IN THE LAHORE HIGH COURT, RAWALPINDI

BENCH, RAWALPINDI

W.P.No: ______________ /2023

Dr. Anser Ishaque,

Chief Executive Officer, District Health Authority, Rawalpindi

Petitioner

Versus

1. The Secretary, Primary and Secondary

Healthcare Department, Government of the Punjab,
1 Birdwood Road, Lahore.

2.

3.

4.

WRIT PETITION UNDER ARTICLE 199 OF

THE CONSTITUTION OF ISLAMIC REPUBLIC OF PAKISTAN

Respectfully Sheweth,

1. That the addresses of the partie given above are sufficient for the purpose of service of
this Honorable Court.

2. That the petitioner is a respectable and law abiding citizen of Pakistan.

3. That the petitioner is a Local Government employee, serving in BPS 19.

4. That the petitioner has been serving up to the entire satisfaction of his superiors for the
last 32 years and not even a single explanation regarding his performance has ever been
issued to him by the competent authorities during the 32 years of his service.

5. That the petitioner, being the senior most doctor in the district was posted as Chief
Executive Officer (Health), District Health Authority Rawalpindi vide order no Dated
3rd August 2022. (Annexure 'A').

6. That when the petitioner took the charge of the post, District Rawalpindi was between
33 to 36, (Annexure 'B') on ranking of the CEO's score card since 2022. The petitioner
took this as a challege to improve the ranking of the District in different indicators of the
Health Facilities and with efforts of 5 months was able to bring the district at 12th
ranking. (Annexure 'C').

7. That when the petitioner took the charge, the polio campaign performances of the
district was at very low level and maximum of LQASs either failed or remained
intermidiate. After posting of the petitioner, the LQAS and PCM performances improved
a lot and on average results were above 90%.(Annexure 'D').

8. That before the assumption of the charge as CEO (Health) Rawalpindi by the petitioner,
the environmental sample of polio virus was positive from Safdarabad and Dhoke Dalal
areas of Rawalpindi but due to proper planning of the petitioner and sweeping activities
in 16 high risks Union Councils of Rawal Town, the environmental samples of the last
three months from these areas became negative.

9. That the petitioner after assumption of the charge highlighted the corruption and
malpractices of Rs. 266 million of Ex Chief Executive Officer (Health), District Health
Officer (Preventive Services) & District Health Officer (Medical Services) which were also
endorsed by the Regional Audit Director Local Fund Audit in the Audit Report for the
year 2021 & 2022 in 11 audit paras, with the remarks/directions to the Secretary
Primary and Secondary Health to probe into the matter and fix responsibilities within 30
days. This report of audit was forwarded on 28th Dec 2022 but after a lapse of 55 days,
no action was taken by the respondant no 1 on this report (Annexure 'E').

10. That the petitioner managed to recover a government vehicle no RIG 1209, Toyota
Hilux, 2009 model from an ex-EDO (Health) which was illegally in his use from January
2015 to October 2022 for more than seven years after being transferred from District's
health department in January 2015 and 2 years after his retirement in September 2020.

11. That the petitioner constituted an inquiry committee to asses the rent and depreciation
of the vehicle. The committee's report was forwarded to respondant No 1 for necessary
action vide letter no dated (Annexure 'F') for recovery of Rs.882500/- but the
same is still pending with respondant No.1.
12. That the petitioner highlighted Mr. Malik Adnan Awan, male sanitary patrol as ghost
employee since his appointment in 2017 but the District Health Officer (Preventive
Services) was intentionally disbursing his salaries since 2017 to date and in due process
regularised his services in 2019. (Annexure 'G').

13. That the petitioner also highlighted the violation of rules and irregularities in the
recruitment of 90 BPS 1 employess (Chokidars & Naib Qasids) in which District Health
Officer (Preventive Services) was also a member of the selection committee (Annexure
'H').

14. That the petitioner also highlighted the malpractices of District Health Officer
(Preventive Services) vide Letter No Dated and constituted an inquiry committee to
probe the corruption of District Health Officer (Preventive Services) who took approval
from the petitioner for purchasing essential items (Glucose Strips, Hepatitis Strips &
Urine Strips) for improvement of CEO's Scorecard as mentioned in CEOs conference of
November 2022, but intentionally changed the list and purchased 129 useless items
which were neither demanded by the incharges of the Health Facilities facilities nor
were required for the improvement of CEO scorecard by violating Public Procurement
Regulatory Authority (PPRA) rules.

15. That the respondent No 1, instead of taking action against this corrupt District Health
Officer (PS) on account of corruption, malpractices and violation of rules rewarded him
with the post of Chief Executive Officer (Health) vide order No Dated , being an
officer of BPS 18, on BPS 19/20 post superceding 4 senior officer in the District in BPS 19
among whom 3 are serving in last years of their retirements.

16. That the respondant No 1, completely ignored/violated directions of the Election

Commission of Pakistan vide letter No Dated , that no officer shall be transferred
from the election areas without approval of the Election Commission, just to post a
junior corrupt officer on a higher grade post superceding 4 senior doctors and ignoring
all his corruptions.

17. That according to the transfer policy, an officer in his or her last year of service before
retirement shall be allowed to work on the same post in the same city.

18. It is therfore humbly prayed that the petitioner being a senior officer than the
respondant No 4 and at the verge of his retirement and without completion of tenure
shall be allowed to work on the same post in the same district till his date of
superannuation on 20th August 2023.
19.
20. 17. Proper inquiries should be conducted against respondant No.4 as reported by CEO
(Health) and audit authorities in above referred letters before posting him on any post
handling public finances.