IN THE COURT OF SPECIAL JUDGE ANTI-CORRUPTION

PROVINCIAL COURT SUKKUR.

Cr.Misc: Appln: NO. of 2020.

Abdullah S/O Khuharo Khan Jatoi by caste Jatoi

R/O Village Muhamamd Mithal JAtoi Taluka LAkhi
District Shikarpur. . . . . . Applicant/
Complainant

VERSUS

The State. . . . . . . . . . .. . . Respondent

Offence U/s 409 420 467,477,471

R/W 5 II PPC.
Cr.NO.16/2019 PS ACE Sukkur
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APPLICATION UNDER SECTION 193 CR.P.C.

It is prayed on behalf of the

applicant/complainant that this Honourable Court
may be pleased to join the accused namely (1)
Irshad Ahmed Memon The then Suprintendent
Engineer (2) Chief Engineer Zahoor ul haq , (3)
Zameer Bhangar @ Abdul Ghafoor Mahar Chief
Draftsman on the consideration of the following
grounds:-

FACTS
The case has been registered in compliance of honorable High court
orders dated 18-12-2019 in CP No 755 of 2015 filed by Abdullah Jatoi before
the honorable high court of Sindh bench at sukkur as well as approval of
deputy director the allegation are that during the year 2011 -2012
rehabilitation of chitti canal Jamal wah & Samad wah awarded to M/S
Gansham das vide work order dated 01-06-2011 .The accused officers
/officials of irrigation department Irrigation sukkur Begari Bund Division
Sukkur namely Ghulam Qdir Junejo the then Begari band Division Ghulm
Murtaza Kalwar the then XEN begari band division Sukkur AXEN ayaz Ali
Soomro AXEN Begari Bund Division Nabi Bux Bhayu the then AXEN
Nasrullah Dall the then sub-engineer Ghulam fareed soomro tender clerk /bill
clerk Irshad Hussain Khakhrani Sub Divisin clerk Tarique Hussain junejo bill
clerk in collusion with M/S Gansham das government contractors illegally
recorded bogus MBs work rehabilitation of Chitti Canal Jamal Wah and
Samad Wah made bogus payments Rs 179,21,267 to M/S Ganshamdass after
that during the year 2012 -2013 the work of rehabilitation of structure of Chiti
Canal & Chiti (compartment )Rd 0 to Rd3.5 Chitti Canal Rd 0 to 33 awarded
to M/s Madani enterprises engineering company ( proprietor mansoor
Iqbal)vide work order dated 23-04-2013 but the concerned officials /officers
of Irrigation Begari bund division AXEN Ali Hassan Mangi Nabi Bux Bhayu
AXEN Nasrullah dall sub-engineer Shahmir Soomro sub-engineer Tariq
Hussain Joyu bill clerk al officials of Begari Bund Division Sukkur illegally
recorded bogus MBS of work of rehabilitation of structure of Chiti canal &
Chitti ( compartment)Rd 0 to 3.5 Rd 0 to 33 and prepared bogus bills made
payments amounting to Rs 286,88,630/ to M/s Madaine Engineering
construction company( proprietor Mansoor Iqbal)the above named officials
misappropriated the amount and misused their official powers which is
punishable under the law
Photostat copy of FIR 16/2019 is submitted marked as annexure “A“

G R O U N D S.

1. That the name of the accused (1) Irshad

Ahmed Memon The then Superintendent Engineer (2)
Chief Engineer Zahoor ul haq , (3) Zameer
Bhangar @ Abdul Ghafoor Mahar Chief Draftsman
are incumbent of the office of Chief Engineer
Guddu Barrage, Superintendent Engineer begari
sindh feeder circle .

2. That the Deputy Director ACE SUKKUR

with malafide intention mixed with the accused
persons and let off the above named accused
persons and not mentioned the names of accused
persons on the bases of so called defense
evidence managed by the Deputy Director ACE in
league with accused persons.

3. That the accused persons committed

heinous offence and are connected with the
commission of crime and they all with planning
participated in above crime and joint signatory
of the re-appropriation amount as the audit
officer also raised objection the amount shown
in the FIR is of 05 crores but the actual amount
after the re-appropriation the amount have
increased upto the 20 crores and the no work is
done as per circle officer before the Honorable
High Court .

4. That the complainant lodged FIR against

the above named accused persons with specific
role assigned to then as per rules of business
and caused loss to the National Exchequer and
usurp the entire amount without any work done
and the amount of contractual work is increased
also fully supported version of the complainant
by the then audit officer

5. That in the interest of justice join

the above named accused in the above case and
proceed in accordance with law.

SUKKUR:
DATED: . .2020. ADVOCATE FOR APPLICANT
COMPLAINANT.