Writ Petition Lahore High Court (Sample)

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  • Topic: Pakistan, Rawalpindi District, Gujar Khan
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  • Published : September 5, 2012
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BEFORE THE LAHORE HIGH COURT RAWALPINDI BENCH, RAWALPINDI

Writ Petition No. __________/2012

1. Nasir Naveed son of Ali Akhtar resident of Village & Post Office Chakri Vakilan, Tehsil Gujar Khan, District Rawalpindi 2. Mrs. Saba Zameer previously Saba Afshan wife of Zameer Ahmed Qazi resident of Village & Post Office Jang Najar, Tehsil Gujar Khan, District Rawalpindi. 3. Salma Jabeen wife of Aqeel Ahmed resident of Village & Post Office Jang Najar, Tehsil Gujar Khan, Distt. Rawalpindi. 4. Rabia Mehmood Daughter of Mazhar Hussain resident of Kohl, Village & Post Office Jang Najar, Tehsil Gujar Khan, Dsitt. Rawalpindi. 5. Noreen Tariq wife of Tariq Javed resident of House No. 126, Ward No. 7, Hayat Sir Road, Gujar Khan, Distt. Rawalpindi.

(Petitioners)
VERSUS

1. Executive District Office (Education) Rawalpindi.
2. DCO Rawalpindi.
3. Best Way Foundation through its Chief Executive Officer Mr. Sayyed Mazhar Ali Shah, 29-M Floor, Beverly Center, Jinnah Avenue, Islamabad. 4. Government of the Punjab province through Chief Secretary (Respondents)

WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF THE ISLAMIC REPUBLIC OF PAKISTAN

__________________________________

Respectfully Sheweth!

1. That the petitioners are government servants and are serving in Education department Rawalpindi. That the respondent No. 1 with the collision of respondent No. 3 issued illegal and irregular transfer orders No. 5784/A-II dated 25.08.2012 and No. 5790/A-II dated 26.08.2012 and transferred the petitioners to various school running under the supervision and partial arrangements of respondent No. 3 in Union Council Thathi (تھاتھی), Tehsil Gujar Khan, District Rawalpindi. The petitioners became aggrieved of the orders and preferred to file this very Writ Petition to invoke the constitutional jurisdiction of this Honorbale Court finding no other efficacious remedy.

2. That as mentioned above on 25.08.2012 & 26.08.2012 the respondent No. 1 issued transfer orders upon the directions of the Chief Minister of Punjab Mr. Shabaz Sahreef for some political gains and reasons.

3. That the Respondent No. 3 and the respondents Nos. 1 & 2 have entered into an agreement which was notified through letter No. 5356 of 01.10.2005 issued by the respondent No. 1 and it was agreed between the parties that the respondent No. 3 shall facilitate the 27 governmental schools working in Union Council Thathi, Tehsil Gujar Khan. In reward the respondent No. 3 who actually belongs to and represents “Bestway Group of Companies”, were having some tax rebates and benefits etc. The respondent No. 3 is having a very influential position in the country and famous Lord Nazir Ahmed also belongs to this group. It has also been said that upon some pressure of the said Lord Nazir and respondent No. 3 the Chief Minister Punjab has directed the respondent No. 1 to issue the impugned orders.

4. That the impugned orders are arbitrary, illegal and against rules and regulations. Serious infringements of human rights have been caused to the petitioners and others by the impugned orders. These orders have been issued solely upon political basis to reward a specific area of Punjab. The impugned orders are good example of pre-pole rigging by the respondent No. 1 for the political gain of the Chief Minister Punjab.

5. That the impugned orders are issued without any prior announcement of any transfer policy etc. in a very hasty manner. Another policy under the title of “rationalization” is under progress in district Rawalpindi and the Punjab province but the respondent No. 1 did not consider that policy or any other policy. How an un-announced, hasty, illegal and irregular action could take place without any policy.

6. That the impugned orders have been issued in a hasty manner. Even the order No. 5790/A-II dated 26.08.2012 was issued on a holyday i.e. Sunday. What was the...
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