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 surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
c. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
d. 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.
e. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
f. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

g. 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.
 2

h. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
i. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
j. 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.
k. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
l. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

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 surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
o. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
 3

of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
p. 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.
q. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
r. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

s. 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.
t. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
u. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
v. 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
 4

conduct any regular inquiry without assigning any reasons. Reliance is

placed on 2007 SCMR 192 and 2006 SCMR 846.
w. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
x. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

y. 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.
z. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
aa. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
bb. 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.
cc. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
 5

the guilt of the accused. Reliance is placed on PLC 1995 CS 134

Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
dd. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

ee. 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.
ff. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
gg. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
hh. 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.
ii. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
jj. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.
 6

GROUNDS;

kk. 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.
ll. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
mm. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
nn. 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.
oo. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
pp. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

qq. 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.
 7

rr. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
ss. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
tt. 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.
uu. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
vv. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

ww. 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.
xx. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
yy. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
 8

of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
zz. 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.
aaa. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
bbb. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

ccc. 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.
ddd. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
eee. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
fff. 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
 9

conduct any regular inquiry without assigning any reasons. Reliance is

placed on 2007 SCMR 192 and 2006 SCMR 846.
ggg. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
hhh. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

iii. 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.
jjj. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
kkk. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
lll. 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.
mmm. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
 10

Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
nnn. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

ooo. 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.
ppp. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
qqq. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
rrr. 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.
sss. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
ttt. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.
 11

GROUNDS;

uuu. 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.
vvv. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
www. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
xxx. 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.
yyy. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
zzz. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

aaaa. 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.
 12

bbbb. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
cccc. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
dddd. 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.
eeee. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
ffff. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

gggg. 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.
hhhh. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
iiii. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
 13

of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
jjjj. 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.
kkkk. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
llll. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.

GROUNDS;

mmmm. 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.
nnnn. That the allegation leveled against the appellant was based on surmised
and conjectures and against facts being concocted story. The appellant
was not involved in the above said incident. The appellant is quite
innocent in the matter.
oooo. That the appellant has been awarded the penalty of reduction in pay by
one stage by the DPO, Okara in violation to the provisions of Rule 4.12
of CSR Punjab. As per Rule 4.12 of CSR Punjab, DPO, Okara was
bound to specify the period within which the penalty of Reduction in pay
will remain operative. No such period has been specified, hence the
penalty order being in violation to Rule 4.12 of CSR, Punjab is illegal
and not sustainable under the law.
pppp. 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.
qqqq. That the penalty awarded to the appellant is too harsh and does not
commensurate with the quantum of guilt of the appellant. It is settled
principle of law that quantum of punishment should commensurate with
the guilt of the accused. Reliance is placed on PLC 1995 CS 134
Qurban Ali Vs. DIG, KLR 2006, L&SC (FST) 205(b), 2006 SCMR
104, 2008 SCMR 1362 and 2007 PLC (CS) 247 (SC).
rrrr. That the appellant always performed his duties to the entire satisfaction
of his seniors. He performed his duties honestly and dedicatedly and the
appellant is quite innocent in the matter.