1

GROUNDS;

a. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject, hence
the same are not sustainable in the eyes of law being without any
justification and unwarranted.
b. That the allegation leveled against the appellant was based on surmises
and conjectures and against facts being concocted story. Factual
position is that on 3.5.2019 the appellant was posted at PS Sadar
Wazirabad. Muhammad Yousaf s/o Muhammad Hussain caste Jatt
Rindhawa r/o Gujranwala submitted an application which was marked
to the appellant. Bothe the parties were called vide order No. 160
Cr.P.C. Both the parties came to PS. In the application Jamshaid etc on
5.5.2019, a compromise was made between both the parties. As
agreement was made that on 6.5.2019 the land measuring 5 acre
situated at Bharokay Cheema will be returned. However, another
agreement was made that learned measuring 01 acre ‘Shatala’ field will
be returned after a month. A stamp paper was given by Jamshaid etc to
the complainant Muhammad Yousaf. Both the parties were produced
before the SHO and matter was solved. On 7.5.2019 the complainant
Muhammad Yousaf submitted an application against the appellant.
c. That a case FIR No. 286/19 dated 7.5.2019 under section 302/109/34
PPC PS Tatlaywali was registered against the appellant and during this
the appellant was transferred to Police Station Ladhaywala Warriach.
Therefore, the appellant was posted at his new place of posting. On
9.10.2019 Malik Asad Awan submitted an application against the
appellant. But actually, the appellant had no connection with the
application. The appellant had not received any amount as illegal
gratification from him. The allegations leveled against the appellant are
false and frivolous.
d. That due to registration of the case against the appellant, he could not
join the inquiry proceedings. However, the appellant requested the
authority that inquiry may kindly be enquired through some other
inquiry officer. Moreover, the complainant submitted a written
statement that he did not want to take further action on his
application. In these circumstances, the
 2

GROUNDS;

e. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject, hence
the same are not sustainable in the eyes of law being without any
justification and unwarranted.
f. That the allegation leveled against the appellant was based on surmises
and conjectures and against facts being concocted story. Factual
position is that on 3.5.2019 the appellant was posted at PS Sadar
Wazirabad. Muhammad Yousaf s/o Muhammad Hussain caste Jatt
Rindhawa r/o Gujranwala submitted an application which was marked
to the appellant. Bothe the parties were called vide order No. 160
Cr.P.C. Both the parties came to PS. In the application Jamshaid etc on
5.5.2019, a compromise was made between both the parties. As
agreement was made that on 6.5.2019 the land measuring 5 acre
situated at Bharokay Cheema will be returned. However, another
agreement was made that learned measuring 01 acre ‘Shatala’ field will
be returned after a month. A stamp paper was given by Jamshaid etc to
the complainant Muhammad Yousaf. Both the parties were produced
before the SHO and matter was solved. On 7.5.2019 the complainant
Muhammad Yousaf submitted an application against the appellant.
g. That a case FIR No. 286/19 dated 7.5.2019 under section 302/109/34
PPC PS Tatlaywali was registered against the appellant and during this
the appellant was transferred to Police Station Ladhaywala Warriach.
Therefore, the appellant was posted at his new place of posting. On
9.10.2019 Malik Asad Awan submitted an application against the
appellant. But actually, the appellant had no connection with the
application. The appellant had not received any amount as illegal
gratification from him. The allegations leveled against the appellant are
false and frivolous.
h. That due to registration of the case against the appellant, he could not
join the inquiry proceedings. However, the appellant requested the
authority that inquiry may kindly be enquired through some other
inquiry officer. Moreover, the complainant submitted a written
statement that he did not want to take further action on his
application. In these circumstances, the
 3

GROUNDS;

i. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject, hence
the same are not sustainable in the eyes of law being without any
justification and unwarranted.
j. That the allegation leveled against the appellant was based on surmises
and conjectures and against facts being concocted story. Factual
position is that on 3.5.2019 the appellant was posted at PS Sadar
Wazirabad. Muhammad Yousaf s/o Muhammad Hussain caste Jatt
Rindhawa r/o Gujranwala submitted an application which was marked
to the appellant. Bothe the parties were called vide order No. 160
Cr.P.C. Both the parties came to PS. In the application Jamshaid etc on
5.5.2019, a compromise was made between both the parties. As
agreement was made that on 6.5.2019 the land measuring 5 acre
situated at Bharokay Cheema will be returned. However, another
agreement was made that learned measuring 01 acre ‘Shatala’ field will
be returned after a month. A stamp paper was given by Jamshaid etc to
the complainant Muhammad Yousaf. Both the parties were produced
before the SHO and matter was solved. On 7.5.2019 the complainant
Muhammad Yousaf submitted an application against the appellant.
k. That a case FIR No. 286/19 dated 7.5.2019 under section 302/109/34
PPC PS Tatlaywali was registered against the appellant and during this
the appellant was transferred to Police Station Ladhaywala Warriach.
Therefore, the appellant was posted at his new place of posting. On
9.10.2019 Malik Asad Awan submitted an application against the
appellant. But actually, the appellant had no connection with the
application. The appellant had not received any amount as illegal
gratification from him. The allegations leveled against the appellant are
false and frivolous.
l. That due to registration of the case against the appellant, he could not
join the inquiry proceedings. However, the appellant requested the
authority that inquiry may kindly be enquired through some other
inquiry officer. Moreover, the complainant submitted a written
statement that he did not want to take further action on his
application. In these circumstances, the
 4

GROUNDS;

m. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject, hence
the same are not sustainable in the eyes of law being without any
justification and unwarranted.
n. That the allegation leveled against the appellant was based on surmises
and conjectures and against facts being concocted story. Factual
position is that on 3.5.2019 the appellant was posted at PS Sadar
Wazirabad. Muhammad Yousaf s/o Muhammad Hussain caste Jatt
Rindhawa r/o Gujranwala submitted an application which was marked
to the appellant. Bothe the parties were called vide order No. 160
Cr.P.C. Both the parties came to PS. In the application Jamshaid etc on
5.5.2019, a compromise was made between both the parties. As
agreement was made that on 6.5.2019 the land measuring 5 acre
situated at Bharokay Cheema will be returned. However, another
agreement was made that learned measuring 01 acre ‘Shatala’ field will
be returned after a month. A stamp paper was given by Jamshaid etc to
the complainant Muhammad Yousaf. Both the parties were produced
before the SHO and matter was solved. On 7.5.2019 the complainant
Muhammad Yousaf submitted an application against the appellant.
o. That a case FIR No. 286/19 dated 7.5.2019 under section 302/109/34
PPC PS Tatlaywali was registered against the appellant and during this
the appellant was transferred to Police Station Ladhaywala Warriach.
Therefore, the appellant was posted at his new place of posting. On
9.10.2019 Malik Asad Awan submitted an application against the
appellant. But actually, the appellant had no connection with the
application. The appellant had not received any amount as illegal
gratification from him. The allegations leveled against the appellant are
false and frivolous.
p. That due to registration of the case against the appellant, he could not
join the inquiry proceedings. However, the appellant requested the
authority that inquiry may kindly be enquired through some other
inquiry officer. Moreover, the complainant submitted a written
statement that he did not want to take further action on his
application. In these circumstances, the
 5

q.

GROUNDS;

r. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject, hence
the same are not sustainable in the eyes of law being without any
justification and unwarranted.
s. That the allegation leveled against the appellant was based on surmises
and conjectures and against facts being concocted story. Factual
position is that on 3.5.2019 the appellant was posted at PS Sadar
Wazirabad. Muhammad Yousaf s/o Muhammad Hussain caste Jatt
Rindhawa r/o Gujranwala submitted an application which was marked
to the appellant. Bothe the parties were called vide order No. 160
Cr.P.C. Both the parties came to PS. In the application Jamshaid etc on
5.5.2019, a compromise was made between both the parties. As
agreement was made that on 6.5.2019 the land measuring 5 acre
situated at Bharokay Cheema will be returned. However, another
agreement was made that learned measuring 01 acre ‘Shatala’ field will
be returned after a month. A stamp paper was given by Jamshaid etc to
the complainant Muhammad Yousaf. Both the parties were produced
before the SHO and matter was solved. On 7.5.2019 the complainant
Muhammad Yousaf submitted an application against the appellant.
t. That a case FIR No. 286/19 dated 7.5.2019 under section 302/109/34
PPC PS Tatlaywali was registered against the appellant and during this
the appellant was transferred to Police Station Ladhaywala Warriach.
Therefore, the appellant was posted at his new place of posting. On
9.10.2019 Malik Asad Awan submitted an application against the
appellant. But actually, the appellant had no connection with the
application. The appellant had not received any amount as illegal
gratification from him. The allegations leveled against the appellant are
false and frivolous.
u. That due to registration of the case against the appellant, he could not
join the inquiry proceedings. However, the appellant requested the
authority that inquiry may kindly be enquired through some other
inquiry officer. Moreover, the complainant submitted a written
 6

statement that he did not want to take further action on his

application. In these circumstances, the

GROUNDS;

v. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject, hence
the same are not sustainable in the eyes of law being without any
justification and unwarranted.
w. That the allegation leveled against the appellant was based on surmises
and conjectures and against facts being concocted story. Factual
position is that on 3.5.2019 the appellant was posted at PS Sadar
Wazirabad. Muhammad Yousaf s/o Muhammad Hussain caste Jatt
Rindhawa r/o Gujranwala submitted an application which was marked
to the appellant. Bothe the parties were called vide order No. 160
Cr.P.C. Both the parties came to PS. In the application Jamshaid etc on
5.5.2019, a compromise was made between both the parties. As
agreement was made that on 6.5.2019 the land measuring 5 acre
situated at Bharokay Cheema will be returned. However, another
agreement was made that learned measuring 01 acre ‘Shatala’ field will
be returned after a month. A stamp paper was given by Jamshaid etc to
the complainant Muhammad Yousaf. Both the parties were produced
before the SHO and matter was solved. On 7.5.2019 the complainant
Muhammad Yousaf submitted an application against the appellant.
x. That a case FIR No. 286/19 dated 7.5.2019 under section 302/109/34
PPC PS Tatlaywali was registered against the appellant and during this
the appellant was transferred to Police Station Ladhaywala Warriach.
Therefore, the appellant was posted at his new place of posting. On
9.10.2019 Malik Asad Awan submitted an application against the
appellant. But actually, the appellant had no connection with the
application. The appellant had not received any amount as illegal
gratification from him. The allegations leveled against the appellant are
false and frivolous.
y. That due to registration of the case against the appellant, he could not
join the inquiry proceedings. However, the appellant requested the
authority that inquiry may kindly be enquired through some other
inquiry officer. Moreover, the complainant submitted a written
 7

statement that he did not want to take further action on his

application. In these circumstances, the

GROUNDS;

z. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject, hence
the same are not sustainable in the eyes of law being without any
justification and unwarranted.
aa. That the allegation leveled against the appellant was based on surmises
and conjectures and against facts being concocted story. Factual
position is that on 3.5.2019 the appellant was posted at PS Sadar
Wazirabad. Muhammad Yousaf s/o Muhammad Hussain caste Jatt
Rindhawa r/o Gujranwala submitted an application which was marked
to the appellant. Bothe the parties were called vide order No. 160
Cr.P.C. Both the parties came to PS. In the application Jamshaid etc on
5.5.2019, a compromise was made between both the parties. As
agreement was made that on 6.5.2019 the land measuring 5 acre
situated at Bharokay Cheema will be returned. However, another
agreement was made that learned measuring 01 acre ‘Shatala’ field will
be returned after a month. A stamp paper was given by Jamshaid etc to
the complainant Muhammad Yousaf. Both the parties were produced
before the SHO and matter was solved. On 7.5.2019 the complainant
Muhammad Yousaf submitted an application against the appellant.
bb. That a case FIR No. 286/19 dated 7.5.2019 under section 302/109/34
PPC PS Tatlaywali was registered against the appellant and during this
the appellant was transferred to Police Station Ladhaywala Warriach.
Therefore, the appellant was posted at his new place of posting. On
9.10.2019 Malik Asad Awan submitted an application against the
appellant. But actually, the appellant had no connection with the
application. The appellant had not received any amount as illegal
gratification from him. The allegations leveled against the appellant are
false and frivolous.
cc. That due to registration of the case against the appellant, he could not
join the inquiry proceedings. However, the appellant requested the
authority that inquiry may kindly be enquired through some other
inquiry officer. Moreover, the complainant submitted a written
 8

statement that he did not want to take further action on his

application. In these circumstances, the

GROUNDS;

dd. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject, hence
the same are not sustainable in the eyes of law being without any
justification and unwarranted.
ee. That the allegation leveled against the appellant was based on surmises
and conjectures and against facts being concocted story. Factual
position is that on 3.5.2019 the appellant was posted at PS Sadar
Wazirabad. Muhammad Yousaf s/o Muhammad Hussain caste Jatt
Rindhawa r/o Gujranwala submitted an application which was marked
to the appellant. Bothe the parties were called vide order No. 160
Cr.P.C. Both the parties came to PS. In the application Jamshaid etc on
5.5.2019, a compromise was made between both the parties. As
agreement was made that on 6.5.2019 the land measuring 5 acre
situated at Bharokay Cheema will be returned. However, another
agreement was made that learned measuring 01 acre ‘Shatala’ field will
be returned after a month. A stamp paper was given by Jamshaid etc to
the complainant Muhammad Yousaf. Both the parties were produced
before the SHO and matter was solved. On 7.5.2019 the complainant
Muhammad Yousaf submitted an application against the appellant.
ff. That a case FIR No. 286/19 dated 7.5.2019 under section 302/109/34
PPC PS Tatlaywali was registered against the appellant and during this
the appellant was transferred to Police Station Ladhaywala Warriach.
Therefore, the appellant was posted at his new place of posting. On
9.10.2019 Malik Asad Awan submitted an application against the
appellant. But actually, the appellant had no connection with the
application. The appellant had not received any amount as illegal
gratification from him. The allegations leveled against the appellant are
false and frivolous.
gg. That due to registration of the case against the appellant, he could not
join the inquiry proceedings. However, the appellant requested the
authority that inquiry may kindly be enquired through some other
inquiry officer. Moreover, the complainant submitted a written
 9

statement that he did not want to take further action on his

application. In these circumstances, the
hh.
ii. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
jj. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
kk. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
ll. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
mm. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
nn. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

oo. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
pp. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
 10

qq. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
rr. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
ss. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
tt. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

uu. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
vv. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
ww. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
xx. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
yy. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
 11

zz. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

aaa. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
bbb. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
ccc. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
ddd. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
eee. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
fff. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

ggg. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
hhh. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
 12

the Article 10 of the Constitution 1973 of the country. It is also violation

of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
iii. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
jjj. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
kkk. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
lll. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

mmm. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
nnn. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
ooo. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
ppp. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
 13

qqq. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
rrr. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

sss. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
ttt. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
uuu. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
vvv. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
www. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
xxx. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

yyy. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
 14

conduct any regular inquiry without assigning any reasons. Reliance is

placed on 2007 SCMR 192 and 2006 SCMR 846.
zzz. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
aaaa. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
bbbb. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
cccc. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
dddd. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

eeee. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
ffff. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
gggg. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
hhhh. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
 15

conduct any regular inquiry without assigning any reasons. Reliance is

placed on 2007 SCMR 192 and 2006 SCMR 846.
iiii. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
jjjj. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

kkkk. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
llll. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
mmmm. That the impugned order is exparte and without giving any
opportunity of hearing to the appellant. He has been condemned
unheard.
nnnn. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
oooo. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
pppp. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
 16

qqqq. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
rrrr. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
ssss. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
tttt. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
uuuu. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
vvvv. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

wwww. That it reflects from the charges that various factual controversies
are involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
xxxx. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
 17

of principle of Audi alterem Partem, therefore, the impugned order is

not sustainable in the eye of law.
yyyy. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
zzzz. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
aaaaa. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
bbbbb. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

ccccc. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
ddddd. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
eeeee. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
fffff. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
ggggg. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
 18

of principle of Audi alterem Partem, therefore, the impugned order is

not sustainable in the eye of law.
hhhhh. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

iiiii. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
jjjjj. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
kkkkk. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
lllll. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
mmmmm. That no show cause notice was ever served upon the appellant
which is sheer and clear violation of principle of natural justice as
guaranteed by the Article 10 of the Constitution 1973 of the country. It
is also violation of principle of Audi alterem Partem, therefore, the
impugned order is not sustainable in the eye of law.
nnnnn. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

ooooo. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
 19

ppppp. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
qqqqq. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
rrrrr. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
sssss. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
ttttt. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

uuuuu. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
vvvvv. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
wwwww. That the impugned order is exparte and without giving any
opportunity of hearing to the appellant. He has been condemned
unheard.
xxxxx. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
 20

holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
yyyyy. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
zzzzz. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

aaaaaa. That it reflects from the charges that various factual controversies
are involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
bbbbbb. That no show cause notice was ever served upon the appellant
which is sheer and clear violation of principle of natural justice as
guaranteed by the Article 10 of the Constitution 1973 of the country. It
is also violation of principle of Audi alterem Partem, therefore, the
impugned order is not sustainable in the eye of law.
cccccc. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
dddddd. That it reflects from the charges that various factual controversies
are involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
eeeeee. That no show cause notice was ever served upon the appellant
which is sheer and clear violation of principle of natural justice as
guaranteed by the Article 10 of the Constitution 1973 of the country. It
is also violation of principle of Audi alterem Partem, therefore, the
impugned order is not sustainable in the eye of law.
ffffff. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
 21

gggggg. That it reflects from the charges that various factual controversies
are involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
hhhhhh. That no show cause notice was ever served upon the appellant
which is sheer and clear violation of principle of natural justice as
guaranteed by the Article 10 of the Constitution 1973 of the country. It
is also violation of principle of Audi alterem Partem, therefore, the
impugned order is not sustainable in the eye of law.
iiiiii. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.
jjjjjj. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
kkkkkk.That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
llllll. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

mmmmmm. That it reflects from the charges that various factual

controversies are involved which is matter of inquiry and cannot be
resolved without holding a regular and full-fledged inquiry but the
authority did not conduct any regular inquiry without assigning any
reasons. Reliance is placed on 2007 SCMR 192 and 2006 SCMR 846.
nnnnnn. That no show cause notice was ever served upon the appellant
which is sheer and clear violation of principle of natural justice as
guaranteed by the Article 10 of the Constitution 1973 of the country. It
is also violation of principle of Audi alterem Partem, therefore, the
impugned order is not sustainable in the eye of law.
 22

oooooo. That the impugned order is exparte and without giving any
opportunity of hearing to the appellant. He has been condemned
unheard.
pppppp. That it reflects from the charges that various factual controversies
are involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
qqqqqq. That no show cause notice was ever served upon the appellant
which is sheer and clear violation of principle of natural justice as
guaranteed by the Article 10 of the Constitution 1973 of the country. It
is also violation of principle of Audi alterem Partem, therefore, the
impugned order is not sustainable in the eye of law.
rrrrrr. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

ssssss. That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
tttttt. That no show cause notice was ever served upon the appellant which is
sheer and clear violation of principle of natural justice as guaranteed by
the Article 10 of the Constitution 1973 of the country. It is also violation
of principle of Audi alterem Partem, therefore, the impugned order is
not sustainable in the eye of law.
uuuuuu. That the impugned order is exparte and without giving any
opportunity of hearing to the appellant. He has been condemned
unheard.
vvvvvv.That it reflects from the charges that various factual controversies are
involved which is matter of inquiry and cannot be resolved without
holding a regular and full-fledged inquiry but the authority did not
conduct any regular inquiry without assigning any reasons. Reliance is
placed on 2007 SCMR 192 and 2006 SCMR 846.
wwwwww. That no show cause notice was ever served upon the appellant
which is sheer and clear violation of principle of natural justice as
guaranteed by the Article 10 of the Constitution 1973 of the country. It
 23

is also violation of principle of Audi alterem Partem, therefore, the

impugned order is not sustainable in the eye of law.
xxxxxx. That the impugned order is exparte and without giving any opportunity
of hearing to the appellant. He has been condemned unheard.

yyyyyy.
zzzzzz.