" BEFORE THE PESHAWAR HIGH COURT PESHAWAR Writ Petition No.2951-P/2017 Malecha Nasir Petitioner vis Director (E &SE) KPK and Others.... Respondents INDEX S.No. | Description of Documents ‘Annexure Page No. 1 Para wise Reply aoe 12 2. Copy of detail marks A 3 certificates of respondent No.5. 3. Copy of letters. B,BI 45 4. Affidavit. Heit 6 ® Di Tonio Officer, (Female), Peshawar 16 NOV 2017pe i‘ BEFORE THE PESHAWAR HIGH COURT PESHAWAR Writ Peti m_No.2951-P/2017 Maleeha Nasir 0.2.0 .0cccsccecceseeteeeeseeteeteneieeeeee Petitioner WS Director (E &SE) KPK and Others... .. Respondents PARA WISE COMMENTS FOR AND ON BEHALF OF RESPONDENTS No.1to3. Respectfully Sheweth:- The respondent submits as under:- PRELIMINARY OBJECTIONS. . That the Petitioner has got no cause of action / locus standi . That the Petitioner has not come to this Hon’ble court with clean hands. . That the instant Petition is based upon malicious/vexatious, frivolous grounds. . That the Petitioner is estopped by her own conduct to file the instant Petition. . That the instant Petition is bad for mis-joinder and non-joinder of the necessary parties. |. That the instant Petition is barred by law. 7. That the instant Petition is not maintainable in its present form. . That Petitioner does not fall within the ambit of aggrieved person. weene a 8 FACTS. . That Para No.1 pertains to record. . That Para No.1 pertains to record. . That Para No.2 is correct. » 18 NOV ANE, . That Para No.3 is also correct. . That Para No.4 pertains to record. . That in reply to Para No.5, it is submitted that Respondent No.5 was deferred by the DSC committee chaired by the District Education Officer (Female) Peshawar with remarks “Not eligible/out district as per CNIC no English in BS (Hons)”. However, on appeal to the competent authority (Director E &SE), the competent authority recommended respondent No.5 for appointment on the bases of having English subject (Structure & Writing skills) in BS (Hons). Moreover, letter vide No.9057 dated: 12-09-2017 was wrote to the Deputy Commissioner Peshawar for verification of Domicile certificate in r/o Nabeela Abbas (respondent No.5) wherein the Deputy Commissioner replied with remarks “ that the Domicile in r/o Mrs. Nabeela Abbas d/o Ghulam Abbas is returned with remarks that the same is not found in the record of this office as per report of domicile clerk”. aygery VswnNeete (Copy of detail marks certificates of respondent No.5 and letters are attached as, annex A,B & B1). . That Para No.6 is replied in Para No.5. . That Para No.7 is replied in Para‘No.5. ‘That Para No.8 is replied in Para No.5. 9. That Para No.9 pertains to.record. 10.That Para No. 10811 are replied in the above Para. 12.That Petitioner has no cause of action, hence she cannot knock at the door of this Hon’ble Court. oN GROUNDS. A. That Ground-A is incorrect, misleading and against the facts. The respondents have acted according to law, rules and policy. . That Ground-B has been replied in the above Para. . That Ground-C is replied in Para No.5. . That Ground-D is incorrect, misleading and against the facts. The respondents have acted according to law, rules and policy. That Ground-E is incorrect, misleading and against the facts. The respondents poe nm have acted according to law, rules and policy. F. That Ground-F is incorrect, misleading and against the facts. The respondents have acted according to law, rules and policy. G.. That Ground-E is replied in Para No.5. H. That Ground-H is incorrect, misleading and against the facts. The respondents have acted according to law, rules and policy. I. That Ground-I is incorrect, misleading and against the facts. The respondents have acted according to law, rules and policy. J. That Respondent also seeks permission of this Hon’ble Court to submit other Grounds and proofs at the time of hearing. It is therefore, most humbly prayed that on acceptance of this Para wise comments, the petition in hand may kindly be dismissed with cost. 74 ae Officer, E &SE KPK Peshawar (Female), Peshawar FILEQ TODAY Deputy Hagistrar 46 NOV 20174 i NWFP AGRICULTURAL UNIVERSITY PESHAWAR (PAKISTAN) Session: 2008-2011 OFFICIAL TRANSCRIPT OF RECORD Name. Nabeela Abbas D/O Ghulam Abbas C.No. 19 Univ. Reg. No. 2008-Agr-U-17066 B.Sc.(Hons) Biotechnology Part-! \~ Course No. Course Title First Semester IBGE-301 Principles of Genetics-I 'BGE-302 _Biotechnology-| 'BGE-303 Plant Tissue Culture IBGE-304 —_Biometrical Genetics 1BGE-305 _introduetory Mycology Eng-301 Second Semester 'BGE-311 Principles ef Genetics-II IBGE-312 Tissue & Cell Culture Bictechnology-ti Cell Biology oe Biological Chemistry-t IBGE-315, CS/1T-311 Computer Science / IT {SES-301 Islamic Studies GPA The examination was taken as 4 whole Hours Obtained — Grade 3 59 Ce 3 75 B+ 3 78 Be 3 84 A 3 83 A 3 “85 A “GPA 3.36 3 80 A 3 82 A 3 85 A 3 72 Be 3 83 A 3 80 A 2 400 At 3.65 CGPA 3.51 ‘ERRORS AND OMISSIONS ACCEPTED ~ Prepared by: te Checked by: OL Dated 26/02/2008 Be Grading Procedure: The equivalence of marks % age, letter grade & grade point is as under: Marks % age Letter grade 90-100, At 80-89 A 70-79 Bt 65-69 B 56-64 : Cr 50-55 ts c 40-49 : D Below.40. 7 E cad Controller of Examinations. i “eis Grade Point 4.00 3.67 3.33 3.00 2.50 2.00 1.00 0.00Office of the District Education Officer, (Female) Peshawar No. 2.057 Dated:_j 47 09/2017 To The Deputy Commissioner, Peshawar Subject VERIFICATION OF DOMICILE CERTIFICATE IN R/O NABEELA ABBAS Memo; Kindly refer to the above captioned subject and to state that one Mst: Nabeela Abbas D/o Ghulam Abbas has been recently appointed as SST-Gen at GGMS Safdar Abad Peshawar. Recently another applicant namely Mst Maleeha Nasir O/o Nasir Shohzed has filed a wnt petition against Nabecla Abbas in the Hon'ble Peshawar High Court Peshawar withthe plea that she has got a domicile certicate of District Peshawar which is fake/bogus. In this connection, itis requested that the authencity of domiaile of Mst: Nabeela Abbas Dio Ghulam Abbas (Avnexed as A), may kinaly be fumishad to this office so that the matter can be resolved as per rule and policy. Your early response in this matter willbe highly appreciated being a court matter. a “| DISTRICT EDUCATION OFFIC, (FEMALE) PESHAWS Encl: As aboveos € OFFICE OF THE, fle mmission? DEPUTY COMMISSIONER PESHAWAR i { / 2 Phone#: 091-9212305 _ MESS Fax #: 091-9212303 de ES yew vaG-wivunicie awed pesh tue: 2 IL n0r7 be ae i 4 : The District Education Officer (Female) cl ee : ve Reference your fetter No, 9057 dated 12.09.2017 on the captioned subject Abbas Domicile Certificate in respect cf Mrs. Nabeela Abbas D/O Ghulam is returned incrovsith the renvarks that the same was not found in the record of this office as per report of ¥ domicile clerk vide NO. 786/DB/DC dated 02.10.2017 fn Deputy Conn Peshawar joner DCPYAG-Y Copy far intimation to PS 10 Deputy Commissioner Peshawar ‘| / i Deputy Confmissioner PeshawarBEFORE THE PESHAWAR HIGH COURT PESHAWAR 951-P/2017 MST; Maleeha Nisar vs Director E&SE & Others Affidavit | Shafiq-Ur-Rehman Suptt’ O/O DEO(Female) Peshawar do hereby solemnly affirm and declare on oath that the contents of the Para Wise reply on behalf of respondents are correct to the best of my knowledge and noting has been concealed from this Honorable Court i 17102-1152585-3 Identify by « that the inmation hetore 1 9 Of. VOM. lea UO. LF6.... wo was ident: Who is personal Y Advocate General Khyber Pakhtunkhwa Peshawar. xy FILED(EQBAY _ Deputy Rifistrar : (16 Nov 2017