Grounds

You might also like

Download as docx, pdf, or txt
Download as docx, pdf, or txt
You are on page 1of 15

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

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
2

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

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

GROUNDS;

m. That the impugned orders have been passed illegally, unlawfully and
arbitrarily against the facts, rules and instructions on the subject,
3

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
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.
4

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.
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 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.
5

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 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 statement that
6

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.
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.
7

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.

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 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.
8

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.
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
9

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
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
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.
10

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.

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.
11

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.

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 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.
12

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.
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
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

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.

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.
14

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.
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 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.
15

You might also like