From The Sr.

Superintendent of Police,
Punjab Highway Patrol,
Region Gujranwala
To The Dy. Inspector General of Police,
Punjab Highway Patrol, Punjab, Lahore
(ATTEN: APPEAL CLERK)
No. 1197 /AC Dated: 19-3-2018
Subject: APPEAL/PARAWISE COMMENTS
Memorandum:
Kindly refer to the subject cited above.

2. It is submitted that parawise comments of Ex-Constable Muhammad

Asjad No. 3075, who filed appeal against the punishment of “DISMISSAL FROM
SERVICE ” awarded by the SSP/PHP, Region Gujranwala vide order No.4147-54/PA
dated 20.10.2017, is mentioned below:-

Sr. Questions Reply

No.
1. Respected Sir, Matter of record, otherwise needs no
I am young energetic and well educated comments.
person. To serve my best selected in
Punjab Highway Patrol, as it was
established to change the image of
Traditional Police Force. Since my
recruitment I am serving with dedication
professionally and honestly. I perform my
duties diligently and to utmost satisfaction
of my seniors. I believe in to achieve the
goal earnestly with the GRACE OF ALLAH
ALMIGHTLY.
2. As a result of departmental proceedings Nature of allegations needs no
under the Punjab Police (E&D) Rules, 1975. comments.
I have been awarded major punishment of
dismissal from service by the
Superintendent of Police, Punjab Highway
Patrol, Region Gujranwala vide his office
order No.4147-54/PA, dated 20.10.2017(
(copy enclosed) by taking ex-parte action
on the following allegations:-
“On the direction of SP/PHP, Region Gujranwala SI
Abdul Hafeez, Checking Officer of PHP Gujranwala
Region carried out surprise checking of the post on
06.07.2017 at about 05:10-pm and found you were
absent from the post without any intimation or prior
permission from the competent authority vide DDE
No.08, dated 03.06.2017 and did not return till date. Prior
to this many directions and circular orders have been
issued from this office performance of official duty but
you miserably failed to the orders of your senior officers
and proved to be an inefficient, lethargic and un-
becoming police officer.”
3. The aforementioned allegations leveled Incorrect. Appellant are making
against me are incorrect. In this regard, the concocted stories just to save himself.
Mr. Mazhar Fareed, Incharge PHP District Mr. Mazhar Fareed Incharge PHP
Gujranwala was deputed to conduct regular District Gujranwala conducted
inquiry into the matter. The inquiry officer departmental enquiry on merit, justice
finalized the inquiry in a slipshod manner and under rules/law.
 without observing due formalities. As such I Furthermore, If the appellant had
have been treated in a harsh manner. some genuine problems then he
should have appeared before the
competent authority in order to
discuss the matter or meet the
solution of his problem at least would
meet with enquiry officer by joining
enquiry proceedings but appellant did
not come on any forum.
4. Hence, by way of instant representation/ Needs no comments.
appeal I beg to submit following
facts/submissions with the hope that the
same may receive favorable consideration
at your gracious hands.
5. I submitted that:-
GROUNDS:
(i) My kind Sir, it may be worth submission that (i) Needs no comments.
since the creation of world/human being.
Sickness and death have always remained
beyond human’s control for which on
effected person can hardly be blamed.
(ii) I am facing the problem of backache. (ii) Incorrect. If appellant’s had suffered
Resultantly the doctors recommended me from backache problems then he
bed rest for getting proper medical treatment. should have appeared before the
The reason which I was unable to resume my competent authority alongwith medical
duty. documents / record to meet the
solutions of his problem but appellant
neither appeared before the
competent authority despite calling 4
times nor appeared before the enquiry
officer despite calling 3 times.
Appellant also remained fail to inform
the department, which clearly shown
his black intentions. Upon which, he
was rightly awarded the punishment.

(iii) Due to my illness my family was facing very
problem and I was very much stressed. I was
not in condition to resume my official duty.
(iv) Due to above said reasons, I was unable to
resume duty as I remained under medical
treatment/rest. It is my hard luck that due one
of the other reason I could not inform the
department about the same due to
emergency, metal stress and worries.
6. That throughout my service I always
discharged my official duties to the best of
my ability and to the entire satisfaction of
the kind seniors/superiors i.e. with full
devotion and diligence. My officers did not
see sympathetic view of my service career
and awarded me harsh punishment of
DISMISSAL FROM SERVICE without any
observing the real facts.
7. I am poor man having no other source of
income. The employment was the only
source of bread winning for my family. Due
to un-timely dismissed from service. I am
facing hard days of financial instability.
Keeping in view the welfare of my family
and me. I deserve leniency by your kind
authority on humanitarian grounds. I may
kindly be given a chance to serve the
department.
(iii) Reply has already been given in the
above grounds No. ii
(iv) Reply has already been given in
the above grounds No. ii
Incorrect. The appellant has black
performing result. According to the
record, appellant has earned 10 bad
entries in credit during his till service
record. The appellant remained fail to
perform his duty in well manner in any
corner and keeping his result & illicit
acts he was rightly awarded the
punishment on merit & justice.
Incorrect. If appellant had some minor
responsibilities then he had adopted
all legal formalities before leaving
official duty but he remained fail.
Moreover, despite of frequent time call
by enquiry officer to join departmental
enquiry proceedings to dig out facts
and calling by punishing authority to
attend OR, he did not come on any
forum. If appellant had some genuine
 problems/reasons then he definitely
come alongwith solid evidence/proof
but he badly failed. Upon which, by
following rules/law he was rightly
awarded with deserved punishment.
8. In the light of above facts/submissions, it is Prayer of the appellant otherwise
prayed that the order passed by the under law/rules he was rightly
Superintendent of Police, Punjab Highway awarded with punishment.
Patrol, Region Gujranwala regarding
punishment of dismissal from service
may very kindly be set-aside and I may
kindly be re-instated in service from the date
of dismissal with all back benefits. For this
act of kindness, I shall remain obliged
praying for your long life and prosperity.

(SHUJAAT ALI RANA) PSP

Superintendent of Police,
Punjab Highway Patrol,
Region Gujranwala
From The Superintendent of Police,
Punjab Highway Patrol,
Gujranwala Region, Gujranwala
To The Dy. Inspector General of Police,
Punjab Highway Patrol, Punjab
(ATTEN: APPEAL CLERK)
No. 1198 /AC Dated: 19-3-2018
Subject: APPEAL/PARAWISE COMMENTS
Memorandum:
Kindly refer to the subject cited above.

2. It is submitted that parawise comments of Ex-Constable Muhammad

Saleem No. 3827, who filed appeal against the punishment of “DISMISSAL FROM
SERVICE ” awarded by the SSP/PHP, Region Gujranwala vide order No.4537/PA
dated 29.11.2017, is mentioned below:-

Sr. Questions Reply

No.
1. Respected Sheweth. With excellent respects Need no comments.
& regards I beg to submit the following few
lines for favorable and sympathetic
consideration for which all the aggrieved
subordinates look towards your benevolent
hands.
2. The facts giving rise to the instant appeal are Nature of allegations hence needs no
that as a result of departmental proceedings comments.
under the Punjab Police E&E Rules, 1975. I
have been awarded major punishment of
dismissal from service by the Superintendent
of Police, PHP, Gujranwala vide his office
order NO.4537/PA dated 29.11.2017 on the
following allegations:-
Show Cause Notice No.4417/PA dated 23.11.2017
1. “Incharge /PHP District Gujranwala conducted an
enquiry by the order of SP/PHP R. Gujranwala vide letter
No.4823/R dated 26.10.2017 on the application of
Muhammad Yaqoob s/o Mehr Din, contents are
mentioned below:-
 Applicant is posted in Traffic Police district Narowal.
 Applicant’s children are young & jobless and is living hand
to mouth.
 Applicant met with Muhammad Saleem, who is employee
at PHP Post Adda Bastan and having belt No.3827.
 Constable promised to get employment for him and his
son in foreign.
 In this connection Constable demanded total
Rs.250,000/-. Out of which Rs.1,00,000/- at spot.
 Applicant’s son Muhammad Bilal Rs.1,00,000/- &
Passport handed over to constable at his office situated
at ShakarGarh in the presence of Qari Muhammad
Shafiq, Muhammad Mushtaq Khan, Muhammad Usman,
Shahid Raza Khan, Sajid Khan & Khawer Javed.
 Further decided that remaining amount will be given after
departing to abroad.
 Constable M. Saleem No.3827 received 1 lac rupees from
him and by giving him a form in the presence of witness,
told that your visa has confirmed and as soon they will be
departure to abroad.
 Now, the constable is vanished and also closed his office.
 Further applicant requested to return his money.
2. E.O conducted an comprehensive enquiry upon the
matter and submitted his finding report vide No.2629/R
dated 9.11.2017, which announced that:-
  He alongwith Ikram-ul-Haq made an office at Shakargarh
to departure people to abroad.
 He promised to applicant for getting job for him & his son
in foreign (Dubai)
 On this account, he demanded 250,000/- from applicant.
 In this connection, applicant’s son M. Bilal gave him Rs.
100,000/- & Passports in the presence of witness at your
ShakarGarh office.
 Further agreement that remaining money / rupees will be
provided after departing to abroad.
 After sometimes, he along with Ikram-ul-Haq closed the
office.
 He orally stated that applicant’s son Visa delayed due to
loss of money. However, visa will be confirmed in 10
days.
 During enquiry proceedings no written agreement by both
parties come on table. However his alongwith Ikram-ul-
Haq committed illegal play with applicant come on
surface.
 Being Member of disciplined force, his giving deceive to
people by working as Agent & yet not returning back 1 lac
rupess to applicant is against the law/rules.
 Further E.O recommended to initiate stern departmental
action against him.
Show Cause Notice No.2765/PA dated 12.6.2017
The Incharge PHP District Narowal forwarded a special report
duly prepared by the Incharge Post PHP Addabostan, District
Narowal against him containing the allegation that on
07.06.2017 the Reader to the Incharge PHP District Narowal
directed that he was appeared before the AIG/PHP Punjab
Lahore on 08.06.2017 at 09:00-am and he was informed
telephonically about his appearance but he did not appeared
before the AIG/PHP Punjab Lahore despite of prior direction.
Moreover, Incharge post mentioned in his report that an FIR
No. 131/17 u/s 489-F, dated 23.05.2017 was registered
against him at Police Station City, Shakr Gharh, District
Narowal. Moreover he became absent from the post without
any intimation or prior permission from the competent
authority vide DDE No. 28, dated 07.06.2017 and did not
return till date. He reported back at duty vide DDE No.19
dated 13.6.2017 after 6-days, 14-hours & 45-minutes.
He was also placed under suspension by this office order
NO.2764/PA dated 12.6.2017.
Show Cause Notice No.2902/PA dated 1.7.2017
“On the direction of SP/PHP R. Gujranwala SI Abdul Hafeez,
Checking Officer of PHP Gujranwala Region carried out
surprise checking of the Post on 18.05.2017 at about 02:25-
pm and found that he absent from the post without any
intimation or prior permission from the competent authority
vide DDE No. 11, dated 18.05.2017 and returned on duty vide
DDE No. 20, dated 18.05.2017 after the absence of 02 hours.
Show Cause Notice No.2783/PA dated 12.6.2017
The Incharge PHP District Gujranwala sent a special report
against him containing the allegation that the Reader to the
Incharge PHP District Gujranwala (Checking Officer) on the
direction of SP/PHP R. Gujranwala telephonically checked
the attendance of the post on 30.05.2017 at about 09:55-am
and found you absent from the post vide DDE No. 04, dated
24.05.2017 and returned on duty vide DDE No. 13, dated
30.05.2017 after the absence of 06 days, 05 hours and 20
minutes.
Show Cause Notice No.3806/PA dated 19.9.2017*
“A “special report” received from Incharge PHP District
Narowal vide his office letter No.1953/R dated 12.9.2017,
which intimating therein that he absented from his official
duty, without getting any prior permission or leave from
competent authority as mentioned below:-
Sr. Rapt & date Rapt & Absence period
# of absence date arrival Days Hrs Mnt
1 17/26.8.17 17/27.11.17 93 - -
3. No proper regular enquiry according to rules Incorrect.
was held to verify the facts and  A regular departmental enquiry
circumstances which lead my so-called has been carried out on his 93
absence from duty. Before the award of days absence through Enquiry
major punishment of dismissal from service Officer, who held him guilty to not
proper procedure was not adopted by the follow any legal procedure
concerned authority and thus I was denied regarding obtaining leave or
the opportunity of defense. The Provisional permission before leaving the
Police Officer, Punjab has issued clear department.
instructions vide Circular Memo. N.1849-
1779/HRC dated 17.06.2008 that in the light
 of ruling of the Honorable Supreme Court of  In addition to an enquiry also got
Pakistan the following instructions should be conducted through enquiry officer
complied with in letter and spirit:- on the application of M. Yaqoob,
i) Holding of a regular enquiry must not be which found that applicant to do
dispense with in a case involving factual work of visa and boarding to
controversy. foreign country after took money
ii) A regular enquiry must be held wherever
along Govt. job and applicant took
a resolution of the disputed facts is found
necessary, especially where the misconduct
rupees from applicant & run from
warrants imposition of a major punishment. the spot, which Enquiry Officer
iii) Award of major punishment merely be held appellant guilty and appellant
means of service of a show cause notice is admitted his crime.
considered to be a violation of the ruling of the  Moreover, appellant despite of
Apex Court. getting prior intimation did not
attend office of the Addl.
IGP/PHP. Moreover, held him
guilty in case FIR No.131/17 u/s
489-F dated 23.5.2017 by I.O of
the case, intimated by DPO
Narowal vide his office letter
No.9136 dated 23.8.2017.
 In addition to, remaining long
absence record, including above
mentioned allegation is offence-
able crime.
 Appellant also failed to defend the
allegation in the orderly room. On
this illicit act, he was rightly with
deserved punishment under
law/rules.
4. The aforementioned allegations leveled Incorrect. A full chance was given to
against me are incorrect. The authority was the appellant in orderly room to
supposed to decide the case in true defend the allegation but appellant
perspective after affording the full remained fail to explain his position
opportunity of hearing as envisaged under against the allegations:-
Article 10-A of the constitution of Islamic  Found guilty in departmental
Republic of Pakistan but the impugned order enquiry on his 93 days absence.
was passed observing legal formalities  Found guilty in case FIR No.
which is against the natural justice. In this 131/17 u/s 489-F dated 23.5.2017
way, the appellant has been awarded major by I.O of the case, intimated by
penalty by depriving the righty of defense. DPO Narowal vide his office letter
The impugned order is inoperative having no No.9136 dated 23.8.2017
legal footings and the same is liable to be  Enquiry Officer also held him
set-aside. strongly guilty into charges on
being member of discipline force
departing people to abroad & not
return the money to applicant
Muhammad Yaqoob s/o Mehr Din.
 Hence, by following all rules/law
order was passed and is
absolutely based on fact, merit &
justice under law/rules.

5. Hence, by way of instant representation/ Needs no comments.

appeal I beg to submit following
facts/submissions with the hope that the
same may receive favorable consideration at
your gracious hands.
6. The factual position is that the alleged Incorrect. The appellant is just
absence was neither intentional nor making concocted stories to save
deliberate but the same was due to un- himself.
avoidable circumstances. My kind Sir, it may  If the appellant suffered from any
be worth submission that since the creation kind of problems then he should
 of world/human beings, sickness and earth
have always remained beyond human’s
control for which an effected person can
hardly be blamed. As regard absence from
duty it may be submitted that on 20.08.2017
I had met with an accident in which I received
injury which cause severe back bone on my
spinal cord. I remained under medical
treatment in Akram Hospital Shakargarh for
three months. Due to severe pain, on
21.8.2017 I had approached DHQ Hospital,
Narowal where the Medical Officer advised
me complete bed rest. A copy of the same is
enclosed herewith. In the meanwhile, my
sister had seriously fallen sick and due to
diagnose her blood cancer, my father also
met with heart attack and remained under
medical treatment. It was great tension for
me that my sister died due to blood cancer
and my father was suffering from heart
disease. I was also sick and patient of lumber
spine. Due to crucial and emergent
circumstances I was unable to join the duty.
It is my hard luck that after restoration of
health when I came back to join the duty. I
was not allowed to do so due to which my so
called absence was also prolonged. The
facts and circumstances which lead to my so
called absence from duty call for
consideration my contention on
humanitarian grounds.
7. As regard allegations pertaining the
application of Muhammad Yaqoob s/o Mehr
Din i.e. giving amount etc. it may be
submitted that the matter was inquired by
W/Addl. IGP, PHP Lahore in which I was
cleared. After clearance I was re-instated in
service from the date of suspension I was
posted back to PHP Adda Bastan on
21.07.2017. In this connection, I was also
acquitted by the court of law in criminal case
registered against me. A copy of court’s
judgment is enclosed herewith for kind
perusal. To sum up it is humbly stated that
the allegations as mentioned in the criminal
case have been quashed against me and I
stand acquitted in the said case by the court
of law.
8. The above mentioned facts are absolutely
true which fully negate the allegations
against me. This all shows that in fact, I have
been fallen prey to the misconception of facts
and nothing else. There is no fault on my part
with regard to the allegations attributed on
my part by the punishing authority. It is my
hard luck that I was not provided opportunity
of defense either by the enquiry officer of
punishing authority before the award of
major punishment. Kind Sir, I was punished
on the basis of sketchy enquiry report
continuing surmises and conjunctions. I did
nothing wrong. I am innocent
have informed the department &
obtained leave by adopting all
legal formalities but neither
appellant appeared before the
competent authority nor follow any
such practice.
In addition to other allegations also
have valued as:-
 Found him guilty by the E.O in the
departmental enquiry, he failed to
submit any solid evidence / proof
in his favor against 93 days
absence.
 In other enquiry, declared him
guilty to do visa work and took
money from applicant and run
from spot.
 Found guilty in case FIR No.
131/17 u/s 489-F dated 23.5.2017
by I.O of the case, intimated by
DPO Narowal vide his office letter
No.9136 dated 23.8.2017
 Found guilty in other allegations.
 Hence, considering all values
view of the E.O he was awarded
with punishment.
Incorrect. The appellant was placed
under suspension by this office Order
No.2764/PA dated 12.6.2017 on his
involvement in case FIR No. 131/17
u/s 489-F dated 23.5.2017 and was
not reinstated from suspension.
Moreover, he was also declared
guilty in case investigation by the I.O
intimated by the DPO Narowal vide
his office letter No.9136 dated
23.8.2017.
Incorrect. Appellant remained fail in
any corner. He was found in any
enquiry and every E.O as mentioned
below:-
 Found him guilty by the E.O in the
departmental enquiry, he failed to
submit any solid evidence / proof
in his favor against 93 days
absence.
 In other enquiry, declared him
guilty to do visa work and took
money from applicant and run
from spot.
  Found guilty in case FIR No.
131/17 u/s 489-F dated 23.5.2017
by I.O of the case, intimated by
DPO Narowal vide his office letter
No.9136 dated 23.8.2017
 Found guilty in other allegations.
Upon which, he was rightly awarded
the punishment under law/rules.
9. I am poor man having no other source of Incorrect. however, he was rightly
income. The employment was the only awarded the punishment on following
source of bread winning for my family. Due allegations:-
to dismissal from service I have faced a lot of  Found him guilty by the E.O in the
problems and still facing hard days of departmental enquiry, he failed to
financial instability. Keeping in view the submit any solid evidence / proof in
welfare of my family and me I deserve his favor against 93 days absence.
leniency by your kind authority on  In other enquiry, declared him guilty
to do visa work and took money from
humanitarian grounds. I want to serve the
applicant and run from spot.
department. I may kindly be given a chance
 Found guilty in case FIR No. 131/17
to serve the department. u/s 489-F dated 23.5.2017 by I.O of
the case, intimated by DPO Narowal
vide his office letter No.9136 dated
23.8.2017
 Found guilty in other allegations.
10. In the light of above facts/submissions, it is The appellant was rightly awarded
prayed that the order passed by SSP/PHP, the punishment on following
Region Gujranwala regarding punishment of grounds:-
dismissal from service may very kindly be  Found him guilty by the E.O in the
set-aside and I may kindly be re-instated in departmental enquiry, he failed to
service from the date of dismissal with all submit any solid evidence / proof in
back benefits. his favor against 93 days absence.
 In other enquiry, declared him guilty
to do visa work and took money from
applicant and run from spot.
 Found guilty in case FIR No. 131/17
u/s 489-F dated 23.5.2017 by I.O of
the case, intimated by DPO Narowal
vide his office letter No.9136 dated
23.8.2017
 Found guilty in other allegations.
11. For this act of kindness, I shall remain Prayer of the appellant, however, he
obliged praying for your long life and was rightly awarded the punishment.
prosperity. I shall be grateful if an opportunity
to be heard in person s afforded to me to
explain my case in more details.

(SHUJAAT ALI RANA) PSP

Superintendent of Police,
Punjab Highway Patrol,
Gujranwala Region, Gujranwala