BEFORE THE HOUNRABLE FEDERAL OMBUDSMANFOR

PROTECTION AGAINST HARASSEMENT OF WOMAN AT

WORK PLACE,ISLAMABAD

Ms Ismat Bibi

Vs

Imran Amir etc

Application for rejection of complaint
written reply of the application filed by the respondents on behalf of complainant

Sir,
Submitted as under:-
1. Phara no 1 of the application is correct needs no reply.
2. Phara no 2 of the application is also correct.
3. Phara no 3 to the extent of the FIR is correct.
4. Phara no 4 is also correct.
5. Phara no 5 of the application is incorrect hence denied the instant
complaint file before this court and this court has the jurisdiction to
entertain such like complaint as defined by the Protection against
harassment of woman at work place Act 2010.
6. Phara no 6 of application is incorrect the complainant came to this
hounrable court with clean hands and she mentioned what happened to
her during her duty hours besides this fact she also annexedall the
relevant documents and the SD card which are sufficient to prove this
instant complaint , and the purpose of the respondents is just to prolong
the instant complaint by filing such like application.
Besides the above mentioned facts the subject matter is regulated by two
laws.
1. 2.
Special Law General Law
In Special Law the remedies are conviction and damages.
In General Law the section provide conviction alone if proved.
Special Law prevails General Law. Special Court / Special Forums
Jurisdiction is not ousted mere on the ground of proceeding commence
under the General Law.
It is therefore requested that the application of the respondent regarding
rejection of the complaint. may kindly be dismiss and the complaint may
be proceeded according to law.

Complainant
Asmat Bibi

through
Syed Shakeel Ahmad
Advocate High Court
Peshawar