 8 years beyond the control of the
appellant, the impugned order dated 01.07.2005 be set aside and appellant may very
graciously be reinstated in service with all back benefit. Any other relief which this Honble
Yours Obediently,
le the appellant started career in October, 1982 against the post of Senior Clerk direct
No.1 Khushab. The appellant was promoted as Assistant on the bases of seniority-cum-
fitness in the year 2000 whereas the appellant was promoted as Superintendent in the year
2001 by order of Honble Lahore Court Lahore/Competent Authority on the basis of good
service record.
When the appellant remained posted at Noorpur Thal with Mian Muhammad
civil suit titled as Hakim Khan etc. vs. Hakim Mehr Ali was presented before Mian
Muhammad Younas the then Civil Judge Noorpur Thal. The same was filed by Raja Ashraf
Hayat, Advocate. The appellant produced the civil suit titled above before the learned Civil
Judge who orders to write kafiyat. On the order of the court the appellant wrote kafiyat and
-4-
the learned Civil Judge/co-accused and the same was adjourned for 06.06.1996 for the
That on 06.06.1996 defendant Mehr Ali appeared before the learned Civil
Judge alongwith his counsel Mr. Muhammad Mushtaq Hussain Burana. On the said date
defendant not recorded the consenting statement besides filling consenting written
statement. When the defendant was identified -------- statement was also verified by his
counsel and accordingly the statement of the defendant and signature of learned counsel was
obtained on the left side of the consenting written statement. The consenting statement of the
defendant was recorded by the Mian Muhammad Younas learned Civil Judge/co-accused on
06.06.1996.
recording the statement decided the case final on the consenting statement of the defendant
vide order dated 06.06.1996. The appellant prepared decree sheet and place the same before
the learned Civil Judge/co-accused who signed the same and ----------- including
06.06.1996.
copying branch to A/C Office Noorpur Thal for preparing certified copies of order and
decree sheet dated 06.06.1996 against the Sawal Form No. 785 dated 18.07.1996 while Mr.
Muhammad Saleem, Ahlmad/co-accused got consigned the filed of above mentioned suit to
the record room of the District Coordination Office Khushab for a lapse of period of three
years.
That the said Muhammad Saleem, Ahlmad/co-accused while appearing
before the learned District & Sessions Judge Khushab/preliminary Inquiry Officer submit in
writing that the filed titled as Chargah Ali etc vs. Hakim Khan was misplaced which was
------ the file in question could not be consigned. As written regarding the misplacement of
------------. As the appellant being innocent in the said proceedings be exaggerated from the
charge and reinstate in service that none of the PWs involved. The appellant nor level not
allegation of misconduct, irregular gratification from in party. So from the PWs on that
innocence of the appellant proof-----. Reference can be placed upon of PLD 1981 SC 176,
inquiry accused Mian Muhammad Younas learned Civil Judge/co-accused the appellant was
-5-
place in the list of Pws and the learned Inquiry Officer consider the appellant as accused
person which was beyond the ----- of learned Inquiry Officer instead it was the complexity
of Honble Lahore High Court Lahore/Authority so the name of the appellant is as accused
by the learned Inquiry Officer is against the E & D Rules 1999. The appellant neither
proceed against nor ---- of the said irregular act. The appellant be exhaust from the charge
and reinstate in service with all back benefit. That Inquiry Officer proceedings were required
to be completed within the period of 90 days by the learned Inquiry Officer as per rule but
Inquiry Office concluded the proceedings of inquiry more than three years meaning thereby
the learned Inquiry Officer violated the provision of rules ibid. The appellant facing mental
agony since long period and ----- to be vitiated and the appellant may exhaust from the
charge.
That the report of Inquiry Officer is misreading, non reading, conjecture and
surmises as well clear violation of E & D Rules 1999. The appellant exhaust from charge
and reinstate into service with all back benefit. That Muhammad Saleem Ahlmad/co-accused
----- i.e of Judicial file consigned after a lapse of period of three year that ------ against
Muhammad Saleem Ahlmad/co-accused while the appellant was dismissed from service
which is very harsh and not sustainable in the law. Further imposition of minor penalty upon
the appellant could meet the justice from the charge of inefficiency. Reliance is placed on
complaint/application except present one and the appellant has not communicated any
adverse remarks meaning thereby that the appellant is blotless service record and as the
appellant having good service record ---- imposed ---- major penalty of dismissal from
service and instead minor penalty -------. Reliance is placed on 2006 PLC (CS) 766 (FST),
SCMR 465.
That service ---- Rule 15/16 of Punjab Civil Servant E & D 1999 against the
major penalty imposed order which was preferred before the Honble Lahore High Court,
Lahore/Appellant Authority on 26.007.2005 which is well within the time of 30 days but the
Respected Sir,
07.06.2015.
Junaid Alam,
Computer Operator,
Sessions Court, Khushab.
To
The Honble District & Sessions Judge,
Khushab.
Respected Sir,
With due veneration and profound regard I have the honour and privilege to submit
that some posts of stenographer are lying vacant in Sessions Courts, Sargodha and advertise in daily
newspaper.
as Junior Clerk/Ahlmad (BS-07) to the Sessions Court Khushab. It is humbly requested that I may
Religious: Islam.
Qualification: B.Com
Yours Obediently,
To
The Honble District & Sessions Judge,
Khushab.
Respected Sir,
With due veneration and profound regard I have the honour and privilege to submit
that some posts of steno-typist and clerks are lying vacant in Ministry of Foreign Affairs, Islamabad
as Junior Clerk/Ahlmad (BS-07) to the Sessions Court Khushab. It is humbly requested that I may
Yours Obediently,
CNIC: 38201-7381574-1
QUALIFICATION:
EXPERIENCE:
Signature
To
Mr. Wajid Hassan Hashmi, Director (Personal-II),
Constitution Avenue, G-5,
Islamabad.
Respected Sir,
With due veneration and profound regard I have the honour and privilege to submit
that some posts of steno-typist and clerks are lying vacant in Ministry of Foreign Affairs, Islamabad
as Junior Clerk/Ahlmad (BS-07) to the Sessions Court Khushab. It is humbly requested that I may
kindly be given a chance to serve under your kind control. (My C.V. & Departmental Permission is
attached herewith).
EXPERIENCE:
Working as Stenographer in Civil Courts, Khushab.
Working as Junior clerk in Sessions Courts, Khushab.
Yours Obediently,
To
The Honble District & Sessions Judge,
Khushab.
Subject: APPLICATION FOR APPOINTMENT AS JUNIOR CLERK (BS-07) UNDER
RULE 17-A A&CS RULES, 1974.
Respected Sir,
With due veneration and profound regard I have the honour and privilege to submit
that my father worked as Stenographer in this department more than 25 years but unfortunately, he
High Court, Lahore the Honble Chief Justice and Judges have been pleased to direct that the
following guiding principles (based upon the instructions of Government of the Punjab, S&GADs
Regulation Wing), be adhered to while making appointments in the sub-Ordinate Courts Staff under
3. It is therefore humbly prayed that I may very graciously be given a chance to work
under your kind control as Junior Clerk (necessary documents are attached herewith.
I will be prayed for your honour during my whole life.
Yours Obediently,
Sami Ullah,
S/O Muhammad Yousaf (late),
House No. 30 Street No.02,
Zaman Colony, Jauharabad.
To
Respected Sir,
hours.
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that some posts of Accounts Officer lying vacant under
Yours Obediently,
Islah-ur-Rahman,
Budget & Accounts Examiner,
Khushab.
Respected Sir,
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that a post of Budget & Accounts Examiner is lying vacant
the N.T.S test/interview for the post of Budget & Accounts Examiner.
To
The Honble District & Sessions Judge,
Khushab
Respected Sir,
With due veneration and profound regard I have the honour and
privilege to submit that a post of stenographer is lying vacant under the control of
To
The Assistant Director (HR-II),
Federal Public Service Commission,
Agha Khan Road F-5/1,
Islamabad.
Respected Sir,
and privilege to submit that some posts of Stenotypist BS-14 are lying
vacant under your kind control and advertised in Daily Jang Lahore.
I fulfill all the requirements mentioned in the advertisement
Yours Obediently,
To
The Section Officer (Admin),
Ministry of Parliamentary Affairs,
R-Block Pak Secretariat,
Islamabad.
Respected Sir,
Yours Obediently,
To,
The Worthy District & Sessions Judge,
Khushab
Dear Sir,
With due reverence, it is humbly submitted that I am working
under your kind control as a Computer Operator. I received a letter from P.O.
Yours Obediently,
Junaid Alam,
Computer Operator, Sessions Court,
KHUSHAB
To,
The Worthy District & Sessions Judge,
Khushab
Dear Sir,
With due reverence, it is humbly submitted that I am working
under your kind control as a Computer Operator. I received a letter from P.O.
BOX -1384, Islamabad dated 21.01.2015.The Public Sector Organization
humbly requested before your honour, please grant me NOC for the post of
Yours Obediently,
Junaid Alam,
Computer Operator, Sessions Court,
KHUSHAB
NO OBJECTION CERTIFICATE
It is certified that Mr. Junaid Alam S/o Arshad Naeem has been
Pakistani, Islamabad.
NO OBJECTION CERTIFICATE
No._______________/ Dated____________/2015
It is certified that Mr. Sarfraz Arshad Khan S/o Abdul Rauf
BS-07 since 2nd of August 2007. This office has no objection to relieve him, if
of Pakistan, Islamabad.
No.___________/ Dated___________/2015
BS-07 since 2nd of August 2007. This office has no objection to relieve him, if
Pakistan, Islamabad.
To
Senior Clerk in BS-09 vide order Endst. No. 833/A.10 (b) dated
Dear Sir,
Senior Clerk in BS-09 vide order Endst. No. 834/A.10 (b) dated
No.____________/ Dated:________/2015
Respected Sir,
No.____________/ Dated:________/2015
Respected Sir,
Operator BS-13 is lying vacant under the control of your honour and
No.____________/ Dated:________/2015
Respected Sir,
Operator BS-13 is lying vacant under the control of your honour and
To
No.____________/ Dated:________/2015
Respected Sir,
Inayat Ullah
Junior Clerk Sessions Court,
Khushab
To
The Commandant,
The Punjab Regiment Center,
Mardan Cantt.
present employer/department.
2. Keeping above in view, you are requested to please
To
Respected Sir,
District & Sessions Court, Rawalpindi are lying vacant under your
kind control.
Yours Obediently,
To
Dear Sir,
09.
rules.
Dear Sir,
(Lubna Munawar)
Lady Constable, Spl. Branch
Sargodha
To
Dear Sir,
ORDER
OFFICE OF THE
DISTRICT & SESSIONS JUDGE
KHUSHAB
ORDER
his previous post as per rules to enable him to join his new