To, DATED: -01-2022 The Divisional Superintendent, Pakistan Railways Karachi, SUB: DETAILED REPLY TO YOUR NOTICE DATED 22-12-2021_AS WELL SSE EPLY TO YOUR NOTICE DATED 22-12-2021_AS WELL AS LEGAL NOTICE TO FULFILL REQUIRMENT/ ACCORDING TO THE LAW OF CONTEMPT OF COURT ORDINANCE 2003. SRRTEMPT OF COURT ORDINANCE 2003. This Letter/Notice has been drafted on behalf of Residents, Owners/Landlords of Project no 7 of Pakistan Railway Employees Cooperative Housing Society (P.R.E.C.H.S), on whom Notices have been served by you time to time in a disgraceful Manner. Before Stating upon Any Legality Firstly | will bring your Attentions towards the Brief History of Project no 7 of (P.R.E.C.H.S). The Pakistan Railway Employees Cooperative Housing Society (P.R.E.C.H.S) will be called the Subject Society herein, The Pakistan Railways in the year 1980 Sold 63.13 Acres of Land to the Subject Society for Project no 7 through a SRO No 473- W/o-11 dated February 4 1978 And SRO NO170(1)/83 on 17 February 1983 made Part and parcel of the Gazette of Pakistan as well as the Law in Section 813 (A) of (The Pakistan Railways Code For the Engineering Department wherein Pakistan Railway Was Fully Empowered by the Then President of Pakistan Zulfiqar Ali Bhutto , to Lease out its Surplus Land for the Beneficial of The Subject HousingSociety.(Copy of Gazette of Pakistan *Section 813(A) of PR Law ,Lease deed Executed by the Pakistan Railways fil led Annexure as A-1) That Soon after the lease execution Between the Subject Society and The Pakistan Railway on Behalf of The President of Pakistan, The Sindh Government came as a Rival and Through Deputy Commissioner Karachi east cancelled the leased Agreement of the Subject Society, Government We filled a Suit no 68/1981 was Decreed in our favor ,Sindh Govern Civil Appeal no 76/1987 Appeal was also Being Aggrieved by the decision of Sindh in the Hon’a’ble Sindh High Court which ‘ent Filled appeal in The Sindh High Court Dismissed, and later on Sindh Government filed an Appeal in Supreme Court of Pakistan no 257-K-1991 And all Decision were Upheld in our favor up till the level of Supreme court of Pakistan, During the pendency of the Cases Your Departments Divisional Superintendent Cancelled the lease of our Society once Again ,Being Aggrieved we filled Civil Suit no 540/1990 Against your Department in the Sindh High Court which is still pending . Latter on Individual Allottees of our society filled Constitutional Petition’s no D-359/92 TO D-361/92 And D-414/92 TO D-418/92( 360/1992) in the Sindh High Court which were decided fully upon merit and decreed in our favor, Being Dissatisfied Pakistan Railways filed Intra Court Appeal in the Sindh High Court which was Dismissed and again Appeal in Supreme Court of Pakistan in C.P No 210-K/96,277-K/96 And 321-K/96 which was also dismissed and a Crl Org Petition no 02/98 was filled Against Your Department Because of Continuing Harassment Against Bonafide Allotees of Project no 7, In that Petition Secretary Railway Board Promised to Execute a Registered Lease deed in favor of our Subject Society, Since 1980 Your department has only created hardship for us and nevertheless nothing more, all these Cases were pending and Prime Minister Investigationcommittee Directed Hon’a’ble Wafaqi Mohtasib to Conduct a Detail Inquiry in the subject Matter and after Detailed Inquiry the Matter was Decided in our favor. (Copy of Civil Suit no 68/1981, Copy of Civil Appeal no 76/1987Copy of Supreme Court of Pakistan Judgment in Case no 257-K/1991, Copy of Order of Civil Suit no 540/1990,Copy of Cp360/1992, copy of Cri Org Petition no 02/1998, Copy of Sindh High Court Appeal ,Copy of Supreme Court of Pakistan Judgment in C p no 210-K1996 And Copy of the Findings of Hon’a’ble Wafaqi Mohtasib filled as Annexure A-2). As in the year 2020 an application was filled by us in the Hon’able President of Pakistan Office to implement the orders of Wafaqi Mohtasib in that Application your department filled Comments in which it was stated that after the year 2000 Pakistan Railway has no Control or Relation with the subject Society and its Land. (Copy of your Comments filled as AnnexureA-3) As until the year late 1999-early 2000 KCR was fully operational on the track near our subject Society ,Latter on the KCR was Abandoned by Pakistan Railways and in the year 2020 The Chief Justice of Pakistan had issued a Restraining order Against Pakistan Railways in which it is clearly mentioned that no Encroachment operation will be carried out Against the subject Society until further order's of Supreme Court and the case is still Sub Judice in Const Petition no 09/2010 And CMA no 177-k/2020. (Copy of the order of Supreme Court of Pakistan filled as Annexure A-4) That the Secretary Pakistan Railway’s and the Commissioner Karachi have filled a Detailed Report in Hon’a’ble Supreme Court of Pakistan stating that the Land of KCR near Gillani station is totally/fully Vacant as per requirements of KCR Operational Purpose so the question of Encroachment does not arise.‘Supreme Court of Paki istan as well as the Principles of ; ; settled Principle that ples of Natural Justice and it is well when a matter is Sub Judice i i in the Highest Forum D , ; epartment et interfere upon their own will and Desire. As if No reasonable reply response is provided in 7 days of issuance of this Letter/Notice We will file/Initiate Contempt of Court Proceedings Against you and your Department in the Supreme Court of Pakistan by filling (Criminal Original Petition) in Const Petition no 09/2010. Copy Sent to; 1)President Of Pakistan 2)Ministry of Railway's 3)Supreme Court of Pakistan Human Right Cell 4)Prime Minister Complain Cell Thanking you Your Sincerely (PRESIDENT RAILWAY SOCIETY WELFARE COMMTEE PROJECT NO 7)