Before the Advisory Board, Govt. of the Punjab, Lahore.

Appeal No. ____________/2002

Anwar Mahmood S/o Muhammad Aslam, caste Qureshi, R/o Mayo

Colony, Masoom Shah Road, proprietor, Shama Plastic Factory,
Multan.
……APPELLANT
VERSUS
1. Multan Electric Power Company Ltd. Khanewal Road,
Multan, through its Chief Executive.
2. Superintending Engineer, MEPCO, Multan Circle, Multan.
3. Executive Engineer, MEPCO Ltd., Cantt. Division, Multan.
4. Revenue Officer, MEPCO Ltd., Cantt. Division, Multan.
5. S.D.O. MEPCO Ltd., Hassan Abad Sub-Division, Multan.
……RESPONDENTS

Appeal against the decision dated 6.7.2002

passed by the Electric Inspector, Multan
Region, Multan.

Respectfully Sheweth: -

1. That the appellant is a consumer of the respondents under

tariff B-2 with sanctioned load of 22 K.W., for running a
plastic factory.

2. That the meter of factory was checked on 8.8.2001 by the

respondents unilaterally without serving prior notice to the
appellant. As appeared from the contents of the F.I.R. No.
408/2001 dated 9.8.2001, the S.D.O. (respondent No. 5)
opened the A.T.B. on 8.8.2001 in the absence of appellant,
removed the meter from the site and then lodged the F.I.R.
against the appellant on 9.8.2001.
3. That the respondents, besides registration of case in P.S. New
Multan, rendered a detection bill of Rs. 124,000/-, which was
wrong, illegal and unjustified. The appellant filed a writ
petition before the Hon’ble Lahore High Court, Bench at
Multan; and then preferred an application to the learned
Electric Inspector, Multan Region, Multan on the direction of
Hon’ble High Court.

4. That the learned Electric Inspector, Multan has reduced the

detection unites to be charged as 16145 instead of 21298 units
vide his order dated 6.7.2002 (Annex “A”).

5. That the order dated 6.7.2002 of the learned Electric

Inspector, Multan is against the law and facts, hence, to be
amended and to set aside the whole detection bill of Rs.
124,000/- on the following:

GROUNDS

i) That the learned Electric Inspector, Multan, has failed

to consider that respondents did not to serve a notice
before checking of meter/opening of A.T.B.

ii) That the learned Electric Inspector, Multan has failed to

consider that the respondents removed the meter from
site on 8.8.2001 and kept in their custody for one day
and then handed over to police on 9.8.2001. In this way,
the respondents succeeded to tamper the meter and
make hole in it.

iii) That the learned Electric Inspector has failed to

consider that the respondents were not clear themselves
about the allegations against the appellant. The
allegations levied in F.I.R., in notice issued to appellant
and in Surveillance Team of MEPCO differ with each
other. Similarly, the S.D.O. MEPCO Hassan Abad Sub-
Division and X.E.N. MEPCO Cantt. Division, Multna
recommended to charge detection bill considering the
period from 5/2001 to 7/2001, but the Surveillance
Team has suggested to charge from 4/2001 to 8/2001. It
 may kindly be noticed that the meter was removed from
the site on 8.8.2001 and supply was disconnected on the
same day.

iv) That, as a matter of act, the factory was given on lease

with effect from 3/2001. The new occupant always
requires some time to settle. So, the consumption of
factory is always liable to rise and fall according to
production, which is absolutely proportional to demand
for which the new occupant has to find customers in the
beginning.

v) That in view of ground realities and facts as stated

above, it is not a case of comparison of consumption
with previous months as the factory was operated by
two different managements, according to their demand
and sale of products.

vi) That the contention of appellant has not been taken into
consideration while deciding the dispute that the
respondent No. 5 had proceeded ex-parte and arbitrarily
at the instance of rival business parties, who are
indulged in malpractices by joining hands with him
(respondent No. 5) and causing heavy loss to MEPCO.
The S.D.O. tried to trap the appellant in the same
business, but when refused, developed grudge and
became inimical with appellant.

vii) That further arguments will be advanced on the date of

hearing fixed by this Hon’ble Tribunal.

It is, therefore, humbly prayed that this

appeal may kindly be accepted to amend the
order dated 6.7.2002, passed by the learned
Electric Inspector, Multan and set aside the
whole impugned detection bill of Rs. 124,000/-.

Any other remedy which this Hon’ble

Tribunal deems fit, may also be granted.

Humble Appellant,

Dated: ________