1

BEFORE THE HONOURABLE ISLAMABAD HIGH COURT, ISLAMABAD

(CONSTITUTIONAL JURISDICTION)

WRIT PETITION NO____ OF 2023

M/S BNP (PVT.) LIMITED,

A PRIVATE LIMITED COMPANY
HAVING ITS OFFICE AT
P-5, KARKHANA BAZAR, FAISALABAD
THROUGH MR. ___________,
ITS DULY AUTHORISED REPRESENTATIVE ;
.....PETITIONER

VERSUS

1. CAPITAL DEVELOPMENT AUTHORITY (“CDA”),

THROUGH ITS CHAIRMAN,
HAVING ITS HEADQUARTERS AT
KHAYABAN-E-SUHARWARDI,
SECTOR G–7/4, ISLAMABAD;

2. DIRECTOR, ESTATE MANAGEMENT – II,

CAPITAL DEVELOPMENT AUTHORITY,
CDA HEADQUARTERS,
KHAYABAN-E-SUHARWARDI,
SECTOR G–7/4, ISLAMABAD;
.....RESPONDENTS

3. MR. ABDUL HAFEEZ SHEIKH,

CHIEF EXECUTIVE OFFICER OF M/S BNP (PVT.) LIMITED
HAVING HIS OFFICIAL ADDRESS AT
P-5 KARKHANA BAZAR, FAISALABAD;
… PROFORMA RESPONDENT

--------------------------------------
CONSTITUTIONAL PETITION UNDER ARTICLE 199 OF THE
CONSTITUTION OF ISLAMIC REPUBLIC OF PAKISTAN, 1973;
--------------------------------------
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RELIEF CLAIMED:

I. That the Petitioner through this instant Writ Petition has

sought indulgence from this Honorable Court, to inter alia set

aside the Impugned Termination Notice dated 08.03.2023, (the

“Impugned Notice”) issued by the Respondent No. 1,

whereby the said Respondent purportedly repudiated the

Petitioner’s Lease Deed dated 28.07.2005 (the “Lease Deed”),

viz the property situated at One Constitution Avenue,

Islamabad (the “Leased Property”);

II. That the Petitioner further seeks indulgence from this

Honorable Court to the effect that the Respondent No. 1 may

be directed to maintain status quo on the rights and obligations

viz. the Leased Property, as well as restraining the said

Respondent No. 1 from creating any third-party rights on the

Leased Property;

Respectfully sheweth:

1. That correct addresses of the parties have been supplied in the

caption hereof, which are sufficient for purposes of service of

notices, summons and other allied processes that may, from

time to time, be issued by this Honorable Court.

PARTIES:

(i) The Petitioner;

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2. That Petitioner (“BNP”) is a private company limited by

shares, duly incorporated with the Securities and Exchange

Commission of Pakistan in terms of the applicable company

laws of the country. The instant Petition is being filed through

Mr. ____________, who has been duly authorised do so vide

the board resolution dated 26.06.2023.

(A copy of the board resolution dated 26.06.2023 is annexed as

Annex [ ].)

3. That through this present Petition, the Petitioner inter alia

seeks enforcement of its proprietary rights arising out of the

Lease Deed dated 28.07.2005 (the Lease Deed), with regard to

the property situated at One Constitution Avenue, Islamabad,

(the Leased Property).

(ii) The Respondents No. 1 & 2;

4. That the Respondent No. 1, Capital Development Authority, is

a statutory body, established and functioning under the

Capital Development Authority Ordinance, 1960. It has been

impleaded in its capacity as the “Lessor” in terms of the Lease

Deed dated 28.07.2005.

5. That the Respondent No. 2, the Director, Estate Management–

II, is the official of the Respondent No. 1. The Impugned

Notice dated 08.03.2023 was issued under the signature of

Respondent No. 2; he has therefore been impleaded as a

necessary and property Party hereto;

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(iii) The Respondent No. 3;

6. That Respondent No. 3 is the Chief Executive of the Petitioner

Company and is being impleaded as a proforma Respondent

as he is currently out of Pakistan for medical reasons. Upon

his return to Pakistan, he will seek to be transposed as a

Petitioner in this present Petition.

BACKGROUND FACTS:

I. FACTUAL BACKGROUND REGARDING THE GRANT OF LEASE;

(i) The Procurement Process & Grant of Lease to the Petitioner;

7. That in year 2004, the Respondent No. 1 undertook the

procurement process for sale of Leasehold rights of plot

situated at One Constitution Avenue, measuring 13.5 acres,

near Convention Centre, Constitution Avenue, Islamabad. In

this regard, initially the procurement process was commenced

through newspaper advertisement dated 13.04.2004; however,

this initial procurement process was cancelled by the

Respondent No. 1, due to lack of response.

8. That subsequently, a fresh procurement process was initiated

by the Respondent No. 1 vide the newspaper advertisement

dated 28.09.2004, whereby applications for pre-qualification

were invited. The Petitioner duly participated in this pre-

qualification process. After evaluating all the applications

received, the Respondent No. 1 vide its letter dated 11.01.2005,

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declared the Petitioner, as well as six other participants, as

successfully prequalified applicants.

9. That the subsequent tender / auction process was held on

09.03.2005. After evaluation of all bids, the Petitioner was

declared as the successful bidder at the bid price of Rs.

75,000/- per sq. yard, for total area of 65,098 sq. yards,

totalling 4.882 billion.

(ii) The Execution of Lease Deed & Amendments thereto;

10. That upon completion of all the formalities, the Lease Deed

was finally executed inter se the Petitioner and the Respondent

No. 1 on 28.07.2005, whereby a 99-year lease was granted to

the Petitioner. This Lease Deed was duly registered with the

Rent Controller, Islamabad.

11. That subsequently, the Lease Deed was amended on two

occasions; the First Amendment dated 04.10.2007, was

necessitated due to the fact that after the devastating

earthquake of October 2005, the CDA started reviewing and

revising applicable building codes and byelaws, and all the

activities viz. approval of building plans etc., were halted. It

was in consideration of the consequent delays on part of CDA

that this first amendment was executed inter se the Parties.

12. That the Second Amendment dated 07.01.2013 arose due to

refusal on part of the Civil Aviation Authority (“CAA”) to

grant NOC for the project. In this regard, CAA required that
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the maximum height of the Project must be reduced from 750

feet to not more than 330.64 feet including the overhead water

tanks. These restrictions placed by CAA had the effect of

changing the entire financial basis of the proposed project, as

well as severely limited the Petitioner’s rights arising from the

Lease Deed. Consequently, the Petitioner filed a suit for

specific enforcement of Lease, and recovery of damages to the

tune of Rs. 6.23 billion against the Respondent No. 1. These

disputes were subsequently settled inter se the Parties in an

amicable manner, which settlement was implemented vide

this Second Amendment.

(iii) The Challenge to Procurement Process;

13. That while the procurement process was being undertaken,

one of the prequalified parties (M/s Hashwani Hotel Limited)

approached the Rawalpindi Bench of honourable Lahore High

Court through W.P. No. 586 of 2005. Through this

constitutional petition certain actions of the Respondent No. 1,

regarding the manner in which procurement process was

being undertaken, were challenged.

14. That while this constitutional petition was pending

adjudication, the procurement was concluded and the present

Petitioner was declared as successful. Subsequently, vide the

Judgement dated 27.04.2005, the honourable High Court, after

reviewing the entire procurement process, dismissed the

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petition. Though the ICA No. 64 of 2005 was filed against this

dismissal order; however, the same was dismissed for non-

prosecution in 2010. This order was never challenged by any

party and consequently, the judgement of learned single

judge, whereby the process was held to be transparent,

attained finality.

II. FIRST PURPORTED CANCELLATION OF LEASE & LITIGATION

ARISING THEREFROM;

(i) The Directions by Public Accounts Committee & Actions

Consequent therefrom;

15. That as has been stated hereinabove, through the Second

Amendment dated 16.05.2013, the Petitioner and the

Respondent No. 1 settled their disputes, that had arisen due to

the reduction in maximum height of the building; these

included the conditional withdrawal of the Petitioner’s claims

for recovery of Rs. 6.23 billion, raised in a civil suit filed by

Petitioner against the Respondent No. 1.

However, despite signing of this Amendment, the

implementation thereof was kept pending by the Respondent

No. 1 on one ground or another. It was finally in March of

2014 that the Respondent No. 1 agreed to implement the same.

Consequently, the revised drawings and architectural plans

were submitted by the Petitioner, which stood approved in

April of 2014.
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16. That however, soon thereafter, certain audit paras pertaining

to Respondent No. 1 were taken by Public Accounts

Committee (PAC). In this regard, the PAC, in its meeting held

on 29.05.2014, without any notice to the Petitioner, referred

the case pertaining to grant of lease to the Petitioner, to

National Accountability Bureau (NAB) as well as Federal

Investigation Agency (FIA).

17. That in addition to the above, the PAC, vide its letter dated

21.07.2014, also directed the Respondent No. 1 to stop

construction activities on project site; these directions were

issued to Respondent No. 1 in furtherance of the PAC’s

decisions taken aforementioned meeting dated 29.05.2014.

(ii) The CDA’s Actions Pursuant to PAC’s Directions & First

Round of Litigation;

18. That consequent upon these directives issued by PAC, the

Respondent No. 1, vide its letter dated 05.08.2014 directed the

Petitioner to stop all construction activities. The Petitioner

challenged these actions before this honourable Court through

the constitutional petition bearing W.P. No. 3755/2014. This

petition was allowed through Judgement dated 03.03.2016. in

this regard, this honourable Court while setting aside the

Respondent No. 1’s letter dated 05.08.2014, directed the said

Respondent to reconsider the entire matter on merits and after

providing an opportunity of hearing to the Petitioner.

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(iii) The Purported Cancellation of Lease by CDA & Second

Round of Litigation;

19. That after pronouncement of the aforementioned Judgement

dated 03.03.2016 in W.P. No. 3755/2014, the Respondent No. 1

undertook unilateral administrative exercise, whereby the

process leading to award of Leasehold rights, and subsequent

amendments thereto, were re-evaluated. Consequent to this

unilateral and mala fide exercise, on 03.08.2016, the

Respondent No. 1 proceeded to cancel the Lease Deed.

20. That this cancellation of Lease Deed, was challenged by the

Petitioner before this Hon’ble Court vide the constitutional

petition bearing W.P. No. 3043/2016. Furthermore, multiple

other petitions were also filed by various third-party

stakeholders, which were connected with the W.P. No.

3043/2016. However, vide the Judgement dated 03.03.2017,

Hon’ble Single Judge of this Court proceeded to dismiss all of

these petitions.

21. That the Judgement dated 03.03.2017 was challenged through

various intra-court appeals, including ICA No. 109/2018 filed

by the present Petitioner, which were also dismissed by the

Judgment dated 03.09.2018. This Judgement was again

challenged by the Petitioner before the August Supreme Court

of Pakistan through the C.A. No. 1280/2018; along with this

civil appeal, the other affected parties also filed their

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respective appeals before the August Supreme Court of

Pakistan, which were all clubbed and decided together.

(iv) The Revival of Lease Deed on Amended Terms and

Conditions;

22. That it was in the above background that the August Supreme

Court vide its short order on 09.01.2019 allowed all these

appeals. Furthermore, through this short order, the Lease

Deed was revived; however, the August Supreme Court

changed the main condition of the Lease by increasing the

total consideration to be paid by the Petitioner from Rs. 4.882

billion to Rs. 17.5 billion; furthermore, the payment schedule

of these payments was approximately halved from 15 years to

8 years. The detailed Order in furtherance of this short order

dated 09.01.2019 has never been issued.

23. That after announcement of this short order, the Petitioner,

filed a review petition thereagainst, which was marked as

CRP No. 200/2019. Similarly, the Respondent No. 1 also filed

a review petition which was marked as CRP No. 174/2019.

III. BACKGROUND OF EVENTS SUBSEQUENT TO REVIVAL OF LEASE

DEED;

(i) The Pronouncement of Short Order dated 09.01.2019 &

Petitioner’s Attempts for Implementation thereof;

24. That in terms of the short Order dated 09.01.2019 pronounced

by the August Supreme Court of Pakistan, Respondent No. 1

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was required to sign a revised schedule of payments and

append the same to the Lease Deed. Furthermore, the

Petitioner was also required to submit a Bank Guarantee to

Respondent No. 1 as a security against future payments.

In this regard, soon after pronouncement of

aforementioned short order, the Petitioner approached the

Respondent No. 1 and vide its letter dated 04.02.2019

submitted drafts of the payment schedule, as well as the draft

format bank guarantee, for approval by the said Respondent.

25. That however, the Respondent No. 1 while patently acting

with mala fide intents, kept pending all the matters viz.

enforcement of short order. In this regard, despite numerous

reminders the Respondent No. 1 has never proceeded with

execution of the revised schedule of payments; the draft

format of bank Guarantee was kept pending for over a year.

Similarly, on one hand the Respondent No. 1 was

delaying the formalization of documents, whereas on the

other hand it kept on delaying the handing over / taking over

of the possession of Lease property; the frivolous and patently

mala fide pretext adopted by Respondent No. 1 for this refusal

of handing over of Lease property, was that de-sealing of

property cannot be processed due to pendency of enquiry by

NAB.
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(ii) The De-Sealing of Property & Intentional Failure of

Respondent No. 1 to Sign Schedule of Payments;

26. That in the above background, it was finally on till ________,

i.e., after lapse of ____ months, that the format for Bank

Guarantee was approved by the Respondent No. 1. Moreover,

the relevant authorities at NAB, vide the letter dated

________, gave express no objection for Respondent No. 1 to

implement the short order. It was after this letter from NAB,

that Respondent No. 1 finally de-sealed the property and

handed over the possession thereof to the Petitioner on

06.01.2021, i.e., 2 years after the pronouncement of short order.

27. That however, even after de-sealing of the Leased Property,

despite numerous requests by the Petitioner, the Respondent

No. 1 continued with its failure to sign the Schedule of

Payments in terms of the Short Order by August Supreme

Court of Pakistan. Consequently, on 31.12.2021, as one year

period from de-sealing of property was nearing completion,

despite the refusal of CDA to sign the payment schedule, BNP

paid an amount of Rs. 1,689,314,167/- to the Respondent No.

1.

(iii) The Continuous & Intentional Failures of Respondent No. 1

to Implement the Short Order dated 09.01.2019;

28. That it is pertinent to clarify that the Petitioner paid the

aforementioned amount of approximately Rs. 1.689 billion to

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the Respondent No. 1 on basis of an apprehension that the

said Respondent was making all out efforts to create frivolous

grounds for cancellation of the Petitioner’s lease. Hence,

though no payment schedule had been signed by the said

Respondent, the Petitioner proceeded to make payments of

maximum amounts which Respondent No. 1 could have

claimed in terms of Short Order; though actual payable

amounts were much lesser.

29. That these apprehensions on part of the Petitioner proved

correct as the said Respondent No. 1, despite having received

these huge payments, started creating unwarranted hurdles

for the project being constructed by the Petitioner at the

Leased property. The following actions on part of the

Respondent No.1 establish beyond any doubt that the said

Respondent was making all out efforts for usurping the

Petitioner’s rights under the Lease Deed:

(i) That on 03.03.2022, the Respondent No. 1 directed the

Petitioner to vacate the Project pending the issuance of

the completion certificate;

(ii) That on 17.03.2022, the Respondent No. 1 adopted a

mala fide stance that no further construction would be

allowed on the site till full payment of the lease amount

was made;

(iii) That on 05.04.2022, the Respondent No. 1 purported to

place an unspecified restriction on any transfer in the

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Project; no rationale for imposing this requirement is

disclosed;

(iv) That on 22.11.2022, the Respondent No. 1 stopped the

construction work on the Project. These works were

being carried out by the Petitioner in accordance with

the already approved drawings;

(iv) The Negotiations for Settlement of all due amounts through

Debt-Swap;

30. That in consideration of multiple issues being faced and the

numerous disputes inter se the Parties, the Petitioner through

its letter dated 25.07.2022, made a proposal to the Respondent

No. 1 for settlement of all the disputes; through this proposal,

the Petitioner offered to pay off the entire amount of Rs. 17.5

billion immediately instead of over 8 years through a debt-

asset swap.

31. That in furtherance of this proposal, multiple meetings were

held inter se the Parties, including meetings under the chair of

learned Attorney General of Pakistan. In this regard, though

an agreement was reached between all the concerned parties,

and the mechanism for implementation of this in principle

agreement was being discussed; however, on 12.12.2022, the

Respondent No. 1 receded from its in-principle agreement.

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IV. THE PURPORTED CANCELLATION OF LEASE LEADING TO THIS

PRESENT PETITION;

32. That in the aforementioned background, it is a matter of

record that the Respondent No. 1 failed to the timely

approvals and permissions lawfully requested and required

by the Petitioner. These violations of the short order further

adversely affected the Petitioner’s ability to generate the funds

required for making payments to the Respondent No. 1.

33. That while proceeding with same mala fide aims, that the

Respondent No. 1, after receding from its in principle

agreement viz. debt-swap settlement, purported to issue the

Notice dated 07.02.2023, whereby communicated its intention

to terminate the lease.

34. That though the Petitioner was making arrangements so as to

ensure the payments being claimed by the Respondent No. 1;

however, the said Respondent, prior to completion of 30 days’

notice period, purported to issue the Termination Notice

dated 08.03.2023.

35. That in the aforementioned factual background, as well as in

consideration of the applicable legal principles, the Petitioner

has no other alternate and efficacious remedy but to approach

this Honourable Court, in its constitutional jurisdiction;

Hence, the Petitioner has now approached this

Honourable Court, seeking inter-alia, the setting aside of the

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Impugned Notices dated 07.02.2023 and 08.03.2023

(hereinafter collectively referred to as the “Impugned

Notices”) on the following, amongst other grounds;

GROUNDS;

I. That the Impugned Notices have the effect of violating

the Petitioner’s constitutional rights under inter alia

Articles 4, 18, 23, 24 and 25 of the Constitution of

Islamic Republic of Pakistan, 1973 (the “Constitution”);

the same are therefore liable to be set aside on this

ground alone;

II. That in addition to the above, the manner in which the

Lease property has been forcefully taken over by the

Respondent No. 1 amounts to a blatant and clear

violation of the Petitioner’s right to fair trial guaranteed

under Article 10A of the Constitution; the Impugned

Notices are therefore liable to be set aside;

III. That without prejudice to the merits of this Petitioner, it

is submitted that the Petitioner has always been willing

and ready to deposit and pay to the Respondent No. 1,

any and all of payments that have become due in terms

of the Lease Deed, as well as the short order dated

09.01.2019. It is further submitted in this regard, that

pending adjudication of this Petition, the Petitioner is

17

willing to deposit these amounts with this Honourable

Court;

IV. That the Short Order dated 09.01.2019, pronounced by

the August Supreme Court of Pakistan, inter alia

provided that

“In case BNP commits default in furnishing a

guarantee or payment of any instalment on its due

date, CDA shall have the right, after giving 30 days’

notice to terminate the lease.”

However, the mode and manner in which the

Impugned Notices were served by the Respondent No.

1 violates the mechanism defined by the August

Supreme Court of Pakistan. It is clarified in this regard

that the first Notice was served by the Respondent No.

1 on 07.02.2023, whereby the Petitioner was asked to

remedy the alleged default in payment of amounts.

However, after only 28 days from the first notice, the

Impugned Termination Notice dated 08.03.2023 was

served upon the Petitioner. Hence, the Impugned

Notices are liable to be set aside on this ground alone;

V. That in addition to the above, the terms of Lease Deed

dated 28.07.2005, vide its Clause 3.5 provides that:

“3.5 The lease granted under this Lease Deed in

favour of the Lessee shall be irrevocable, except where

the following occurred:

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(i) Default in payment of the remaining cost of the

Said Demised Property as per the terms and

conditions of this Deed; or

(ii) ….. “

In the event any of the above events have occurred, the

Lessor shall serve upon the Lessee a notice notifying it

of. Such default and allowing the Lessee a period of 30

(thirty) days, from the date of the notice, to remedy the

default, failing which this Deed may be terminated by

the Lessor. In the event this Deed is terminated as

stated above, the Lessee shall from the date of

termination not be under any obligation to pay any

further sums to the Lessor under this Deed or any

other connected document, instrument, agreement,

etc., and the Lessor shall immediately reimburse the

Lessee all costs including but not limited to the costs

of construction, improvements, development, etc.

undertaken by it on the Said Demised Property.”

A mere perusal of this Clause 3.5 of the Lease

Deed makes it patently clear that the Impugned Notices

have been served by the Respondent No. 1 in violation

of the express covenant of the Lease Deed. It is clarified

in this regard that by failing to give a complete 30 days’

notice to the Petitioner, the Respondent No. 1 has

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violated the Petitioner’s express right to remedy the

default (if any) that was being claimed by the said

Respondent. The Impugned Notices are therefore

violative of the Petitioner’s proprietary rights, as well as

the its constitutional right under Article 24(1) of the

Constitution which provides that “No person shall be

deprived of his property save in accordance with law.”;

VI. That the text of first Impugned Notice dated 07.02.2023,

in paragraph 3 thereof, inter alia provides that;

“….. Subsequent reminders have advised you to remit

the due instalment until 31 December 2022 in line

with the Honourable Supreme Court of Pakistan and

re-adjusted timelines given as per the Secretary

Committee / Deputy Secretary PAC letter of 23

October 2020……”

A mere perusal of the afore-quoted text contained

in the Impugned Notice dated 07.02.2023 makes it

patently clear that the same was issued for factors

extraneous to the respective rights and liabilities of the

Parties under the Lease Deed. The Impugned Notice is

therefore liable to be set aside on this ground alone;

VII. That similarly, the text of second Impugned Notice (i.e.,

Termination Notice) dated 08.03.2023, in paragraph 2

thereof, inter alia provides that;

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“….. Through subsequent reminders, it has been

advised you to remit the due instalment until 31

December 2022 in line with the orders of Honourable

Supreme Court of Pakistan and re-adjusted timelines

given as per the Secretary Committee / Deputy

Secretary PAC letter of 23 October 2020….”

A mere perusal of the afore-quoted text contained

in the Impugned Termination Notice dated 08.03.2023

makes it patently clear that this Termination Notice too,

was issued for factors extraneous to the respective

rights and liabilities of the Parties under the Lease

Deed. The Impugned Notice is therefore liable to be set

aside on this ground alone;

VIII. That in addition to the above, a mere perusal of texts of

Impugned Notices quoted in Grounds VI and VIII

(hereinabove), establishes beyond any doubt that the

Respondent No. 1, by issuing the Impugned Notices,

has proceeded to exercise its authority for extraneous

purposes. Hence, the Impugned Notices have been

issued in violation of Section 24-A of the General

Clauses Act, 1897; the same are therefore liable to be set

aside;

IX. That furthermore, the Respondent No. 1 on one hand

has continued to default on its obligation to sign and

21

execute the payment schedule, as per the directions

issued by August Supreme Court of Pakistan in the

short order dated 09.01.2019; whereas, on the other

hand, through the Impugned Notices, it purports to

force the so called ”re-adjusted timelines given by Secretary

Committee / Deputy Secretary PAC” upon the Petitioner.

It is submitted in this regard that attempted

enforcement of the so called re-adjusted timelines

against the Petitioner amounts to violation of

Petitioner’s rights arising from the short order dated

09.01.2019 of the August Supreme Court of Pakistan.

X. That in addition to the above, it is clarified in this

regard that the August Supreme Court, in its short

order dated 09.01.2019, had directed that “Both parties

shall prepare and sign a schedule for yearly payment of

instalments which shall be deemed to be a part of the original

lease.” Hence, the revised payment schedule was to be

“agreed” between the parties, and was to thereafter

would have been deemed to be part of original lease.

The Respondent No. 1’s attempt to super-impose the

PAC’s so called re-adjusted payment schedule upon the

Petitioner therefore constitutes a patent and clear

violation and of the orders of the Supreme Court; the

Impugned Notices are therefore liable to be set aside on

this ground alone;

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XI. That the issuance of Impugned Notices amounts to

arbitrary and capricious exercise of discretion;

XII. That the Impugned Notices are ultra vires of applicable

law and in contravention of settled principles

enunciated by the superior courts of Pakistan;

XIII. That the Respondents, while issuing the Impugned

Notices acted in a mechanical manner without

application of mind;

XIV. That no other alternate and efficacious remedy is

available to the Petitioner; hence, the Petitioner has

approached this Honourable Court, under its inherent

constitutional jurisdiction;

XV. That Petitioner, very respectfully, reserves the right to

raise further grounds in support of its petition while

arguing the matter before this Honourable Court;

PRAYER:

In light of the foregoing facts, submissions and

circumstances, as well as the applicable legal provision, it is most
therefore most respectfully prayed, that by allowing this Petition,
the Impugned Notices dated 07.02.2023 and 08.03.2023 may kindly
be set aside;
That the Petitioner further seeks indulgence from
this Honorable Court to the effect that pending disposal of this
Petition, the Respondent No. 1 may be directed to maintain status
quo on the rights and obligations viz. the Leased Property, as well as
 23

restraining the said Respondent No. 1 from creating any third-party

rights on the Leased Property;

Any other relief not specifically prayed for, which

this Honourable Court deems fit and appropriate on facts of instant
case as well as in interest of justice, equity and fair play, may also be
granted to the Petitioner;

PETITIONER

THROUGH

IFTIKHARUDDIN RIAZ
BILAL AKBAR TARAR BARRISTER
BARRISTER-AT-LAW ADVOCATE SUPREME COURT
ADVOCATE SUPREME COURT CC NO. 11330

SUITE NO. 01, BLOCK 10,

PHA, SECTOR G–8/4,
ISLAMABAD;
MOBILE: 0335 6666986 NASIR MEHMOOD AHMED ABDUL REHMAN
ADVOCATE HIGH COURT ADVOCATE HIGH COURT
CC NO. 00067
BHANDARI NAQVI RIAZ
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