IN THE FEDERAL SERVICE TRIBUNAL,

ISLAMABAD

Appeal No._______/2022

Hamid farooq qureshi s/o Muhammad saleem Iqbal working as

senior transportation Pakistan railways r/o Pakistan railways
headquarters office Lahore.

Versus

Ministry of railway through its secretary, Block D of the Pak

Secretariat in Islamabad.

APPEAL U/S 4 OF SERVICE TRIBUNALS ACT, 1973

Respectfully Sheweth,

FACTS:

1. That the addresses of the parties are correctly mentioned in the

heading.

2. That the  Ministry of Railways  is a ministry of the Government

of Pakistan tasked with planning, administrating and overseeing

government policies for the development of the national rail

network, Pakistan Railways. Originally a department of

the Ministry of Communications, in May 1974 it formed into an

autonomous ministry of the federal government. The ministry

headquarters is located at Block D of the Pak

Secretariat in Islamabad.

3.
 PRAYER:

In the light of what has been stated above it is humbly prayed that following
declarations may kindly be passed in favour of the appellants:

a. A declaration to the effect that impugned notice dated ______is

against the law laid down by the Superior Courts.

b. A declaration to the effect that

Any other relief this court may deem appropriate be awarded in

the interest of justice.

Appellant

Through

RAJA SAIF UR REHMAN

ADVOCATE SUPREME COURT OF PAKISTAN
LLB - LLM (UNITED KINGDOM)

MAK& REHMAN LAW

Mob: 03132 838383
Email: highcourt100@gmail.com

Certificate:

Certified that as per instructions received from the client this is the first
appeal filed by the appellant challenging this impugned order and no other
petition is pending or decided by any court of law in this regard.
 IN THE FEDERAL SERVICE TRIBUNAL,
ISLAMABAD
Appeal No._______/2022

HAMID FAROOQ QURESHI

VERSUS

MINISTRY OF RAILWAY

APPEAL U/S 4 OF SERVICE TRIBUNALS ACT, 1973

AFFIDAVIT

I, Hamid farooq qureshi s/o Muhammad saleem Iqbal working

as senior transportation Pakistan railways r/o Pakistan railways
headquarters office Lahore, do hereby solemnly affirm and
declare as under:

That the contents of the accompanying appeal are true and

correct to the best of my knowledge and belief and nothing has
been concealed or withheld therein.

DEPONENT

It is verified on oath at Islamabad on this ___ day of November

2022 that the contents of the above affidavit are true and correct
to the best of my knowledge and belief and nothing has been
concealed.

DEPONENT
 IN THE FEDERAL SERVICE TRIBUNAL,
ISLAMABAD
Appeal No._______/2022

HAMID FAROOQ QURESHI

VERSUS

MINISTRY OF RAILWAY

APPEAL U/S 4 OF SERVICE TRIBUNALS ACT, 1973

APPLICATION FOR INTERIM RELIEF UNDER ORDER XXXIX

RULE 1&2 READ WITH SECTION 94 & SECTION 151 CPC.

Respectfully Sheweth,

1. That the applicant has filed the above titled appeal before
this Honorable Court today, contents of which may kindly be
read as an integral part of this application.

2. That the appellant has a good prima facie case and there
is every likelihood of her success in the petition.

3. That the balance of convenience and also lies in favour of

the appellant.

4. That if the relief prayed is not granted to the appellant

will suffer irreparable loss.

In the light of what has been stated above it is humbly prayed

that impugned order dated __________ be suspended and
respondent be directed not to take any adverse action till the
finalization of this appeal.

Appellant

Through

RAJA SAIF UR REHMAN

ADVOCATE SUPREME COURT OF PAKISTAN
LLB - LLM (UNITED KINGDOM)

MAK& REHMAN LAW

Mob: 03132 838383
Email: highcourt100@gmail.com
 IN THE FEDERAL SERVICE TRIBUNAL,
ISLAMABAD
Appeal No._______/2022

HAMID FAROOQ QURESHI

VERSUS

MINISTRY OF RAILWAY

APPEAL U/S 4 OF SERVICE TRIBUNALS ACT, 1973

AFFIDAVIT

I, Hamid farooq qureshi s/o Muhammad saleem Iqbal working

as senior transportation Pakistan railways r/o Pakistan railways
headquarters office Lahore, do hereby solemnly affirm and
declare as under:

That the contents of the accompanying appeal are true and

correct to the best of my knowledge and belief and nothing has
been concealed or withheld therein.

DEPONENT

It is verified on oath at Islamabad on this ___ day of November

2022 that the contents of the above affidavit are true and correct
to the best of my knowledge and belief and nothing has been
concealed.

DEPONENT
 IN THE FEDERAL SERVICE TRIBUNAL,
ISLAMABAD
Appeal No._______/2022

HAMID FAROOQ QURESHI

VERSUS

MINISTRY OF RAILWAY

APPEAL U/S 4 OF SERVICE TRIBUNALS ACT, 1973

APPLICATION FOR EXEMPTION OF FILING CERTIFIED

COPIES OF DOCUMENTS

Respectfully Sheweth,

1. That the applicant has filed the above titled appeal before
this Honorable Court today, contents of which may kindly be
read as an integral part of this application.

2. That certain documents either enclosed with the petition are

attached with the pleadings of the parties, certified copies of
which cannot be obtained at this stage i.e. before recording of
evidence or original are in possession of parties.

In these circumstances, it is, therefore, most humbly prayed

that applicant be exempted from filing of certified copies of
documents annexed with the petition in the interest of justice.

Appellant

Through

RAJA SAIF UR REHMAN

ADVOCATE SUPREME COURT OF PAKISTAN
LLB - LLM (UNITED KINGDOM)

MAK& REHMAN LAW

Mob: 03132 838383
Email: highcourt100@gmail.com
 IN THE FEDERAL SERVICE TRIBUNAL,
ISLAMABAD
Appeal No._______/2022

HAMID FAROOQ QURESHI

VERSUS

MINISTRY OF RAILWAY

APPEAL U/S 4 OF SERVICE TRIBUNALS ACT, 1973

AFFIDAVIT

I, Hamid farooq qureshi s/o Muhammad saleem Iqbal working

as senior transportation Pakistan railways r/o Pakistan railways
headquarters office Lahore, do hereby solemnly affirm and
declare as under:

That the contents of the accompanying appeal are true and

correct to the best of my knowledge and belief and nothing has
been concealed or withheld therein.

DEPONENT

It is verified on oath at Islamabad on this ___ day of November

2022 that the contents of the above affidavit are true and correct
to the best of my knowledge and belief and nothing has been
concealed.

DEPONENT
 IN THE FEDERAL SERVICE TRIBUNAL,
ISLAMABAD
Appeal No._______/2022

HAMID FAROOQ QURESHI

VERSUS

MINISTRY OF RAILWAY

APPEAL U/S 4 OF SERVICE TRIBUNALS ACT, 1973

INDEX

S.NO DESCRIPTION OF DOCUMENTS DATED Annex. PAGE

No NO

1 Appeal along with Affidavit

2 Impugned letter dated A

3 Departmental Appeal B

Application for Interim Relief along

with Affidavit

Application for Exemption along

with Affidavit

Wakalatnama

Appellant

Through

RAJA SAIF UR REHMAN

ADVOCATE SUPREME COURT OF PAKISTAN
LLB - LLM (UNITED KINGDOM)

MAK& REHMAN LAW

Mob: 03132 838383
Email: highcourt100@gmail.com