1

GROUNDS;

a. That the impugned orders have been passed

illegally, unlawfully and arbitrarily against the

facts, rules and instructions on the subject,

hence the same are not sustainable in the

eyes of law being without any justification

and unwarranted.

b. That the allegation leveled against the

appellant was based on surmises and

conjectures and against facts being

concocted story. Factual position is that on

3.5.2019 the appellant was posted at PS

Sadar Wazirabad. Muhammad Yousaf s/o

Muhammad Hussain caste Jatt Rindhawa r/o

Gujranwala submitted an application which

was marked to the appellant. Bothe the

parties were called vide order No. 160 Cr.P.C.

Both the parties came to PS. In the

application Jamshaid etc on 5.5.2019, a

compromise was made between both the

parties. As agreement was made that on

6.5.2019 the land measuring 5 acre situated

at Bharokay Cheema will be returned.

However, another agreement was made that

learned measuring 01 acre ‘Shatala’ field will

be returned after a month. A stamp paper

 2

was given by Jamshaid etc to the

complainant Muhammad Yousaf. Both the

parties were produced before the SHO and

matter was solved. On 7.5.2019 the

complainant Muhammad Yousaf submitted

an application against the appellant.

c. That a case FIR No. 286/19 dated 7.5.2019

under section 302/109/34 PPC PS Tatlaywali

was registered against the appellant and

during this the appellant was transferred to

Police Station Ladhaywala Warriach.

Therefore, the appellant was posted at his

new place of posting. On 9.10.2019 Malik

Asad Awan submitted an application against

the appellant. But actually, the appellant had

no connection with the application. The

appellant had not received any amount as

illegal gratification from him. The allegations

leveled against the appellant are false and

frivolous.

d. That due to registration of the case against

the appellant, he could not join the inquiry

proceedings. However, the appellant

requested the authority that inquiry may

kindly be enquired through some other inquiry

officer. Moreover, the complainant submitted

a written statement that he did not want to

 3

take further action on his application. In

these circumstances, the

GROUNDS;

e. That the impugned orders have been passed

illegally, unlawfully and arbitrarily against the

facts, rules and instructions on the subject,

hence the same are not sustainable in the

eyes of law being without any justification

and unwarranted.

f. That the allegation leveled against the

appellant was based on surmises and

conjectures and against facts being

concocted story. Factual position is that on

3.5.2019 the appellant was posted at PS

Sadar Wazirabad. Muhammad Yousaf s/o

Muhammad Hussain caste Jatt Rindhawa r/o

Gujranwala submitted an application which

was marked to the appellant. Bothe the

parties were called vide order No. 160 Cr.P.C.

Both the parties came to PS. In the

application Jamshaid etc on 5.5.2019, a

compromise was made between both the

parties. As agreement was made that on

6.5.2019 the land measuring 5 acre situated

at Bharokay Cheema will be returned.

However, another agreement was made that

 4

learned measuring 01 acre ‘Shatala’ field will

be returned after a month. A stamp paper

was given by Jamshaid etc to the

complainant Muhammad Yousaf. Both the

parties were produced before the SHO and

matter was solved. On 7.5.2019 the

complainant Muhammad Yousaf submitted

an application against the appellant.

g. That a case FIR No. 286/19 dated 7.5.2019

under section 302/109/34 PPC PS Tatlaywali

was registered against the appellant and

during this the appellant was transferred to

Police Station Ladhaywala Warriach.

Therefore, the appellant was posted at his

new place of posting. On 9.10.2019 Malik

Asad Awan submitted an application against

the appellant. But actually, the appellant had

no connection with the application. The

appellant had not received any amount as

illegal gratification from him. The allegations

leveled against the appellant are false and

frivolous.

h. That due to registration of the case against

the appellant, he could not join the inquiry

proceedings. However, the appellant

requested the authority that inquiry may

kindly be enquired through some other inquiry

officer. Moreover, the complainant submitted

 5

a written statement that he did not want to

take further action on his application. In

these circumstances, the

GROUNDS;

i. That the impugned orders have been passed

illegally, unlawfully and arbitrarily against the

facts, rules and instructions on the subject,

hence the same are not sustainable in the

eyes of law being without any justification

and unwarranted.

j. That the allegation leveled against the

appellant was based on surmises and

conjectures and against facts being

concocted story. Factual position is that on

3.5.2019 the appellant was posted at PS

Sadar Wazirabad. Muhammad Yousaf s/o

Muhammad Hussain caste Jatt Rindhawa r/o

Gujranwala submitted an application which

was marked to the appellant. Bothe the

parties were called vide order No. 160 Cr.P.C.

Both the parties came to PS. In the

application Jamshaid etc on 5.5.2019, a

compromise was made between both the

parties. As agreement was made that on

6.5.2019 the land measuring 5 acre situated

at Bharokay Cheema will be returned.

 6

However, another agreement was made that

learned measuring 01 acre ‘Shatala’ field will

be returned after a month. A stamp paper

was given by Jamshaid etc to the

complainant Muhammad Yousaf. Both the

parties were produced before the SHO and

matter was solved. On 7.5.2019 the

complainant Muhammad Yousaf submitted

an application against the appellant.

k. That a case FIR No. 286/19 dated 7.5.2019

under section 302/109/34 PPC PS Tatlaywali

was registered against the appellant and

during this the appellant was transferred to

Police Station Ladhaywala Warriach.

Therefore, the appellant was posted at his

new place of posting. On 9.10.2019 Malik

Asad Awan submitted an application against

the appellant. But actually, the appellant had

no connection with the application. The

appellant had not received any amount as

illegal gratification from him. The allegations

leveled against the appellant are false and

frivolous.

l. That due to registration of the case against

the appellant, he could not join the inquiry

proceedings. However, the appellant

requested the authority that inquiry may

kindly be enquired through some other inquiry

 7

officer. Moreover, the complainant submitted

a written statement that he did not want to

take further action on his application. In

these circumstances, the

GROUNDS;

m. That the impugned orders have been passed

illegally, unlawfully and arbitrarily against the

facts, rules and instructions on the subject,

hence the same are not sustainable in the

eyes of law being without any justification

and unwarranted.

n. That the allegation leveled against the

appellant was based on surmises and

conjectures and against facts being

concocted story. Factual position is that on

3.5.2019 the appellant was posted at PS

Sadar Wazirabad. Muhammad Yousaf s/o

Muhammad Hussain caste Jatt Rindhawa r/o

Gujranwala submitted an application which

was marked to the appellant. Bothe the

parties were called vide order No. 160 Cr.P.C.

Both the parties came to PS. In the

application Jamshaid etc on 5.5.2019, a

compromise was made between both the

parties. As agreement was made that on

6.5.2019 the land measuring 5 acre situated

 8

at Bharokay Cheema will be returned.

However, another agreement was made that

learned measuring 01 acre ‘Shatala’ field will

be returned after a month. A stamp paper

was given by Jamshaid etc to the

complainant Muhammad Yousaf. Both the

parties were produced before the SHO and

matter was solved. On 7.5.2019 the

complainant Muhammad Yousaf submitted

an application against the appellant.

o. That a case FIR No. 286/19 dated 7.5.2019

under section 302/109/34 PPC PS Tatlaywali

was registered against the appellant and

during this the appellant was transferred to

Police Station Ladhaywala Warriach.

Therefore, the appellant was posted at his

new place of posting. On 9.10.2019 Malik

Asad Awan submitted an application against

the appellant. But actually, the appellant had

no connection with the application. The

appellant had not received any amount as

illegal gratification from him. The allegations

leveled against the appellant are false and

frivolous.

p. That due to registration of the case against

the appellant, he could not join the inquiry

proceedings. However, the appellant

requested the authority that inquiry may

 9

kindly be enquired through some other inquiry

officer. Moreover, the complainant submitted

a written statement that he did not want to

take further action on his application. In

these circumstances, the

q.

GROUNDS;

r. That the impugned orders have been passed

illegally, unlawfully and arbitrarily against the

facts, rules and instructions on the subject,

hence the same are not sustainable in the

eyes of law being without any justification

and unwarranted.

s. That the allegation leveled against the

appellant was based on surmises and

conjectures and against facts being

concocted story. Factual position is that on

3.5.2019 the appellant was posted at PS

Sadar Wazirabad. Muhammad Yousaf s/o

Muhammad Hussain caste Jatt Rindhawa r/o

Gujranwala submitted an application which

was marked to the appellant. Bothe the

parties were called vide order No. 160 Cr.P.C.

Both the parties came to PS. In the

application Jamshaid etc on 5.5.2019, a

compromise was made between both the

 10

parties. As agreement was made that on

6.5.2019 the land measuring 5 acre situated

at Bharokay Cheema will be returned.

However, another agreement was made that

learned measuring 01 acre ‘Shatala’ field will

be returned after a month. A stamp paper

was given by Jamshaid etc to the

complainant Muhammad Yousaf. Both the

parties were produced before the SHO and

matter was solved. On 7.5.2019 the

complainant Muhammad Yousaf submitted

an application against the appellant.

t. That a case FIR No. 286/19 dated 7.5.2019

under section 302/109/34 PPC PS Tatlaywali

was registered against the appellant and

during this the appellant was transferred to

Police Station Ladhaywala Warriach.

Therefore, the appellant was posted at his

new place of posting. On 9.10.2019 Malik

Asad Awan submitted an application against

the appellant. But actually, the appellant had

no connection with the application. The

appellant had not received any amount as

illegal gratification from him. The allegations

leveled against the appellant are false and

frivolous.

u. That due to registration of the case against

the appellant, he could not join the inquiry

 11

proceedings. However, the appellant

requested the authority that inquiry may

kindly be enquired through some other inquiry

officer. Moreover, the complainant submitted

a written statement that he did not want to

take further action on his application. In

these circumstances, the

GROUNDS;

v. That the impugned orders have been passed

illegally, unlawfully and arbitrarily against the

facts, rules and instructions on the subject,

hence the same are not sustainable in the

eyes of law being without any justification

and unwarranted.

w. That the allegation leveled against the

appellant was based on surmises and

conjectures and against facts being

concocted story. Factual position is that on

3.5.2019 the appellant was posted at PS

Sadar Wazirabad. Muhammad Yousaf s/o

Muhammad Hussain caste Jatt Rindhawa r/o

Gujranwala submitted an application which

was marked to the appellant. Bothe the

parties were called vide order No. 160 Cr.P.C.

Both the parties came to PS. In the

application Jamshaid etc on 5.5.2019, a

 12

compromise was made between both the

parties. As agreement was made that on

6.5.2019 the land measuring 5 acre situated

at Bharokay Cheema will be returned.

However, another agreement was made that

learned measuring 01 acre ‘Shatala’ field will

be returned after a month. A stamp paper

was given by Jamshaid etc to the

complainant Muhammad Yousaf. Both the

parties were produced before the SHO and

matter was solved. On 7.5.2019 the

complainant Muhammad Yousaf submitted

an application against the appellant.

x. That a case FIR No. 286/19 dated 7.5.2019

under section 302/109/34 PPC PS Tatlaywali

was registered against the appellant and

during this the appellant was transferred to

Police Station Ladhaywala Warriach.

Therefore, the appellant was posted at his

new place of posting. On 9.10.2019 Malik

Asad Awan submitted an application against

the appellant. But actually, the appellant had

no connection with the application. The

appellant had not received any amount as

illegal gratification from him. The allegations

leveled against the appellant are false and

frivolous.
 13

y. That due to registration of the case against

the appellant, he could not join the inquiry

proceedings. However, the appellant

requested the authority that inquiry may

kindly be enquired through some other inquiry

officer. Moreover, the complainant submitted

a written statement that he did not want to

take further action on his application. In

these circumstances, the

GROUNDS;

z. That the impugned orders have been passed

illegally, unlawfully and arbitrarily against the

facts, rules and instructions on the subject,

hence the same are not sustainable in the

eyes of law being without any justification

and unwarranted.

aa. That the allegation leveled against the

appellant was based on surmises and

conjectures and against facts being

concocted story. Factual position is that on

3.5.2019 the appellant was posted at PS

Sadar Wazirabad. Muhammad Yousaf s/o

Muhammad Hussain caste Jatt Rindhawa r/o

Gujranwala submitted an application which

was marked to the appellant. Bothe the

parties were called vide order No. 160 Cr.P.C.

 14

Both the parties came to PS. In the

application Jamshaid etc on 5.5.2019, a

compromise was made between both the

parties. As agreement was made that on

6.5.2019 the land measuring 5 acre situated

at Bharokay Cheema will be returned.

However, another agreement was made that

learned measuring 01 acre ‘Shatala’ field will

be returned after a month. A stamp paper

was given by Jamshaid etc to the

complainant Muhammad Yousaf. Both the

parties were produced before the SHO and

matter was solved. On 7.5.2019 the

complainant Muhammad Yousaf submitted

an application against the appellant.

bb. That a case FIR No. 286/19 dated 7.5.2019

under section 302/109/34 PPC PS Tatlaywali

was registered against the appellant and

during this the appellant was transferred to

Police Station Ladhaywala Warriach.

Therefore, the appellant was posted at his

new place of posting. On 9.10.2019 Malik

Asad Awan submitted an application against

the appellant. But actually, the appellant had

no connection with the application. The

appellant had not received any amount as

illegal gratification from him. The allegations

 15

leveled against the appellant are false and

frivolous.

cc. That due to registration of the case against

the appellant, he could not join the inquiry

proceedings. However, the appellant

requested the authority that inquiry may

kindly be enquired through some other inquiry

officer. Moreover, the complainant submitted

a written statement that he did not want to

take further action on his application. In

these circumstances, the

GROUNDS;

dd. That the impugned orders have been passed

illegally, unlawfully and arbitrarily against the

facts, rules and instructions on the subject,

hence the same are not sustainable in the

eyes of law being without any justification

and unwarranted.

ee. That the allegation leveled against the

appellant was based on surmises and

conjectures and against facts being

concocted story. Factual position is that on

3.5.2019 the appellant was posted at PS

Sadar Wazirabad. Muhammad Yousaf s/o

Muhammad Hussain caste Jatt Rindhawa r/o

Gujranwala submitted an application which

 16

was marked to the appellant. Bothe the

parties were called vide order No. 160 Cr.P.C.

Both the parties came to PS. In the

application Jamshaid etc on 5.5.2019, a

compromise was made between both the

parties. As agreement was made that on

6.5.2019 the land measuring 5 acre situated

at Bharokay Cheema will be returned.

However, another agreement was made that

learned measuring 01 acre ‘Shatala’ field will

be returned after a month. A stamp paper

was given by Jamshaid etc to the

complainant Muhammad Yousaf. Both the

parties were produced before the SHO and

matter was solved. On 7.5.2019 the

complainant Muhammad Yousaf submitted

an application against the appellant.

ff. That a case FIR No. 286/19 dated 7.5.2019

under section 302/109/34 PPC PS Tatlaywali

was registered against the appellant and

during this the appellant was transferred to

Police Station Ladhaywala Warriach.

Therefore, the appellant was posted at his

new place of posting. On 9.10.2019 Malik

Asad Awan submitted an application against

the appellant. But actually, the appellant had

no connection with the application. The

appellant had not received any amount as

 17

illegal gratification from him. The allegations

leveled against the appellant are false and

frivolous.

gg. That due to registration of the case against

the appellant, he could not join the inquiry

proceedings. However, the appellant

requested the authority that inquiry may

kindly be enquired through some other inquiry

officer. Moreover, the complainant submitted

a written statement that he did not want to

take further action on his application. In

these circumstances, the

hh.

ii. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

jj. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

 18

therefore, the impugned order is not

sustainable in the eye of law.

kk. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

ll. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

mm. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

nn. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.
 19

oo. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

pp. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

qq. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

rr. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

 20

ss. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

tt. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

uu. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

vv. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

 21

therefore, the impugned order is not

sustainable in the eye of law.

ww. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

xx. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

yy. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

zz. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.
 22

aaa. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

bbb. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

ccc. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

ddd. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

 23

eee. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

fff. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

ggg. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

hhh. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

 24

therefore, the impugned order is not

sustainable in the eye of law.

iii. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

jjj. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

kkk. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

lll. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.
 25

mmm. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

nnn. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

ooo. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

ppp. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

 26

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

qqq. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

rrr. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

sss. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

ttt. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

 27

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

uuu. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

vvv. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

www. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

xxx. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.
 28

yyy. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

zzz. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

aaaa. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

bbbb. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

 29

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

cccc. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

dddd. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

eeee. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

ffff. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

 30

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

gggg. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

hhhh. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

iiii. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

jjjj. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.
 31

kkkk. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

llll. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

mmmm. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

nnnn. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

 32

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

oooo. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

pppp. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

qqqq. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

rrrr. That no show cause notice was ever served

upon the appellant which is sheer and clear

 33

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

ssss. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

tttt. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

uuuu. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

vvvv. That the impugned order is exparte and

without giving any opportunity of hearing to

 34

the appellant. He has been condemned

unheard.

wwww. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

xxxx. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

yyyy. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

zzzz.That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

 35

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

aaaaa. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

bbbbb. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

ccccc. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

ddddd. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

 36

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

eeeee. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

fffff. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

ggggg. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

hhhhh. That the impugned order is exparte and

without giving any opportunity of hearing to

 37

the appellant. He has been condemned

unheard.

iiiii. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

jjjjj. That no show cause notice was ever served

upon the appellant which is sheer and clear

violation of principle of natural justice as

guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

kkkkk. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

lllll. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

 38

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

mmmmm. That no show cause notice was

ever served upon the appellant which is

sheer and clear violation of principle of

natural justice as guaranteed by the Article

10 of the Constitution 1973 of the country. It

is also violation of principle of Audi alterem

Partem, therefore, the impugned order is not

sustainable in the eye of law.

nnnnn. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

ooooo. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

ppppp. That no show cause notice was ever

served upon the appellant which is sheer and

 39

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

qqqqq. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

rrrrr.That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

sssss. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

ttttt.That the impugned order is exparte and

without giving any opportunity of hearing to

 40

the appellant. He has been condemned

unheard.

uuuuu. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

vvvvv. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

wwwww.That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

xxxxx. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

 41

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

yyyyy. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

zzzzz. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

aaaaaa. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

bbbbbb. That no show cause notice was ever

served upon the appellant which is sheer and

 42

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

cccccc. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

dddddd. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

eeeeee. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

ffffff. That the impugned order is exparte and

without giving any opportunity of hearing to

 43

the appellant. He has been condemned

unheard.

gggggg. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

hhhhhh. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

iiiiii. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

jjjjjj. That it reflects from the charges that various

factual controversies are involved which is

matter of inquiry and cannot be resolved

without holding a regular and full-fledged

 44

inquiry but the authority did not conduct any

regular inquiry without assigning any

reasons. Reliance is placed on 2007 SCMR

192 and 2006 SCMR 846.

kkkkkk. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

llllll. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

mmmmmm. That it reflects from the charges

that various factual controversies are

involved which is matter of inquiry and

cannot be resolved without holding a regular

and full-fledged inquiry but the authority did

not conduct any regular inquiry without

assigning any reasons. Reliance is placed on

2007 SCMR 192 and 2006 SCMR 846.

nnnnnn. That no show cause notice was ever

served upon the appellant which is sheer and

 45

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

oooooo. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

pppppp. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

qqqqqq. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

rrrrrr. That the impugned order is exparte and

without giving any opportunity of hearing to

 46

the appellant. He has been condemned

unheard.

ssssss. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

tttttt. That no show cause notice was ever

served upon the appellant which is sheer and

clear violation of principle of natural justice

as guaranteed by the Article 10 of the

Constitution 1973 of the country. It is also

violation of principle of Audi alterem Partem,

therefore, the impugned order is not

sustainable in the eye of law.

uuuuuu. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

vvvvvv. That it reflects from the charges that

various factual controversies are involved

which is matter of inquiry and cannot be

resolved without holding a regular and full-

 47

fledged inquiry but the authority did not

conduct any regular inquiry without assigning

any reasons. Reliance is placed on 2007

SCMR 192 and 2006 SCMR 846.

wwwwww. That no show cause notice was

ever served upon the appellant which is

sheer and clear violation of principle of

natural justice as guaranteed by the Article

10 of the Constitution 1973 of the country. It

is also violation of principle of Audi alterem

Partem, therefore, the impugned order is not

sustainable in the eye of law.

xxxxxx. That the impugned order is exparte and

without giving any opportunity of hearing to

the appellant. He has been condemned

unheard.

yyyyyy.

zzzzzz.