IN THE LAHORE HIGH COURT LAHORE.

Writ Petition No. ______________ / 2024

Sajid Ahmed Khan Son of Ahmed Khan Bhatti, Resident

of New Campus Road, House No.11, Street Number Johar,
Mohallah Canal Bank Lahore.
Through attorney Safdar Iqbal Ranjha son of Muhammad
Hanif resident of Thakkar Kalan post Office Bherowal,
Tehsil Phalia, District Mandi baha Ud Din.
….Petitioner

VERSUS

1. Chief Election Commissioner through Secretary,

Election Commission of Pakistan, Islamabad.
2. Provincial Election Commissioner Punjab Lahore.
3. Government of Punjab through its Chief Secretary,
Lahore.
4. Inspector General of Police, Punjab, Church Road,
Old Anarkali Road, Lahore.
5. District Police Officer (DPO), Mandi Bahauddin.
6. District Returning Officer, Mandi Bahauddin.
7. Returning Officer NA 69 Mandi Bahauddin.
8. Returning Officer PP 42 Mandi Baha-ud-Din.

….Respondents

WRIT PETITION UNDER ARTICLE 199 OF THE

CONSTITUTION OF ISLAMIC REPUBLIC OF
PAKISTAN, 1973
*******
May it Please the Honourable Court:

1. That the names and addresses of the parties as

given in the heading of the instant petition are

sufficient for the purposes of effecting the service on

the parties.

2. That the Petitioner is a law-abiding citizen of

Pakistan and has close relations with Mr. Parvez

Elahi who served as Chief Minister for the Province

of Punjab for two times and belongs to a political

party (Pakistan Tehreek-e-Insaf) which is in shallow

waters these days.

3. That for the upcoming General Elections announced

to be held on 08.02.2024 the petitioner submitted

his nomination papers to contest the General

Elections from NA 69 & PP 42.

4. That initially the respondents No.7 & 8 refused to

receive the nomination papers of the petitioner and

harassed the proposers and seconders of the

petitioner but later on they received the same.

5. That on 30.12.2023 the respondents rejected the

nomination papers of the petitioner and since

30.12.2023 the representative of the petitioner are

trying to get the copy of rejection order so that the

petitioner can file appeal against the rejection order

but the returning officers are not available in their

 offices and nobody is ready to issue attested copies

as prayed for to the representatives of the petitioner

and they technically want to restrain the petitioner

from filing appeal as the appeal can be filed within

three days and after three days the appeal of

petitioner will become time barred. That

furthermore police has been harassing the

representatives of the petitioner who are trying to

obtain copy of the orders dated: 30.12.2023

whereby nomination papers of the petitioner were

rejected. Copies of the receipts are attached

herewith.

6. That there is no alternative immediate and adequate

remedy available to the petitioner to redress his

grievances except to file the instant petition.

It is, therefore, most respectfully

prayed that the instant petition may

kindly be accepted, and the Respondents

may kindly be directed to receive “Naqal

Form” and to provide certified copies of

rejection orders dated 30.12.2023 along

with nomination papers and all annexures

and objections, to the petitioner so that the

 petitioner may file appeals against the

said rejection orders.

It is further prayed that a strict legal

action may also graciously be taken

against the Respondents for infringing

upon the fundamental rights of the

petitioner.

Any other relief as this Honourable

Court may feel fit and appropriate may

also kindly be granted to the Petitioner.

Petitioner

Through:

MUKHTAR RANJHA ASIF MEHMOOD CHEEMA

Advocate High Court Advocate Supreme Court

FARRUKH AMIN RANA IRFAN MEHMOOD RANJHA

Advocate High Court Advocate High Court

MOHSIN QAMAR RANA

Advocate High Court

NOTE:
Under the instruction of my client this is the first
petition on the subject matter before this
Honourable Court.

Advocate
 IN THE LAHORE HIGH COURT LAHORE.

Writ Petition No. ______________ / 2024

In re:
Sajid Ahmed Khan
VS
Chief Election Commissioner etc.

WRIT PETITION UNDER ARTICLE 199 OF THE

CONSTITUTION OF ISLAMIC REPUBLIC OF
PAKISTAN, 1973.

AFFIDAVIT OF Safdar Iqbal Ranjha son of Muhammad

Hanif resident of Thakkar Kalan post Office Bherowal,
Tehsil Phalia, District Mandi baha Ud Din.

I the above named deponent do hereby solemnly affirm and

declare as under:
That the deponent has filed accompanying writ petition before
this Honourable Court and the contents of which are true and
correct and same may be read as an integral part of this
affidavit.

Deponent
VERIFICATION
Verified on oath at Lahore on this 1 st day of
January, 2024 that the contents of the
above said affidavit are true and correct to
the best of my knowledge and nothing has
been concealed thereof.

Deponent
 IN THE LAHORE HIGH COURT LAHORE.

Writ Petition No. ______________ / 2024

In re:
Sajid Ahmed Khan
VS
Chief Election Commissioner etc.

INDEX

Sr. No. Description of Documents Date Page

1. Writ Petition 01.01.2024

2. Affidavit 01.01.2024

3. Power of Attorney

Petitioner

Through:

MUKHTAR RANJHA ASIF MEHMOOD CHEEMA

Advocate High Court Advocate Supreme Court

FARRUKH AMIN RANA IRFAN MEHMOOD RANJHA

Advocate High Court Advocate High Court

MOHSIN QAMAR RANA

Advocate High Court
Dated:01.01.2024