IN THE HON’BLE SUPREME APPELLATE COURT GILGIT-BALTISTAN, AT

GILGIT

CoC Petition No. /2019

In
Review Petition No____________/2018

1. Mohammad Ali Khan s/o Ahmad Shah Contract Lecturer Botany BS-17, Govt. Inter
College Kharmong Skardu.
2. Mohammad Hasnian and Mohammad Hussain Contract Lecturer Chemistry BS-17, Govt.
Inter College Kharmong Skardu.
3. Asghar Ali s/o Johar Ali Contract Lecturer Chemistry BS-17, Govt. Inter Boys Degree
College Skardu.
4. Manzoor Hussain s/o Ghulam Hussain Contract Lecturer Comp. Science BS-17, Govt.
Inter College Kharmong Skardu.
5. Basharat Ali s/o Shukoor Shah Contract Lecturer Comp. Science BS-17, Govt. Degree
College Skardu.
6. Aslam Shah s/o Shukoor Shah Contract Lecturer Economics BS-17, Govt. Inter College
Gupis Ghizer.
7. Wasim Abbas s/o Abdul Aziz Contract Lecturer Economics BS-17, Govt. Boys Degree
College Chilas.
8. Ejaz Haider s/o Abdul Aziz Contract Lecturer Economics BS-17, Govt. Inter College
Gamba Skardu.
9. Asif Hussain s/o Muhammad Amin Contract Lecturer English BS-17, Govt. Inter College
yasin Ghizer.
10. Sultan Ishaq s/o Zakir Hussain Contract Lecturer English BS-17, Govt. Inter College
Shigar Skardu.
11. Fida Hussain S/O Yousaf Ali Contract Lecturer Geography BS-17, Govt. Boys Degree
College Jutial Gilgit.
12. Amin Khan s/o Malik Shah Contract Lecturer Geography BS-17, Govt. Boys Degree
College Aliabad.
13. Muhammad Aqeel s/o Ghulam Muhammad Contract Lecturer Geography BS-17, Govt.
Boys Inter College Kharmong.
14. Sageer Alam s/o Muhammad Wazir Contract Lecturer Islamiyat BS-17, Govt. Boys Inter
College jagir Basin Gilgit.
15. Muhammad Usman s/o Jan Bahadur Contract Lecturer Islamiyat BS-17, Govt. Boys Inter
College Ghizer.
16. Haroon-Ur-Rasheed s/o Ashraf Khan Contract Lecturer Islamiyat BS-17, Govt. Boys
Degree College Chilas.
17. Amjad Iqbal s/o Muhammad Shafi Contract Lecturer Maths BS-17, Govt. Boys Inter
College Kharmong.
18. Sirat Shah s/o Hazrat Shah Contract Lecturer Maths BS-17, Govt. Boys Inter College
yasin Ghizer.
19. Syed Sultan Muhammad s/o Syed Akbar Contract Lecturer Persian BS-17, Govt. Boys
Degree College Skardu.
20. Asif Ali s/o Shah Jahan Contract Lecturer Persian BS-17, Govt. Boys Degree College Ali
Abad.
21. Muhammad Sharif s/o Muhammad Ibrahim Contract Lecturer Physics BS-17, Govt. Boys
Inter College Khaplu.
22. Muhammad Nazir s/o Raj Meer Contract Lecturer Physics BS-17, Govt. Boys Degree
College Chilas.
23. Sharif Ullah s/o Muhammad Shah Contract Lecturer Pol. Science BS-17, Govt. Boys
Degree College Gilgit.
24. Mushtaq Ahmed s/o Abdul Majeed Contract Lecturer Pol. Science BS-17, Govt. Boys
Inter College Shigar Skardu.
25. Fidaullah s/o Shahzada Khan Contract Lecturer Sociology BS-17, Govt. Boys Degree
College Jutial Gilgit.
26. Ismail s/o Ibrahim Khan Contract Lecturer Sociology BS-17, Govt. Boys Inter College
Chalt Nagar.
27. Safdar Khan s/o Mir Ahmed Khan Contract Lecturer Sociology BS-17, Govt. Boys Inter
College Khaplu.
28. Ashraf Hussain s/o Muhammad Contract Lecturer Statistics BS-17, Govt. Boys Degree
College Skardu.
29. Faiz Ullah s/o Muhammad Naeem Contract Lecturer Urdu BS-17, Govt. Boys Degree
College Chilas.
30. Karim Madad s/o Bulbul Wali Khan Contract Lecturer Urdu BS-17, Govt. Boys Inter
College Chalt Nagar.
31. Naeem Ashraf s/o Binyamin Contract Lecturer Zoology BS-17, Govt. Boys inter College
Khaplu.
32. Gazi Johar s/o Shah Barat Contract Lecturer Pak. Studies BS-17, Govt. Boys Degree
Colege Aliabad
33. Alamgir s/o Meherban Ali Contract Lecturer Pak. Studies BS-17, Govt. Boys Degree
College Danyore Gilgit.
34. Sabira Aman d/o Aman Ali Shah Contract Lecturer Botany BS-17, Govt. Degree College
for Women Gilgit.
35. Naima Adanan d/o Farhat Ali Contract Lecturer Chemistry BS-17, Govt. Girls Degree
College Skardu.
36. Uzma Mir d/o Sirajuddin Contract Lecturer Education BS-17, Govt. Girls Degree College
Skardu.
37. Nuzhat W/O Shah Faisal Khan Contract Lecturer Islamiyat BS-17, Govt. Girls Inter
College Gahkuch Ghizer.
38. Bibi Aqeela D/O Maula Dad Contract Lecturer Mathematics BS-17, Govt. Girls Degree
College Skardu.
39. Anser Hina D/O Daulat Shah Contract Lecturer Mathematics BS-17, Govt. Girls Inter
Csollege Karimabad.
40. Shamshad Begum D/O Farman Ali Contract Lecturer Pak-Studies BS-17, Govt. Girls Inter
College Gahkuch Ghizer.
41. Kaneez Zahra d/o Ibrahim Contract Lecturer Physics BS-17, Govt. Girls Inter College
Karimabad.
42. Syeda Zahra d/o Syed Ibrahim Contract Lecturer Pol. Science BS-17, Govt. Girls Degree
College Skardu.
43. Samar Zahra d/o Muhammad Ali Khan Contract Lecturer Psychology BS-17, Govt. Girls
Degree College Gilgit.
44. Najma Khan d/o Muhammad Issa Khan Contract Lecturer Sociology BS-17, Govt. Girls
Inter College Karimabad.

Through their Constituted Attorneys namely:-

i. Alamgir S/o Meharban Ali Lecturer Inter College Chalt Nagar
ii. Fidaullah s/o Shahzada Khan Lecturer Boys Degree College Gilgit.

PETITIONERS

VERSUS

1. Mr. Haseeb Athar Chairman Federal Public Service Commission, F/5/1

Agah Khan Road Islamabad.
2. Muhammad Zamir Ud Din Deputy Assistant Director Regional Office
FPSC Gulsher Colony Konodas Gilgit.
3. Najeeb Alam, Secretary Education Government of Gilgit Baltistan Gilgit.
 4. Rahim Gull, Secretary Law and prosecution Department Gilgit Baltistan,
Gilgit.
5. Manzoor Karim, Director Education (Colleges) Gilgit Baltistan, Gilgit.

CONTEMNORS/RESPONDENTS

APPLICATION UNDER ARTICLE 90 of Government of Gilgit

Baltistan Order 2018 FOR PROCEEDING AGAINST THE UNDER
MENTIONED ACCUSED /CONTEMNORS UNDER
AFOREMENTIONED LAW

May it Please your honor:-

The above named petitioners very respectfully beg to submit as under.

1. That petitioners are serving as on contract basis in BPS- 17 in Education

department of GB since their appointment i.e. 7/03/2014.
2. That this honorable court was pleased to take cognizance through Review
Petition No. 39/2018 wherein a question was raised for resolution inter alia
that they are equally entitled to be appointed against their occupied posts on
permanent basis as their appointments were initially made on merit through
in the wake of test and interview conducted in an identical manner by the
competent authorities duly constituted by the government of GB.
3. That this apex court was pleased to pass mandatory injunctory order dated
16/3/2019 in very clear and categorical terms.
4. That recently the Supreme Appellate Court Gilgit has given temporary
injunction in case No. G.4-75/2014 lecturers male but ironically the Federal
Public Service Commission blatantly refused to obey the orders of Apex
Court and scheduled the interview program on 19/3/2019.
5. That respondents No.1,2,3,and 5/contemnor having knowledge of and despite believing
that a legal matter is sub judice before a Superior Court of Law and injunctions thereto
have consistently been passed on the subject But despite this, the respondents particularly
FPSC did not budge even an inch and in violation of all facts mentioned herein above he
proceeded with the process interview insofar as continuous flouting of the court’s orders
which is tantamount to ridiculing the court’s unquestionable honor and dignity and hence
they are liable to be proceeded against under the contempt laws (the relevant provisions
envisaged in order 2018 reproduced as under for the convenience of this Honorable
Court.)
CONTEMPT OF COURT
1. “Article 90 in this article, the expression “Court” means the Gilgit-Baltistan
Appellate Court or Chief Court.
2. Court shall have power to punish any person who
a. Abuses, interferes with or obstruct the process of the court in any way or
disobeys any order of the court.
b. Scandalizes the court or otherwise does anything which tends to bring the
court or a judge of the court in to hatred, ridicule or contempt.
c. Does anything which tends to prejudice the determination of a matter
pending before the court or
d. Does any other thing which by law constitutes contempt of court”
6. That while denying the authority of the Court, the Respondents No.1, 2,3 and 5 have
made themself liable to be proceeded against under the Contempt Laws by making a
naked attempt to assume the powers of the honorable court purportedly which clearly
constitutes a defiance and sheer arrogance and unacceptable attitude of disrespect towards
the court of law and judiciary at large.

It is therefore prayed that;-

I. The process of interview” by Federal Public Service Commission for appointment

of lecturers against the posts held by contract lecturers BPS-17 in case no. F.4-
75/2014-R may kindly be ordered to be stopped forthwith till the final decision of
Writ Petition No. 39/2018 and the interview under the consolidated advertisement
No F.4-75/2014 may kindly be declared as ultra vires, void ab initio and without
any legal effect.
II. That the respondent no 1, 2, 3 and 5/ contemnors may kindly be dealt with
according to law to maintain the dignity of the judiciary in public perception.
III. Any other remedy which this Honorable Court deems fit in the circumstances of
the case may also kindly be granted to meet the ends of justice.

Dated:-

Filed by Advocate on Record

Petitioners through their

Attorneys

i. Alamgir ii. Fidaullah

& Counsel

Amjad Hussain Advocate

IN THE HON’BLE SUPREME APPELLATE COURT GILGIT-BALTISTAN, AT

GILGIT

CoC Petition No. /2019

In
Review Petition No____________/2018

Muhammad Ali Khan & 43 others

PETITIONERS

Versus
1. Provincial Government Gilgit-Baltistan through Chief Secretary Gilgit-Baltistan.
2. Secretary Services Gilgit-Baltistan.
3. Secretary Education Gilgit-Baltistan.
4. Chairmen Federal Public Services Commission, Aga Khan Road Sector F-5/1
Islamabad.
5. DAD Regional Office FPSC, Gulsher Colony Konodas Gilgit
Respondents
Affidavit

I Shakoor Khan Advocate on Record Supreme Appellate Court Gilgit-

Baltistan solemnly affirm that the contents of above application are correct
and true to the best of my knowledge

Gilgit:
Dated:

Shakoor Khan
Advocate on Record
Supreme appellate court
Gilgit-Baltistan

IN THE HON’BLE SUPREME APPELLATE COURT GILGIT-BALTISTAN, AT

GILGIT

CoC Petition No. /2019

In
Review Petition No____________/2018

Muhammad Ali Khan and 43 others etc.

PETITIONERS

VERSUS

Provincial Government Gilgit-Baltistan through Chief Secretary Gilgit-

Baltistan and 4 others
 RES
PONDENTS

AFFIDAVIT OF FACTS

I, Shakoor Khan Advocate on record Supreme Appellate court Gilgit-

Baltistan do hereby solemnly affirm that contents of petition are correct and
true to best of my knowledge and belief and nothing has been concealed
there from.

Gilgit

Dated;

SHAKOOR KHAN
Advocate on record
Supreme Appellate court
Gilgit-Baltistan

AFFADAVIT OF SERVICE OF NOTICE

I Shakoor Khan, Advocate on Record, Supreme Appellate

Court Gilgit-Baltistan, do hereby solemnly affirm and state that I served the
respondents with notice for filing of Replication of Contempt of Court in
Supreme Appellate Court Gilgit-Baltistan.

That whatever has been stated above is true and correct to the
best of my knowledge and belief and nothing has been concealed there from.

Gilgit:-

Dated.
 SHAKOOR KHAN

Advocate on Record

Supreme Appellate Court

Gilgit-Baltistan
IN THE HON’BLE SUPREME APPELLATE COURT GILGIT-BALTISTAN, AT
GILGIT

CoC Petition No. /2019

In
Review Petition No____________/2018

Muhammad Ali Khan & 43 others

PETITIONERS
VERSUS

1. Provincial Government Gilgit-Baltistan through Chief Secretary Gilgit-

Baltistan.
2. Secretary Law Gilgit-Baltistan.
3. Secretary Education Gilgit-Baltistan.
4. Chairmen Federal Public Services Commission, Aga Khan Road Sector F-
5/1 Islamabad.
5. DAD Regional Office FPSC, Gulsher Colony konodass Gilgit

RESPONDENTS

NOTICE:

Take notice that, petitioners are filing an application for Contempt of

Court before Honorable Supreme Court Gilgit Baltistan.

You are hereby intimated accordingly.

Gilgit:-

Dated.

SHAKOOR KHAN

Advocate on Record

Supreme Appellate
Court

Gilgit-Baltistan
 IN THE HON’BLE SUPREME APPELLATE COURT GILGIT-BALTISTAN,
AT GILGIT

CoC Petition No. /2019

In
Review Petition No____________/2018

Mohammad Ali Khan and 43 others contract lecturers in BPS-17 of Education

Department GB.

PETITIONERS

VERSUS

1. Provincial government Gilgit Baltistan through Chief Secretary GB and 04

others.

RESPONDENTS

APPLICATION UNDER ARTICLE 90 GILGIT BALTISTAN (EMPOWERMENT

AND SELF GOVERNANCE) ORDER 2018

Page
S. No Description of Documents
No.
0
Memo of Contempt Petition 1-4
1
0
Affidavit 5
2
0 Copy of Order Sheet of Supreme Appellate Court Dated
6
3 16-03-19
0
Copy of Interview Schedule by FPSC 7-8
4
0
Copy of Review Petition 9-12
5
0
6
Affidavit of facts 13

0
7
Notice to respondents along with receipts 14

0
8
Affidavit of service of notice 15

0
Power of Attorney to Advocate on record 16
9
Dated: Petitioners through their
Attorneys

i. Fida Ullah
ii. Alamgir

& Counsel
 Amjad Hussain Advocate

BEFORE THE HON’BLE SUPREME APPELLATE COURT GILGIT

BALTISTAN, GILGIT.

(Appellate Jurisdiction)

C.O.C No /2019

Muhammad Ali Khan and 43 Others.

Petitioners
VERSUS
Provincial Government through Chief Secretary and 4 Others.
Respondents

POWER OF ATTORNEY TO ADVOCATE ON RECORD:-

We, Alamgir and Fidaullah, Attorneys / petitioners in the above

petition for contempt of court do hereby appoint and constitute Mr.
Shakoor Khan Advocate on Record Supreme Appellate Court Gilgit
Baltistan for the above said petition for contempt of court to
commence and prosecute / defend or to appear and defend this
petition for contempt of court on behalf of petitioners all proceedings
that may be taken in respect of any application connected with the
same including proceedings in the taxation and application for petition
for contempt of court, to draw and deposit money, to file and take
back documents, to accept the proceedings of the court, to appoint
and instruct counsel, to represent the aforesaid petitioners in the
above matter and to do all things incidental to such acting for the
aforesaid petitioners to rectify all acts done by the aforesaid Advocate
on Record in pursuance of this Authority.

IN WITNESSES THEREOF I DO HEREUNTO SET OUR

HANDS ON THIS 3rd day of April, 2019.

WITNESSES: Signature

1. ______________
2. ______________

Amjad Hussain Advocate will appear as counsel on behalf of petitioners and

argue the case.

Shakoor Khan

ADVOCATE ON RECORD
SUPREME APPELLATE COURT

GILGIT BALTISTAN