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
 2

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

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
 3

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
 4

a written statement that he did not want to take further

action on his application. In these circumstances, the

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.
 5

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

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
 6

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
 7

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
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
 8

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 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.
 9

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
 10

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 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
 11

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 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
 12

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
 13

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 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.
 14

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
 15

Partem, therefore, the impugned order is not

sustainable in the eye of law.
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.
 16

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.
zz. That the impugned order is exparte and without giving
any opportunity of hearing to the appellant. He has
been condemned unheard.
 17

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
 18

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 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.
 19

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.
 20

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.
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
 21

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
 22

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.
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.
 23

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 conduct
any regular inquiry without assigning any reasons.
Reliance is placed on 2007 SCMR 192 and 2006
SCMR 846.
 24

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.
 25

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.

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
 26

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
 27

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 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.
 28

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
 29

is also violation 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.
 30

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.
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.
 31

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.
 32

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 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
 33

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.
 34

ffffff.That the impugned order is exparte and without giving

any opportunity of hearing to the appellant. He has
been condemned unheard.

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.
 35

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.
oooooo. That the impugned order is exparte and without
giving any opportunity of hearing to the appellant. He
has been condemned unheard.
 36

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
 37

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
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.
 38

yyyyyy.
zzzzzz.