BEFORE THE AUTHORITY, OGRA, ISLAMABAD

In Appeal No. 116/2018 against the decision

dated 03-08-2018 in complaint no. 1801/2018

Sui Northern Gas Pipelines Limited V/s M. Naveed Khan, Islamabad

Para wise Reply/ comments on behalf of respondent

With utmost respect it is submitted that the instant appeal is liable

to be dismissed on the inter alia grounds that: -

1. Material facts have been concealed in the captioned appeal with intent to

mislead the authority while proceeding with the matter.

2. Decision of the designated officer to the extent of its Para B,C and D has

not been assailed by way of filing the instant appeal.

3. Provisions of the applicable billing manual have been interpreted in an

arbitrary, illogical and unjustified way just to deprive the respondent from

his valuable rights guaranteed under the law.

4. Despite the fact that decision of the designated officer dated 03-08-2018

remained in field, was never implemented by the appellant till filling of the

appeal and the respondent is still clogged with the outstanding excessive

billing.

5. The contents of the appeal are self-contradictory and misleading, which do

not reflect case of the appellant in definite terms.

On merits:

1. The para is misleading as neither any fact was ignored by the designated

officer while passing the decision nor passed two decisions simultaneously,

rather it is needful to mention that the decision passed on 09-05-2018 was

just an ex-parteand unheard decision, in which the respondent was not heard

and the same was set aside on the application of respondent vide its detailed

written order dated 16-05-2018 and only thereafter further proceedings

were again carried out in the complaint and after ample opportunity of

hearing to the parties, the decision dated 03-08-2018 was passed. Hence

there is no question of existing two decisions on the matter at the same

time.
 2. There is no denial on the part of the appellant that the meter reading on

monthly basis was not taken and made basis for the billing rather

accumulative billing for the several months was later levied. More so, the

provisional billing for couple of months itself shows the slackness and

negligence on the part of the appellant.Neither the appellant made a

provisional billing for the months on regular and actual meter reading basis

nor the reading of previous year in the same months was made basis for such

billing. Needless to mention that keeping mum for months by the appellant

and billing the respondent at much belated stage with maximum slab not only

contravened the regulations on the subject but also violated the precious

rights of the respondent.

3. The appellant neither disputed nor raised any defense whatsoever as to why

during pendency of the complaint in question, in the subsistence of injunctive

orders, the meter of the respondent was disconnected and incase it was not

accessible for the reading purposes so how was it removed during the

pendency of the complaint, which subsequently on the filing the application

by the respondent, was ordered to be restored.

In the given backdrop, the instant appeal is without any force

and is liable to be dismissed with heavy costs.

Muhammad Naveed Khan

29.10.2018 Respondent/Complainint