Office of the

AUDITOR GENERAL OF PAKISTAN

Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip Dated: .11.2015

CHARGE SHEET

WHEREAS, I, Ahmed Hussain, Deputy Auditor General (A&C)

Authorized Officer have decided to proceed against you under Rule 5 (1) (ii) of the
Government Servants (Efficiency & Discipline) Rules, 1973.
2. Whereas, I consider that in the light of facts of the case and in the
interest of justice, it is necessary to hold an inquiry against you through an Inquiry
Officer.
3. Whereas, you, Syed Taimoor Bukhari, Assistant Accountant General
(BPS-17), office of the Accountant General Punjab Lahore, failed to discharge your
duties efficiently and committed the following acts of omission/commission which
are tantamount to inefficiency, misconduct and corruption within the meaning of
Rule 3 (a) (b) & (c) of the Government Servant (E&D) Rules, 1973.

(i) You with the connivance of Mr. Zahhid Rasheed the then
Director General DAO’s (OPS) got yourself posted back
as Assistant Accountant General, whereas you already
had been surrendered on account of misconduct from the
office of Accountant General Punjab.
(ii) You obtained the possession of token punching machine
in complete disregard to standard operating procedures,
during the month of June, 2014.
(iii) You compelled your staff in Payroll-7 Section to process
the counterfeited bills without exercising proper pre-audit
checks which confirm your willful involvement in
processing the counterfeited bills in connivance with the
then Director General/Accountant General (on look after
basis).
 (iv) You were found to be in possession of fake stamps of the
vendors, in whose name the fake bills were got prepared
and processed. This further corroborates your active
involvement in the fraud.

(v) You collaborated with the team of private persons and

officials of Accountant General Punjab malafide deployed
by Mr. Zahhid Rasheed in order to create a rush and an
environment of fear in the office so as to get the things
done according to your whims.

4. And whereas, by reasons of above read with the details given in the
enclosed Statement of Allegations, you are liable to disciplinary action under the
Government Servants (E&D) Rules, 1973, which may include imposition of one or
more penalties including the major penalty of “Dismissal from Service” as
prescribed in Rule 4 of the said Rules.
6. Whereas, in pursuance of sub-rule (ii) of Rule 5 of the Government
Servants (E&D) Rules, 1973 Mr. Masood Akhtar Sherwanee, Deputy Military
Accountant General, BS-20 Officer of PA&AS has been appointed by the
undersigned as an Inquiry Officer, who will conduct the proceedings in this case
against you.
7. Now therefore, you are hereby required to submit your written
defence to the above charge sheet, within (14) days on its receipt to the above
named Inquiry Officer, failing which it shall be presumed that you have nothing to
say and action against you will be initiated ex-parte. In your written explanation to
this charge sheet, you should also state whether you desire to be heard in person
by the undersigned.

8. Statement of Allegations is enclosed.

 (Ahmad Hussain)
Deputy Auditor General
(A&C)
Authorized Officer

Syed Taimoor Bukhari,

Assistant Military Accountant General,
O/o Military Accountant General
Rawalpindi.

Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

Statement of Allegations

Syed Taimoor Bukhari, Assistant Accountant General, in the office of

Accountant General Punjab, Lahore, committed the following acts of

omission/commission:-

i. That you in connivance with Mr. Zahid Rasheed, Director General DAOs

(OPS) also holding the charge of Accountant General (on look after basis)

illegally, maneuvered to get yourself posted as Assistant Accountant General

(AAG) in the office of the Accountant General Punjab in June, 2014 despite

the fact that you were surrendered as AAG, by the then Accountant General

Punjab on account of misconduct in December 2013 (Annexure-A & B).

ii. That you obtained the possession of Token Punching Machine in complete

disregard of standard operating procedures during the month of June, 2014.

During the period that the Token Punching Machine remained in your
 custody, you used it for punching tokens on counterfeited/bogus bills

(Annexure- C, D, E, F, G & H).

iii. You being the officer in-charge compelled Mr. Jawad-ul-Qamer, Key Punch

Operator, Mr. Muhammad Shahbaz Qamer, Senior Auditor and Assistant

Accounts Officer viz Mr. Muhammad Arshad Iqbal of Payroll-7 Section to

process the counterfeited bills of “Sustainable Development of Walled City

Lahore Project” and cleared those bills without applying proper pre-audit

checks. You then forwarded those bills from the computer terminal in the

section hurriedly, without applying the prescribed pre-audit checks. After

clearing the bills in a swift manner and without applying proper pre-audit

checks, you recorded the following statement on the passed bills statement

“Necessary approval has been taken by the Director General/Accountant

General”. These action on your part confirm your willful involvement in

processing the counterfeited bills in connivance with the then Director

General/Accountant General Mr. Zahhid Rasheed

(Annexure- I, J, K, L, M, N & O).

iv. As per statements of the Mr. Jawad-ul-Qamer, Senior Auditor/Key Punch

Operator and Syed Shiraz Hussein, Naib Qasid, you were in possession of

the fake stamps, used on the bogus bills of the fake vendor, of the

Sustainable Development of the Walled City Project Lahore. The name of the

fake vendor was M/s Qavi Engineering (Annexure- I, O & P).

v. You operated through private armed persons and placed officials violating all

the prescribed standard operating procedures, created a rush and an

 environment of fear in order to clear bills in lieu of handsome bribes. You and

the private armed guards acted in connivance with the then ex-Accountant

General Punjab Mr. Zahhid Rasheed. (Annexure-Q).

2. By reasons of the above, Syed Taimoor Bukhari, Assistant Accountant

General, office of Accountant General Punjab, has rendered himself liable for

disciplinary action under the Government Servants (Efficiency & Discipline) Rules,

1973 which may include imposition of one or more penalties including major penalty

of “ Dismissal from Service”.

(Ahmad Hussain)
Deputy Auditor General
(A&C)
Authorized Officer

1/N

1. PUC is a letter received from O/o the CGA, Islamabad which may also please be
seen.

2. With reference to the remarks of DAG (A&C) at para 72/N of noting portion of
PA&AS Section file in respect of Syed Taimoor Bukhari, Assistant Accountant
General, a BS-17 PA&AS officer has been forwarded to legal section for taking
necessary action against him under the prescribed E&D Rules, 1973 which may
kindly be seen (F/A).

3. In the PUC, the O/o the CGA, Islamabad has forwarded request of Accountant
General Punjab to this office to initiate disciplinary proceedings against Syed
 Taimoor Bukhari, Assistant Accountant General, BS-17 PA&AS officer
alongwith statement of allegations and a draft of charge sheet due to misconducts
under Rule 5 of the Government Servants (Efficiency & Discipline) Rules, 1973 (F/B
& C).

4. Under Rule 5 of the Government Servants (Efficiency & Discipline) Rules, 1973 the
following procedure shall be observed when a Government servant is proceeded
against under these rules:–

(ii) The Authorized Officer shall decide whether in the light of facts of the case
or the interest of justice, an inquiry should be conducted through an Inquiry
Officer or Inquiry Committee. If he so decides, the procedure indicated in
rule 6 shall apply.

(iii) If the Authorized Officer decides, that it is not necessary to have an inquiry
conducted through an Inquiry Officer or Inquiry Committee, he shall:

(a) by order in writing, inform the accused of the action proposed to be

taken in regard to him and the grounds of the action; and

(b) give him a reasonable opportunity of showing cause against that

action: Provided that no such opportunity shall be given where the
authority is satisfied that in the interest of the security of Pakistan
or any part thereof it is not expedient to give such opportunity.

5. In view of above, it would be appropriate to initiate the disciplinary proceedings

against Syed Taimoor Bukhari, Assistant Accountant General, BS-17 PA&AS
officer under the provisions of the Government Servants (Efficiency & Disciplinary)
Rules, 1973 with the prior approval of the Deputy Auditor General (A&C) /
Authorized Officer please.

AAO (Legal-I)

AO (Legal-I)

10/N

25. With reference to approval at para 18/N accorded by the Auditor General of
Pakistan and to initiate the disciplinary proceedings under the provisions of the
Government Servants (Efficiency & Disciplinary) Rules, 1973 against Mr. Zahhid
Rasheed (a BS-19/PA&AS) ex-AG Punjab and Syed Taimoor Bukhari, (a BS-17/
PA&AS) ex-AAG O/o the AG Punjab, Lahore the two draft Charge Sheets
alongwith Statement of Allegations are submitted for approval and further orders
please.

AAO (Legal-I)

AO (Legal-I)

Office of the
 AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip Dated: .11.2015

ORDER

In pursuance of Rule-5(I) (ii) of the Government Servants (Efficiency &

Discipline) Rules, 1973 Mr. Masood Akhtar Sherwanee, Deputy Military
Accountant General, BS-20 Officer of PA&AS is hereby appointed to be the
Inquiry Officer to conduct the proceedings against Syed Taimoor Bukhari, a BS-
17/PA&AS, while posted as Ex-Assistant Accountant General, in the office of
Accountant General Punjab, Lahore, in Charge Sheet No.____ Dir (A)/11-
321/Discip dated .11.2015.

2. The inquiry shall be conducted on day to day basis in accordance with

the provisions contained in the Government Servants (Efficiency & Discipline)
Rules, 1973, and instructions issued from time to time. The inquiry report should be
submitted within 10 days of the conclusion of the proceedings.

(Ahmad Hussain)
Deputy Auditor General
(A&C)
Authorized Officer

Syed Taimoor Bukhari,

Assistant Military Accountant General,
O/o Military Accountant General
Rawalpindi.
 ONE PAGE BRIEF OF THE CASE AGAINST SYED TAIMOOR BUKHARI,
EX-ASSISTANT ACCOUNTANT GENERAL, BS-17 PA&AS

O/o the CGA, Islamabad has forwarded request of Accountant General

Punjab to this office to initiate disciplinary proceedings against Syed Taimoor
Bukhari, Assistant Accountant General, BS-17 PA&AS officer along with
statement of allegations and a draft of charge sheet due to misconducts under
Rule 5 of the Government Servants (Efficiency & Discipline) Rules, 1973.

A Charge Sheet has been issued dated 05.11.2015 to the accused officer
(presently under suspension) and Mr. Masood Akhtar Sherwani, Dy.MAG has been
appointed as Inquiry Officer to conduct the proceedings against the officer vide order
dated 05.11.2015. Charge Sheet has been received back on 16.11.2015 un-delivered
due to non-availability of the accused on his address and again dispatched on
25.11.2015 and the same has been received by the accused. Afterwards the accused
sent his request that he has not received the charge sheet and order of inquiry and
provided a new address and a photocopy of the same material has again been
dispatched through TCS on provided new address on 30.12.2015 which has been
delivered to him. The accused officer has submitted his defence reply to the charges
leveled against him to the Inquiry Officer on 11.01.2016 accordingly. The inquiry report is
awaited.
INQUIRY REPORT IN CHARGE SHEET CASE OF MR. TAIMOOR BUKHARI, B-17
PAAS OFFICER

Charge as per para 3(i) of charge sheet

Para 3(i) of charge sheet:

You with the connivance of Mr. Zahhid Rasheed the then Director General DAO’s (OPS)
got yourself posted back as Assistant Accountant General, whereas you already had been
surrendered on account of misconduct from the office of Accountant General Punjab.

Facts:
a. During his first tenure of posting in AG Punjab Lahore upto 28-01-2014,Mr. Taimoor
Bukhari was in charge of DAO’s Coord Cell, besides other sections. He was on
probation period then.
b. The Reporting Officer was DG Accounts (Mr. Zahhid Rasheed), under the then AG
(Mr. Idrees Tarar)
c. On 31-12-2013, Mr. Idrees Tarar AG Punjab wrote a letter to Dir Admin AGP office,
signed by the AG himself, requesting posting of Mr. Taimoor Bukhari out of AG
Punjab immediately on the grounds mentioned in the said letter.(Annexure-A)
d. Mr. Taimoor Bukhari AAG was accordingly posted out of AG Punjab by the AGP
office on 28-01-2014.(Annexure-B)
e. The order of transfer issued by the AGP office on 28-01-2014 did not give any
reason for the transfer of the officer (Mr. Taimoor Bukhari).
 f. On 22-05-2014, Mr. Idrees Tarar was replaced by Mr Zahhid Rasheed as
AG.(Annexure-C)
g. On 03-06-2014, Mr. Taimoor Bukhari was again posted back as Assistant AG in AG
Punjab.(Annexure-D)
h. In the intervening period, i.e between 28-01-2014 and 03-06-2014, probation
period of the officer was terminated.

Findings:
a. Letter written by Mr. Idrees Tarar as AG Punjab to Dir. Admin AGP office on 31-02-
2013 was “confidential”. (Annexure-A)
b. AGP’s transfer orders in regard to Mr. Taimoor Bukhari, dated: 28-01-2014 and03-
06-2014, did not mention ground of posting.(Annexure-E)
c. Questionnaire regarding background of posting of Mr. Taimoor Bukhari again into
AG Punjab on 03-06-2014 was sent by the inquiry officer to the present and
previous Dir. Admin. The same are still un-responded.
Opinion:
a. The Charge Sheet mentions the cause of surrender of the officer out of AG Punjab
by Mr. Idrees Tarar AG Punjab, as misconduct. Evidently, this charge was not
communicated to the accused officer before this charge sheet. Therefore, the
accused has responded that he has no knowledge about his surrender in January
2014 by the then AG as a cause of his transfer out of AG Punjab.
b. It is viewed that the choice of words made by Mr. Idrees Tarar in his letter dated:
31-12-2013(Annexure-A) clearly indicates the AG’s uneasiness in regard to officer’s
style of working under the then DG Accounts who was the overall in charge of
DAOs. The latter happenings in AG Punjab during the month of June and the acts of
utter faithfulness exhibited by Mr. Taimoor Bukhari to Mr. Zahhid Rasheed as AG
Punjab, however do provide a semblance of his possible connivance with Mr.
Zahhid Rasheed for his reposting, but cannot be proved through evidence, unless
the former Dir. Admin disclose it.
Charge as per para 3(ii) of charge sheet

Para 3(ii) of charge sheet:

You obtained the possession of token punching machine in complete disregard to

standard operating procedure, during the month of June, 2014.

Facts:
a. Token punching machine is held in the charge of cheque section.
b. SOPs are available in this regard.
c. On 16-06-2014 AO Cheque issued a certificate regarding last cheque punched by his
section.(Annexure-F)
d. The section incharge stated before the inquiry officer that the charge of the
machine was handed over by the cheque section on verbal orders of the AG
conveyed to the cheque section through Mr. Taimoor Bukhari.(Annexure-G)
Findings:
a. Thousands of tokens were punched after 16-06-2014 in the office of AG Punjab by
the same token machine. These bills were entertained by various sections just like
routine / normal bills. However, the machine was now under the direct influence of
one of the outsiders installed by the then AG in cheque section, namely Mr.
Shakeel.(Annexure-H)
b. As per statements of cheque section, they handed over charge of the machine on
AG’s orders conveyed verbally by Mr. Taimoor Bukhari. (Annexure-I)
Opinion:
a. The statements of officers and officials indicate that the AG’s orders regarding shift
of possession of the token punching machine w.e.f 16-06-2014 was verbally
conveyed through Mr. Taimoor Bukhari, otherwise these would not have gained
enough strength for the cheque section to follow the same. These statements do
not indicate that the orders came directly from the AG but do indicate via media of
Mr. Taimoor Bukhari .It is viewed that in order to possess full control over the bills
 to be punched after 16-06-2014, the influence of the cronies of theAG over the
token machine was necessary and possibly it was got done by the AG through Mr.
Taimoor Bukhari. It however does not verify that the machine was in physical
possession of the accused officer.
b. Some level of control over the machine in last days of June by the administration is
usual but control of an outside agent of the AG in June 2014 is unusual.
 Charge as per para 3(iii) of charge sheet

Para 3(iii) of charge sheet:

You compelled your staff in Payroll-7 Section to process the counterfeited bills without
exercising proper pre-audit checks which confirm your willful involvement in processing
the counterfeited bills in connivance with the then Director General / Accountant
General (on look after basis).

Facts:
a. The following bills were punched in the system in the last week of June 2014 by the
payroll-7 section of the AG Punjab:(Annexure-J)

Bill Tracking Report

03-02-2016
Token No Token Date Section Cost Center Token Amount Document No Park By Park date Level 1 Date Level 2 Level 2 Date Level 3 Level 3 date No of Posted Date Token By
Name bills
189240 25-6-2014 Payroll 07 LZ4116 16,956,464 5105676957 AHMADM 26-6-14 26-6-14 ARSHADI 26-6-14 TAIMOORSYED 26-6-14 1 26-6-14 SAJJADSHAH

Bill Tracking Report

03-02-2016
Token No Token Date Section Cost Center Token Amount Document No Park By Park date Level 1 Date Level 2 Level 2 Date Level 3 Level 3 date No of Posted Date Token By
Name bills
189241 25-6-2014 Payroll 07 LZ4116 38,000,443 5105676915 AHMADM 26-6-14 26-6-14 ARSHADI 26-6-14 TAIMOORSYED 26-6-14 1 26-6-14 SAJJADSHAH

Bill Tracking Report

03-02-2016
Token No Token Date Section Cost Center Token Amount Document No Park By Park date Level 1 Date Level 2 Level 2 Date Level 3 Level 3 date No of Posted Date Token By
Name bills
189242 25-6-2014 Payroll 07 LZ4116 10,961,028 5105676956 AHMADM 26-6-14 26-6-14 ARSHADI 26-6-14 TAIMOORSYED 26-6-14 1 26-6-14 SAJJADSHAH

Bill Tracking Report

03-02-2016
Token No Token Date Section Cost Center Token Amount Document No Park By Park date Level 1 Date Level 2 Level 2 Date Level 3 Level 3 date No of Posted Date Token By
Name bills
189243 25-6-2014 Payroll 07 LZ4116 26,579,674 5105676914 AHMADM 26-6-14 26-6-14 ARSHADI 26-6-14 TAIMOORSYED 26-6-14 1 26-6-14 SAJJADSHAH
 b. Both the AAO and Assistant AG as in charge of Payroll-7 were posted only a few
days ago.(Annexure-K)

Findings:
a. The record of SAP system shows that all the four bills crossed the three levels
(Level-1, level-2 and level-3) within 24 minutes late at night at around 2200 hrs on
26-06-2014. (Annexure-L)
b. Both the AAO and Auditor claim that the bills were handed over to them by Mr.
Taimoor Bukhari. Mr. Taimoor Bukhari denies. Incidentally the SAP record shows
that the token number was punched by Mr. Sajjad Shah on 26-06-2014 on each of
these 4 bills.
c. Interestingly, Mr. Sajjad Shah is the regular charge holder of the punching
machine.(Annexure-M)
d. At the time of generation of document numbers in payroll-7, it had been known
that the fifth bill of the same nature could not be accepted by the system due to
non availability of budget. Hence the same was not processed.
e. The statements of the AAO and the Senior Auditor reflect that they applied pre-
audit checks on all the four bills but under the duress of urgency from the Assistant
AG. The Assistant AG denies it.(Annexure-N)
f. After the bills were passed there was a usual need to convey an authorization from
the AG about forwarding of these bills to the cheque section. The same was
conveyed by Mr. Taimoor Bukhari Assistant AG.(Annexure-O)
g. There is nothing on the record to show that these bills were formally signed by the
AG as per requirement of the office order dated: 26-05-2014 whereby all bills of the
value beyond five million were to be approved by the DG.(Annexure-P)
h. The signature of the DDO did not match but the payroll-7 section could not detect
it. Accordingly they relied on fake documents to admit the bills for payment. They
overlooked the following pre-audit requirements either intentionally or due to lack
of experience:-(Annexure-Q)
 i. Recommendation by the Consultant firm M/s ACE (Pvt.) Ltd. For
processing of contractor’s bill
ii. The signatures of the DDO are forged
iii. The sequence of IPC Nos. is incorrect
iv. The Letter Head in the forged document is without the WCLA watermark
logo
v. Difference in font and size of the print
vi. WCLA vouchers numbers and amount to the forged bills are incorrect
vii. The relevant documents that show the civil works items are missing

i. The Senior Auditor, AAO and Assistant AG signed all the bills and punched in the
system using their own User IDs.
j. The cheque was issued and credited into fake bank account until got reversed by
the next AG after 27-06-2014.
k. When the change of AG was taking place on 27-06-2014 under pressure from the
employees / Police, paid vouchers of these four bills were on the table of the AG as
reported in the statements of Senior Auditor / AAO of payroll-7 to this inquiry
officer as well as in other inquiry reports. In fact, some of the documents from the
bills were in the drawer of the AG’s table and recovered from there almost instantly
after forceful exit of Mr. Zahhid Rasheed from the Chamber of the AG on 27-06-
2014 after commotion.
Opinion:
a. The chain of events ranging from punching of token on these four fake bills of the
“Walled City Project” to the physical presence of these paid vouchers in the AG’s
Chamber proves a nexus of common interest between all those who processed,
possessed and sought for the same. However, what surprises is a common
experience that usually the culprits of such wrong doing (Passing a fake bill) either
do not paste their original signature on fake bills or vanish the same immediately
after issue of cheque to remove any evidence of their wrong doing. This has not
 happened. All the concerned officers of Payroll-7 have signed the bills. They have
entered them into system using their own ID. The AAO created an alarm at the time
of commotion (which took place in the chamber of the AG on 27-06-2014 resulting
in change of command of AG) by informing the Additional AG and the new AG
about the possibility of something fishy about these bills, emanating from presence
of their paid vouchers on the AG’s table.
b. While the AAO and the Auditor remained in the office taking possession of these
vouchers and possibly questioning genuineness of the bills (and verifying the same
on following day), Mr. Taimoor Bukhari did not bother to come to the AG office
after the commotion and change of command. In his statement to the inquiry
officer, he claims that he did not do that due to perceived threat to his
life.(Annexure-R)
c. It is obvious that pre audit checks were not exercised at any level. The section
should have been conscious that both the AAO and Assistant AG were just recently
posted in the section and therefore lacked experience of the work of the section.
They should have applied substantive checks before admitting the claims.
d. There are various possibilities;
I. Mr. Taimoor Bukhari knew that the bills were fake and yet processed them.
II. He got them processed expeditiously due to lack of experience because he
did not know what checks to be applied.
III. He got the bills processed to appease the AG and to show his utter
faithfulness without realizing about nature of bills.
IV. He authorized the bill on behalf of AG on the trust that he would sign the
same.
V. He was confident that either the wrong payment would not be detected and
even if detected the vouchers would not be found to fix responsibility.

e. Only detailed forensic expertise can decide which one of the above possibilities is
true. However, the documentary soft and hard evidence prove that Mr. Taimoor
 Bukhari successfully persuaded Payroll-7 section to process the fake bills in a space
of just 24 minutes either out of his own interest to get things done or to show
compliance to the AG who had circumstantially obliged him by maneuvering his
posting back to AG Punjab after the disgraceful surrender by the Ex-AG.
f. Mr. Taimoor Bukhari could claim a benefit of doubt on account of lack of
experience, but is ineligible on account of his blind compliance to the system
installed by the then AG which allowed such fake bills, as of Walled City Project, to
find easy access to the Government’s wallet unhindered and unhurdled.
Charge as per para 3(iv) of charge sheet

Para 3(iv) of charge sheet:

You were found to be in possession of fake stamps of the vendors, in whose name the
fake bills were got prepared and processed. This further corroborates your active
involvement in fraud.
Facts:
a. The Senior Auditor Payroll-7 and Naib Qasid of Mr. Taimoor Bukhari reported that
the stamp of M/S Qavi Engineers was noticed from the room of Mr. Taimoor
Bukhari on 27-06-2014 almost at the same time when commotion was taking place
in AG’s Chamber.(Annexure-S)
b. Mr. Taimoor Bukhari went away from the AG office at the time of commotion and
did not return thereafter.
c. His room was locked and was later opened in his absence. The fake stamp was
reportedly recovered from the room.(Annexure-T)
Findings:
a. Mr. Taimoor Bukhari disowns possession of any stamp. It is obvious that before
leaving the AG office at the time of commotion he could have removed anything
from his office without knowledge of any one because everyone was focused at the
mob activity on the ground floor.
b. Mr. Taimoor Bukhari’s room was upstairs.He even left his cheque book behind
before leaving.
Opinion:
a. The first report about the presence of the fake stamp came from the Senior Auditor
(Mr. Jawwad)of Payroll-7 section who had documented these four bills in the
system. The other Senior Auditor (Mr. Shehbaz) teamed up with AAO who created
an alarm to the Additional AG/ new AG about paid vouchers of Walled City Project
Bills after the commotion and change of command. Interestingly, the same AAO
 played a vital role in verifying these bills as fake from the Project Office on 28-06-
2014 resulting in eventual recovery from the Allied Bank of Pakistan. When asked
from the Senior Auditor (Mr. Jawwad)by the inquiry officer as to why he had gone
to Mr. Taimoor Bukhari’s room precisely at the time of commotion at ground floor,
he replied that he had been offered cold water from the dispenser stationed in the
locked office of Mr. Taimoor Bukhari upstairs by his Niab Qasid from whom he had
requested a glass of water, when standing on ground floor. He added that while he
was having water in Mr. Taimoor Bukhari’s room, he noticed a stamp on the table
of Mr. Taimoor Bukhari which later came to be found as fake.
b. It is considered that the Senior Auditor has concocted a story of fake stamp
presence in Mr. Taimoor Bukhari’s room because of the following:

i. There was no point for the Senior Auditor to go to Mr. Bukhari’s room at the
heat of the moment of commotion when he was already concerned about
the Walled City vouchers.
ii. The same AAO who created an alarm about the vouchers of fake claims on
27-06-2014 also reported about the fake stamp.
iii. Going upstairs merely for water in a locked room appears to be farfetched.
iv. Recovery of same stamp has been mentioned by the CGA in her letter to
NAB dated: 01-07-2014 as having been found from the Chamber of the AG.
(Annexure-U)
v. Mr. Taimoor Bukhari could have easily removed the stamp before running
away from AG office on 27-06-2014 at the time of commotion.
Charge as per para 3(v) of charge sheet

Para 3(v) of charge sheet:

You collaborated with the team of private persons and officials of Accountant General
Punjab malafide deployed by Mr. Zahhid Rasheed in order to create a rush and an
environment of fear in the office so as to get the things done accordingly to your whims.
Facts:
a. Ever since Mr. Zahhid Rasheed took over the charge as AG (Punjab) on 22-05-2014,
he employed various tactics to strengthen his control over the office and one of
those was deployment of several guards / private persons in various sections to
watch and monitor swift implementation of his commands.(Annexure-V)
b. These guards / persons might also be armed as evident from the statement of an
official of AG Punjab. (Annexure-W).
c. These guards / persons also occupied the Rest House in AG’s office premises.
Findings:

a. Mr.Taimoor Bukhari was in charge of Admin Section. (Annexure-X)

b. The AG office was conscious of the relationship of Mr. Taimoor Bukhari with Mr.
Zahhid Rasheed from the day when Mr. Taimoor Bukhari was in charge of DAOs
Coord cell under DG Accounts because of which he was surrendered by Mr. Idrees
Tarar the Ex-AG.
c. Any command of the AG communicated by Mr. Taimoor Bukhari even verbally was
taken seriously by the officials as evident from the handover of token punching
machine by cheque section on 16-06-2014 on verbal command.
d. Free movement of private persons and guards and its negative effect on the office
should have been a concern for the admin section.
e. The creation of environment of fear due to presence of guards and private persons
is reflected in the events which took place during the six week tenure of Mr. Zahid
Rasheed as AG Punjab, such as:-
 i. All Accounts Officers of AG Punjab applied for leave to the AG.(Annexure-Y)
ii. Sudden mob activity /commotion on 27-06-2014.
iii. Presence of Police at the time of commotion
iv. Departure of the AG under police protection after the employees reportedly
threatened to physically assault him during commotion.
v. Occupation of rest house and DG’s office by these persons.

Opinion:
a. The manner in which Mr. Taimoor Bukhari joined AG Punjab, attained the charge of
important sections, conveyed the command of the AG, facilitated the handover of
the punching machine, persuaded payroll-7 to pass the bills of M/S Qavi
Engineering in the presence of private guard, his sudden disappearance from the
office of AG Punjab during commotion, his choice not to attend the office after
joining of new AG, his perception of life threat etc. provide sufficient circumstantial
evidence that Mr. Tamoor Bukhari facilitated Mr. Zahhid Rasheed in creating an
environment in AG Punjab in June 2014 which was conducive to his (Mr. Zahhid
Rasheed) interests and motives as reflected in passage of four fake bills of Rs. 104
million and possible attempt of clearance of 19 bills of Rs. 383 million.

Concluding Remarks:

Mr. Taimoor Bukhari was surrendered by the AG when he was on probation. He

joined back after the AG who surrendered him had been replaced.With such short
experience of working in AG Punjab, he was not expected to be at the center of such a
mess in June 2014 which brought the highly respected organization of AG Punjab to open
disrepute. In deed out of his free will, he allowed himself to be used as a pawn by the
others for their own larger interest at the cost of his career and reputation. Borrowing
words from Mr. Idrees Tarar, it was unbecoming of a PA&AS officer. He deserves a
psychological make over under a professional mentor.
 List of Enclosures
S.No Annexure Page No.

1 Annexure-A 15
2 Annexure- B 17
3 Annexure- C 20
4 Annexure- D 22
5 Annexure- E 24
6 Annexure- F 27
7 Annexure- G 29
8 Annexure- H 32
9 Annexure- I 35
10 Annexure- J 40
11 Annexure- K 42
12 Annexure- L 45
13 Annexure- M 52
14 Annexure- N 54
15 Annexure- O 64
16 Annexure- P 66
17 Annexure- Q 68
18 Annexure- R 73
19 Annexure- S 83
20 Annexure- T 87
21 Annexure- U 91
22 Annexure- V 94
23 Annexure- W 99
24 Annexure- X 105
25 Annexure- Y 107
26 Annexure- Z 108
Inquiry Report
 CONFIDENTIAL

OFFICE OF THE
MILITARY CCOUNTANT GENERAL
Kashmir Road, Rawalpindi Cantt.

No. /DMAG/Misc/01 Dated: -05-2016

To

Rana Shakeel Asghar

Director (Legal),
AGP Office
Constitution Avenue,
Islamabad

Subject: ORDER / CHARGE SHEET / STATEMENT OF ALLEGATIONS IN CASE OF

TAIMOOR BUKHARI , B-17/ PA&AS OFFICER.

Reference: Your letter No. 05-Dir (A)/II-321 Discip, dated: 14-04-2016.

Inquiry report in case of Mr. Taimoor Bukhari, B-17 PA&AS officer as per
Charge Sheet No. 391-Dir (A)/11-321-Discip, dated: 05-11-2015 has been submitted to the
Authorized Officer.

(Masood Sherwani)
Deputy Military Accountant General
 CONFIDENTIAL

OFFICE OF THE
MILITARY CCOUNTANT GENERAL
Kashmir Road, Rawalpindi Cantt.

No. /DMAG/Misc/01 Dated: -05-2016

To

Mr. Ahmed Hussain

Deputy Auditor General (A&C)
Office of the Auditor General of Pakistan
Constitution Avenue,
Islamabad

Subject: CHARGE SHEET – TAIMOOR BUKHARI , B-17/ PA&AS OFFICER.

Reference: Charge Sheet No. 391-Dir (A)/11-321-Discip, dated: 05-11-2015.

Kindly find enclosed Inquiry Report in the subject case in your capacity as
Authorized Officer.

(Masood Sherwani)
Deputy Military Accountant General
 STATEMENT SHOWING JUXTA POSITION IN RESPECT OF DISCIPLINARY CASE AGAINST SYED TAIMOOR BUKHARI EX-ASSISTANT AG, AG PUNJAB (BS-19)
Sr.
No. Charge
1. Para 3(i) of charge sheet:
You with the connivance of Mr.
Zahhid Rasheed the then
Director General DAO’s (OPS)
got yourself posted back as
Assistant Accountant General,
whereas you already had been
surrendered on account of
misconduct from the office of
Accountant General Punjab.
PA&AS OFFICER
Fact
a. During his first tenure of posting
in AG Punjab Lahore upto 28-
01-2014, Mr. Taimoor
Bukhari was in charge of DAO’s
Coord Cell, besides other
sections. He was on probation
period then.
b. The Reporting Officer was DG
Accounts (Mr. Zahhid Rasheed),
under the then AG (Mr. Idrees
Tarar)
c. On 31-12-2013, Mr. Idrees
Tarar AG Punjab wrote a letter
to Dir Admin AGP office, signed
by the AG himself, requesting
posting of Mr. Taimoor Bukhari
out of AG Punjab immediately
on the grounds mentioned in the
said letter. (Annexure-A)
d. Mr. Taimoor Bukhari AAG was
accordingly posted out of AG
Punjab by the AGP office on 28-
01-2014. (Annexure-B)
e. The order of transfer issued by
the AGP office on 28-01-2014
did not give any reason for the
transfer of the officer (Mr.
Taimoor Bukhari).
f. On 22-05-2014, Mr. Idrees
Tarar was replaced by Mr.
Zahhid Rasheed as AG.
(Annexure-C)
g. On 03-06-2014, Mr. Taimoor
Bukhari was again posted back
as Assistant AG in AG Punjab.
(Annexure-D)
h. In the intervening period, i.e
between 28-01-2014 and 03-06-
2014, probation period of the
officer was terminated.
Finding
a. Letter written by Mr. a.
Idrees Tarar as AG
Punjab to Dir. Admin AGP
office on 31-02-
2013 was “confidential”.
(Annexure-A)
b. AGP’s transfer orders in
regard to Mr. Taimoor
Bukhari, dated: 28-01-
2014 and 03-06-2014,
did not mention ground of
posting. (Annexure-E)
c. Questionnaire regarding
background of posting of
Mr. Taimoor Bukhari
again into AG Punjab on
03-06-2014 was sent by
the inquiry officer to the
present and previous Dir.
Admin. The same are still b.
un-responded.
Accused Reply to Show
Opinion Remarks
Cause Notice
The Charge Sheet Charge (i) and Charge (iv)
mentions the cause of were clearly held by the inquiry Charge has not
surrender of the officer officer to have not been been proved.
out of AG Punjab by proved. As far as charges (ii),
Mr. Idrees Tarar AG (iii) and (v) are concerned, the The charge
Punjab, as misconduct. necessary corollary thereof, appears to be
Evidently, this charge there charges were also not proved by
was not communicated proved. Submissions in circumstantially
to the accused officer respect of charges (ii), (iii) and however, can not
before this charge (v) are also briefly being made be proved through
sheet. Therefore, the in this reply. evidence unless
accused has the former Director
responded that he has The important feature of the Admn discloses it.
no knowledge about inquiry report is that a number
his surrender in of extraneous factors to the
January 2014 by the charge sheet have been taken
then AG as a cause of into consideration by the
his transfer out of AG Inquiry officer and the
Punjab. conclusion have been drawn
It is viewed that the with observations which never
choice of words made part of the charge sheet and
by Mr. Idrees Tarar in were beyond the scope of the
his letter dated: 31-12- inquiry because at no stage
2013 (Annexure-A) the undersigned had an
clearly indicates the opportunity to rebut those.
AG’s uneasiness in Reliance is respectfully placed
regard to officer’s style on Government of Pakistan
of working under the Vs. Farheen Rasheed (2011
then DG Accounts who SCMR 1) in which a civil
was the overall in servant was dismissed on the
charge of DAOs. The allegation which was not part
latter happenings in AG of the charge sheet and
Punjab during the Fayyaz Muhammad Vs.
month of June and the Deputy Inspector General of
acts of utter Police Bahawalpur Range,
faithfulness exhibited Bahawalpur and another {1973
by Mr. Taimoor Bukhari PLC (CS) 361} in which
to Mr. Zahhid Rasheed instead of proof of charge a
as AG Punjab, civil servant was punished on
however do provide a extraneous considerations and
semblance of his the Service Tribunal interfered
possible connivance in both the matters.
with Mr. Zahhid
Rasheed for his

2. Para 3(ii) of charge sheet:
You obtained the possession
of token punching machine in
complete disregard to standard
operating procedure, during
the month of June, 2014.
a. Token punching machine is held
in the charge of cheque section.
b. SOPs are available in this
regard.
c. On 16-06-2014 AO Cheque
issued a certificate regarding
last cheque punched by his
section. (Annexure-F)
d. The section incharge stated
before the inquiry officer that the
charge of the machine was
handed over by the cheque
section on verbal orders of the
AG conveyed to the cheque
section through Mr. Taimoor
Bukhari. (Annexure-G)
a. Thousands of tokens a.
were punched after 16-
06-2014 in the office of
AG Punjab by the same
token machine. These
bills were entertained by
various sections just like
routine / normal bills.
However, the machine
was now under the direct
influence of one of the
outsiders installed by the
then AG in cheque
section, namely Mr.
Shakeel. (Annexure-H)
b. As per statements of
cheque section, they
handed over charge of
the machine on AG’s
orders conveyed verbally
by Mr. Taimoor Bukhari.
(Annexure-I)
b.
reposting, but cannot
be proved through
evidence, unless the
former Dir. Admin
disclose it.
The statements of Obtaining possession of
officers and officials token punch machine Charge proved.
indicate that the AG’s
orders regarding shift As far the law laid down by the
of possession of the Superior Courts and the
token punching Service Tribunal the charge
machine w.e.f 16-06- had to be proved and not an
2014 was verbally allegation which was not part
conveyed through Mr. of the charge sheet. The
Taimoor Bukhari, finding of the inquiry officer
otherwise these would was that:-
not have gained
enough strength for the “The punching machine was
cheque section to under the direct influence of
follow the same. These the outsider namely Shakeel
statements do not Ahmad, installed by the AG”.
indicate that the orders
came directly from the According to bill tracking report
AG but do indicate via (BTR) Mr. Sajjad Shah had
media of Mr. Taimoor punched the token. The only
Bukhari .It is viewed evidence to support this
that in order to possess charge comes from Mian
full control over the bills Ahmad Saeed, the AO,
to be punched after 16- Cheque Section.
06-2014, the influence
of the cronies of the According to him (AO, Cheque
AG over the token Section) the machine was
machine was handed over to Rana Shakeel
necessary and possibly on the verbal orders of the
it was got done by the then Accountant General
AG through Mr. conveyed by undersigned.
Taimoor Bukhari. It However, while appearing
however does not before the Investigating Officer
verify that the machine of the NAB, he took a different
was in physical position and stated that the
possession of the undersigned conveyed the
accused officer. order of the Accountant
Some level of control General through Muzaffar
over the machine in shah to handover the machine
last days of June by to the concerned authority and
the administration is incidentally he (AO, Cheque
usual but control of an Section), himself was
outside agent of the concerned authority. This
AG in June 2014 is contradiction makes the to
 unusual. statements as mutually
destructive. However, one
thing which is positively
established is that at no stage
the token machine was ever in
possession of the undersigned
as alleged n the charge.

The inquiry officer clearly

found that the machine was
not in physical passion of the
accused and also found that
“Some level of control of the
machine in the last days of
June by the administration is
usual but control of an outside
agent of the AG in June, 2014
is usual”.

Sajjad Shah, who punched the

token clearly admitted that it
was Mr. Shakeel a private
person representing the then
AG at whose asking he had
punched the four bills.

The charge is not supported by

any evidence and the ultimate
finding of the Inquiry Officer is
that “It however, does not
verify that the machine was in
physical possession of the
accused officer”

with the result that this charge

was also not proved.
(underlined to supply
emphasis)
3. Para 3(iii) of charge sheet: a. The following bills were a. The record of SAP a. The chain of events Charge (iii)
punched in the system in the system shows that all the ranging from punching Charge proved.
You compelled your staff in last week of June 2014 by the four bills crossed the of token on these four You compelled your staff in
Payroll-7 Section to process payroll-7 section of the AG three levels (Level-1, fake bills of the “Walled Payroll-7 Section to process
the counterfeited bills without Punjab: (Annexure-J) level-2 and level-3) within City Project” to the the counterfeited bills
exercising proper pre-audit 24 minutes late at night at physical presence of without exercising proper
checks which confirm your Bill Tracking Report around 2200 hrs on 26- these paid vouchers in pre-audit checks which
willful involvement in 03-02-2016 06-2014. (Annexure-L) the AG’s Chamber confirm your willful
processing the counterfeited b. Both the AAO and Auditor proves a nexus of involvement in processing
bills in connivance with the Toke Token Section Cost Token Document claim
Park that
By the
Parkbills were
Level 1 Level 2 common
Level 2 Level 3the Nocounterfeited
Level 3 interest of Posted billsBy in
Token
n No Date Name Center Amount No date Date Date date bills Date
then Director General / 1892 25-6- Payroll LZ4116 16,956,4 51056769
handed
AHMAD
over to them
26-6-14
by
26-6-14 ARSHA
between
26-6-14
all those
TAIMOORS
who
26-6-14
connivance
1
with
26-6-14
the
SAJJADS
then
Accountant General (on look 40 2014 07 64 57 Mr.MTaimoor Bukhari. Mr. DI processed, YED possessed Director General
HAH /
after basis). Taimoor Bukhari denies. and sought for the Accountant General (on look
Bill Tracking Report Incidentally the SAP same. However, what after basis).
03-02-2016 record shows that the surprises is a common
token number was experience that usually a) As far the charge as
Toke Token Section Cost Token Document punched
Park By by Park
Mr. Sajjad
Level 1 Level 2 the
Level 2culprits
Level 3 of such Level 3 framed
No of is concerned,
Posted Token Bythe
n No Date Name Center Amount No date Date Date date bills Date
1892 25-6- Payroll LZ4116 38,000,4 51056769
ShahAHMAD
on 26-06-2014
26-6-14
on
26-6-14 ARSHA
wrong
26-6-14
doing (Passing
TAIMOORS
a
26-6-14 1
Inquiry officer
26-6-14
has found
SAJJADS
41 2014 07 43 15 eachM of these 4 bills. DI fake bill) YED
either do not it disproved. Instead,
HAH the
c. Interestingly, Mr. Sajjad paste their original operative finding is that
Bill Tracking Report Shah is the regular signature on fake bills the undersigned
03-02-2016 charge holder of the or vanish the same “successfully persuaded
punching machine. immediately after issue Payroll-7 Section to
Toke Token Section Cost Token Document (Annexure-M)
Park By Park Level 1 Level 2 of cheque
Level 2 Levelto3 remove Level 3 process
No of fake Token
Posted bill inBy a
n No Date Name Center Amount No d. At the time of date Date
generation Date evidence of their
any date bills
space Dateof 24 minutes
1892 25-6- Payroll LZ4116 10,961,0 51056769 AHMAD 26-6-14 26-6-14 ARSHA 26-6-14 TAIMOORS 26-6-14 1
42 2014 07 28 56 of Mdocument numbers in DI wrong doing.
YED This has either 26-6-14
out of SAJJADS
his own
HAH
payroll-7, it had been not happened. All the interest to get things
Bill Tracking Report known that the fifth bill of concerned officers of done or to show
03-02-2016 the same nature could not Payroll-7 have signed compliance of AG…..”.
be accepted by the the bills. They have there is no clear finding
Toke Token Section Cost Token Document system
Park By duePark to non-
Level 1 Level 2 entered
Level 2 them
Level 3 into
Level 3 except
No of probabilities.
Posted Token By
n No Date Name Center Amount No availability dateof budget.Date system
Date using their own date b) bills
Mr. Jawad
Date Qamar the
1892 25-6- Payroll LZ4116 26,579,6 51056769 AHMAD
Hence 26-6-14was26-6-14
the same not ARSHA 26-6-14
ID. The TAIMOORS
AAO created 26-6-14 1KPO 26-6-14
who is SAJJADS
not an
43 2014 07 74 14 M DI YED HAH
processed. an alarm at the time of accused has also been
e. The statements of the commotion (which took examined. He falsely
b. Both the AAO and Assistant AG
AAO and the Senior place in the chamber of stated that the
as in charge of Payroll-7 were
Auditor reflect that they the AG on 27-06-2014 undersigned handed
posted only a few days ago.
applied pre-audit checks resulting in change of over to him five bills. So
(Annexure-K)
on all the four bills but command of AG) by far recovery of stamp is
under the duress of informing the Additional concerned; the Inquiry
urgency from the AG and the new AG Officer disbelieved his
Assistant AG. The about the possibility of statement. He has not
Assistant AG denies it. something fishy about been proved to be liar of
(Annexure-N) these bills, emanating this own showing.
f. After the bills were from presence of their c) The finding of persuasion
passed there was a usual paid vouchers on the does not amount to
need to convey an AG’s table. compelling the
authorization from the AG b. While the AAO and the concerned official to
about forwarding of these Auditor remained in the process those bills. The
bills to the cheque office taking witnesses examined in
section. The same was possession of these support of this charge
conveyed by Mr. Taimoor vouchers and possibly are Shahbaz Qamar
Bukhari Assistant AG. questioning Senior Auditor and
(Annexure-O) genuineness of the bills Arshad Iqbal Assistant
g. There is nothing on the (and verifying the same Accounts Officer were in
record to show that these on following day), Mr. fact the persons
bills were formally signed Taimoor Bukhari did responsible for the this
by the AG as per not bother to come to unfortunate happening.
requirement of the office the AG office after the They are also co-
order dated: 26-05-2014 commotion and change accused alongwith the
whereby all bills of the of command. In his undersigned before the
value beyond five million statement to the inquiry NAB and are also being
 were to be approved by officer, he claims that proceeded against under
the DG. (Annexure-P) he did not do that due the E&D Rules. So, their
h. The signature of the DDO to perceived threat to testimony is tainted with
did not match but the his life. (Annexure-R) the very strong bias to
payroll-7 section could c. It is obvious that pre make the undersigned a
not detect it. Accordingly audit checks were not scapegoat. As section
they relied on fake exercised at any level. incharge, the
documents to admit the The section should undersigned could
bills for payment. They have been conscious supervise and ensure
overlooked the following that both the AAO and that the work of the
pre-audit requirements Assistant AG were just section runs smoothly,
either intentionally or due recently posted in the particularly, it was the
to lack of experience:- section and therefore month of June, the end
(Annexure-Q) lacked experience of of financial year and
i. Recommendati the work of the section. burden of work had
on by the They should have increased. Please see
Consultant firm applied substantive Rai Shabbir Ahmed Vs
M/s ACE (Pvt.) checks before Government of Punjab
Ltd. For admitting the claims. {1981 PLC (CS)755} and
processing of d. There are various Sarfraz Khan Vs. Water
contractor’s bill possibilities; and Power Development
ii. The signatures i. Mr. Taimoor Bukhari Authority and 2 Others
of the DDO are knew that the bills {1991 PLC (CS)9} as to
forged were fake and yet the evidentiary value of a
iii. The sequence processed them. co-accused.
of IPC Nos. is ii. He got them d) The statement of a co-
incorrect processed accused/accomplice
iv. The Letter expeditiously due to does not provide
Head in the lack of experience sufficient evidence to
forged because he did not sustain a charge unless
document is know what checks to it is properly
without the be applied. corroborated by tangible
WCLA iii. He got the bills independent evidence
watermark logo processed to which is totally missing in
v. Difference in appease the AG this case.
font and size of and to show his e) That the inquiry officer
the print utter faithfulness drew a totally baseless
vi. WCLA without realizing inference from the fact
vouchers about nature of that the processing of the
numbers and bills. bill was completed in 24
amount to the iv. He authorized the minutes. (it was not part
forged bills are bill on behalf of AG of the charge). However,
incorrect on the trust that he he has not tried to find
vii. The relevant would sign the out that processing of
documents that same. many others bills was
show the civil v. He was confident completed even before
works items are that either the 24 minutes. In their
missing wrong payment statements before the
would not be Inquiry Officer the AAO
i. The Senior Auditor, AAO detected and even and the Senior Auditor
 and Assistant AG signed
all the bills and punched
in the system using their
own User IDs.
j. The cheque was issued
and credited into fake
bank account until got
reversed by the next AG
after 27-06-2014.
k. When the change of AG
was taking place on 27-
06-2014 under pressure
from the employees /
Police, paid vouchers of
these four bills were on
the table of the AG as
reported in the
statements of Senior
Auditor / AAO of payroll-7
to this inquiry officer as
well as in other inquiry
reports. In fact, some of
the documents from the
bills were in the drawer of
the AG’s table and
recovered from there
almost instantly after
forceful exit of Mr. Zahhid
Rasheed from the
Chamber of the AG on
27-06-2014 after
commotion.
if detected the have admitted that they
vouchers would not were never asked to
be found to fix ignore pre-audit checks
responsibility. rather they admitted that
they were asked to
e. Only detailed forensic process the bills swiftly
expertise can decide and that comes within
which one of the above the scope of the duty of
possibilities is true. the undersigned as a
However, the Section Incharge,
documentary soft and particularly in view of the
hard evidence prove fact of that on
that Mr. Taimoor 23.06.2014, on the
Bukhari successfully complaint of Mr. Kamran
persuaded Payroll-7 Lashari, the Director
section to process the General of the Walled
fake bills in a space of City Project Authority,
just 24 minutes either the Senior Auditor and
out of his own interest AAO were changed and
to get things done or to additional charge of the
show compliance to the post of Incharge Payroll-
AG who had 7 was given to the
circumstantially obliged undersigned to look after
him by maneuvering the duties of the said
his posting back to AG section.
Punjab after the f) The bills were allotted
disgraceful surrender token on 25.6.2014 and
by the Ex-AG. not on 26.6.2014 as
f. Mr. Taimoor Bukhari assumed by the Inquiry
could claim a benefit of Officer to draw a totally
doubt on account of groundless presumption
lack of experience, but that the bills were
is ineligible on account processed with undue
of his blind compliance haste. The pre-audit
to the system installed checks, which according
by the then AG which to the Inquiry Officer
allowed such fake bills, were overlooked, did not
as of Walled City come within the purview
Project, to find easy of the responsibility of
access to the the undersigned and for
Government’s wallet that the Senior Auditor
unhindered and and the AAO are
unhurdled. responsible who have
clearly admitted that they
were never asked for to
bypass or ignore any
pre-audit check. The
finding of the Inquiry
Officer that the pre-audit
checks were not properly
 applied, clearly means
that the AAO and the
Senior Auditor failed to
do their duty. Thus, the
evidence brought on the
record does not
substantiate the charge
against the undersigned
nor the Inquiry Officer
has so found.
g) Also in the inquiry report
under the Efficiency and
Discipline Rules against
Mr. Arshad Iqbal AAO,
the Inquiry Officer, Mr.
Hamza Ali, a PAAS (BS-
17 Officer) has
remarked:-

"It is pertinent to mention

here both Senior Auditor, Mr.
M. Shahbaz Qamar and
Assistant Accounts Officer
Mr. Arshad Iqbal have alleged
that they failed to perform
their duty due to pressure
from Mr. Taimoor Bukhari, the
then AAG. However, during
the course of inquiry, they
have not been able to
successfully prove their
allegation through an
objective and substantial
piece of evidence to
completely rule out their
failure to stop the fraudulent
claims.”

h) Under clause (d) of the

opinion he has referred to five
possibilities. As to the extent
of responsibility of the
undersigned in this entire
unfortunate incident and
under clause (e) of the

4. Para 3 (iv) of charge sheet:
You were found to be in
possession of fake stamps of
the vendors, in whose name
a. The Senior Auditor Payroll-7
and Naib Qasid of Mr. Taimoor
Bukhari reported that the stamp
of M/S Qavi Engineers was
noticed from the room of Mr.
opinion he finds:-
“Only detailed forensic
expertise can decide which
one of the above
possibilities is true.
However, the documentary
soft and hard evidence
prove that Mr. Taimoor
Bukhari successfully
persuaded Payroll-7
section to process the fake
bills in a space of just 24
minutes either out of his
own interest to get things
done or to show
compliance to the AG who
had circumstantially obliged
him by maneuvering his
posting back to AG Punjab
after the disgraceful
surrender by the Ex-AG.”
i) Thus, in fact the Inquiry
Officer did not find the
undersigned guilty of this
charge as well. The
observations of persuasion
was never the part of the
charge and even if, without
conceding, persuasion is
proved, then the undersigned
was only doing his duty to
ensure that the work of the
section is conducted smoothly
and swiftly. There is no
finding that this charge has
been proved.
a. Mr. Taimoor Bukhari a. The first report about Charge has not
disowns possession of the presence of the As at para 3(i) been proved.
any stamp. It is obvious fake stamp came from
that before leaving the the Senior Auditor (Mr.
AG office at the time of Jawwad) of Payroll-7
the fake bills were got prepared Taimoor Bukhari on 27-06-2014
and processed. This further almost at the same time when
corroborates your active commotion was taking place in
involvement in fraud. AG’s Chamber.(Annexure-S)
b. Mr. Taimoor Bukhari went away
from the AG office at the time of
commotion and did not return
thereafter.
c. His room was locked and was
later opened in his absence.
The fake stamp was reportedly
recovered from the room.
(Annexure-T)
commotion he could have
removed anything from
his office without
knowledge of any one
because everyone was
focused at the mob
activity on the ground
floor.
b. Mr. Taimoor Bukhari’s
room was upstairs. He
even left his cheque book
behind before leaving.
b.
section who had
documented these four
bills in the system. The
other Senior Auditor
(Mr. Shehbaz) teamed
up with AAO who
created an alarm to the
Additional AG/ new AG
about paid vouchers of
Walled City Project
Bills after the
commotion and change
of command.
Interestingly, the same
AAO played a vital role
in verifying these bills
as fake from the
Project Office on
28-06-2014 resulting in
eventual recovery from
the Allied Bank of
Pakistan. When asked
from the Senior Auditor
(Mr. Jawwad) by the
inquiry officer as to why
he had gone to Mr.
Taimoor Bukhari’s
room precisely at the
time of commotion at
ground floor, he replied
that he had been
offered cold water from
the dispenser stationed
in the locked office of
Mr. Taimoor Bukhari
upstairs by his Niab
Qasid from whom he
had requested a glass
of water, when
standing on ground
floor. He added that
while he was having
water in Mr. Taimoor
Bukhari’s room, he
noticed a stamp on the
table of Mr. Taimoor
Bukhari which later
came to be found as
fake.
It is considered that the
 Senior Auditor has
concocted a story of
fake stamp presence in
Mr. Taimoor Bukhari’s
room because of the
following:

i. There was no point

for the Senior Auditor
to go to Mr. Bukhari’s
room at the heat of
the moment of
commotion when he
was already
concerned about the
Walled City
vouchers.
ii. The same AAO who
created an alarm
about the vouchers
of fake claims on 27-
06-2014 also
reported about the
fake stamp.
iii. Going upstairs
merely for water in a
locked room appears
to be farfetched.
iv. Recovery of same
stamp has been
mentioned by the
CGA in her letter to
NAB dated: 01-07-
2014 as having been
found from the
Chamber of the AG.
(Annexure-U)
v. Mr. Taimoor Bukhari
could have easily
removed the stamp
before running away
from AG office on
27-06-2014 at the
time of commotion.

5. Para 3(v) of charge sheet: a. Ever since Mr. Zahhid Rasheed a. Mr. Taimoor Bukhari was a. The manner in which Charge proved.
took over the charge as AG in charge of Admin Mr. Taimoor Bukhari You collaborated with the
You collaborated with the team of (Punjab) on 22-05-2014, he Section. (Annexure-X) joined AG Punjab,
team of private persons and
private persons and officials of employed various tactics to b. The AG office was attained the charge of
Accountant General Punjab strengthen his control over the conscious of the important sections, officials of Accountant
malafide deployed by Mr. Zahhid office and one of those was
Rasheed in order to create a rush deployment of several guards /
and an environment of fear in the private persons in various
office so as to get the things done sections to watch and monitor
accordingly to your whims. swift implementation of his
commands. (Annexure-V)
b. These guards / persons might
also be armed as evident from
the statement of an official of
AG Punjab. (Annexure-W).
c. These guards / persons also
occupied the Rest House in
AG’s office premises.
relationship of Mr. conveyed the General Punjab mala fide
Taimoor Bukhari with Mr. command of the AG, deployed by Mr. Zahid
Zahhid Rasheed from the facilitated the handover Rasheed in order to create
day when Mr. Taimoor of the punching
a rush and an environment
Bukhari was in charge of machine, persuaded
DAOs Coord cell under payroll-7 to pass the of fear in the office so as to
DG Accounts because of bills of M/S Qavi get the things done
which he was Engineering in the according to your whims.
surrendered by Mr. Idrees presence of private
Tarar the Ex-AG. guard, his sudden (a) The portion of the
c. Any command of the AG disappearance from
opinion under (a) as to
communicated by Mr. the office of AG Punjab
Taimoor Bukhari even during commotion, his the manner in which the
verbally was taken choice not to attend the undersigned attained
seriously by the officials office after joining of the charge of important
as evident from the new AG, his perception section etc. was wholly
handover of token of life threat etc. uncalled for after
punching machine by provide sufficient Charges (i) and (iv) he
cheque section on 16-06- circumstantial evidence
2014 on verbal command. that Mr. Taimoor himself held as not
d. Free movement of private Bukhari facilitated Mr. proved and regarding
persons and guards and Zahhid Rasheed in other charges there is
its negative effect on the creating an no finding that these
office should have been a environment in AG charges stood proved.
concern for the admin Punjab in June 2014
section. which was conducive
e. The creation of to his (Mr. Zahhid (b) That, in any case, the
environment of fear due Rasheed) interests and charge was too vague
to presence of guards motives as reflected in to merit consideration,
and private persons is passage of four fake inasmuch as, that the
reflected in the events bills of Rs. 104 million stated team of private
which took place during and possible attempt of persons and officials of
the six week tenure of Mr. clearance of 19 bills of
the Accountant General
Zahhid Rasheed as AG Rs. 383 million.
Punjab, such as:- remain unidentified and
i. All Accounts also that there was no
Officers of AG evidence whatsoever
Punjab applied that the undersigned
for leave to the was responsible for
AG. commotion of 27th June,
(Annexure-Y)
ii. Sudden mob 2014.Rather, the
activity charge itself says that
/commotion on these private persons
27-06-2014. and officials were
iii. Presence of deployed by Mr. Zahid
Police at the Rasheed. The only
time of
allegation against the
commotion
iv. Departure of petitioner was of
 the AG under collaboration, but
police neither any overt act
protection after was attributed to the
the employees
petitioner nor was there
reportedly
threatened to any evidence to
physically substantiate this
assault him charge. (emphasis
during supplied)
commotion.
v. Occupation of
(c) Under finding at (a), the
rest house and
DG’s office by Inquiry Officer declared
these persons. the undersigned as
Incharge of Admin
Section. This is not
correct. The overall
incharge of the
Administration of the
A.G. Office is one PAAS,
BS-19 Officer, i.e.,
Additional Accountant
General (Admin).

(d) The very charge, itself, is

that private persons and
officials of the
Accountant General
were deployed by Mr.
Zahid Rasheed, the then
Accountant General. In
fact they were deployed
by the then Accountant
General on 23.5.2014
while the undersigned
had joined the Office on
4.6.2014. Thus, the
undersigned could not be
blamed for outside
influence. It was the
previous administration
who had facilitated their
presence in the office for
which the undersigned
could hardly be blamed.
However, even that
finding was demolished
by the Inquiry officer
himself when under
clause (e) he established
the responsibility of this
charge on Mr. Zahhid
Rasheed, the then
Accountant General,
Punjab.
 28/N

109. Wit reference to the kind remarks at para 108/N, it is submitted that inquiry report
dated 17.05.2016 has been received from Mr. Masood Akhtar Sherwani, Dy. MAG,
Rawalpindi/Inquiry Officer against Syed Taimoor Bukhari, Ex-AAG Punjab (under
suspension) the accused officer, which may kindly be seen. The inquiry report is placed
in the below linked file please. The same could not be processed earlier due to reason
the case file was under process in his suspension case please.

110. A Charge Sheet was issued by the Competent Authority against the accused officer vide
order dated 05.11.2015 (Page-154/C) containing five allegations and task for conducting
of inquiry was assigned to Mr. Masood Akhtar Sherwani, Dy. MAG, Rawalpindi and
accused officer gave his written defence reply to the Inquiry Officer on 11.01.2016
which is placed in the below linked file.

111. The nominated Inquiry Officer has conducted the assigned inquiry in detail and exposed
the facts, findings and has also given his opinion on each charge leveled in the Charge
Sheet and has also recorded the evidences/witness in support of his findings as well.

112. The inquiry officer has concluded in his findings as ‘‘Mr. Taimoor Bukhari was
surrendered by the AG when he was on probation. He joined back after the AG who
surrendered him had been replaced. With such short experience of working in AG
Punjab, he was not expected to be at the center of such a mess in June 2014 which
brought the highly respected organization of AG Punjab to open disrepute. In deed out
of his free will, he allowed himself to be used as a pawn by the others for their own
larger interest at the cost of his career and reputation. Borrowing words from Mr.
Idrees Tarar, it was unbecoming of a PA&AS officer. He deserves a psychological make
over under a professional mentor’’.

113. The Juxta position of the inquiry conducted is placed in the linked file which may also
kindly be seen. In the Charge Sheet four allegations out of five have been proved by the
Inquiry Officer.

114. It is pointed out that inquiry officer has not proposed/recommended penalty(s) to be
imposed upon the accused officer on conclusion of inquiry and also has not afforded an
opportunity of personal hearing as required under Rule 6 of the Government Servants
(E&D) Rules, 1973.

115. Submitted for kind perusal and further orders please.

AAO (Legal-I)

AO (Legal-I)

Director Legal
 (To be published in part- 1 of the Gazette of Pakistan)

Office of the
Auditor General of Pakistan
(Constitution Avenue)
Islamabad

Notification
Date: 29.06.2016

No. Dir (A)/11-321/Discip/15. In continuation of this office Notification bearing No.16/Dir (A)/11-
321/Discip/15 dated 18.04.2016, the Auditor General of Pakistan has been pleased to extend the
suspension period of Syed Taimoor Bukhari, BS-17 of Pakistan Audit & Accounts Service
(Ex-Assistant Accountant General Punjab) for a further period of three months w.e.f 08-05-2016
under Rule 5(1) (i) of E&D Rules, 1973.

2. The officer will be entitled to draw subsistence grant as admissible under FR-53 (b) during his
suspension period.

(Ahmed Hussain)
Deputy Auditor General (A&C)/
Authorized Officer
The Manager,
Printing Corporation of Pakistan Press
Karachi
Copy to:-
1. The Accountant General of Pakistan Revenue, Islamabad/ Sub office, Lahore.
2. S.P.S to Auditor General of Pakistan
3. P.S to Additional Auditor General-I
4. P.S to Additional Auditor General-II
5. P.S to CGA, Islamabad
6. Military Accountant General Rawalpindi Cantt.
7. Controller Military Accounts, Lahore Command, Lahore Cantt.
8. Mr. Taimoor Bukhari, ACMA O/O Controller Military Accounts (Lahore Command) Lahore
Cantt (under suspension)
9. The Audit Officer (Confidential-II), Local
10. The Assistant Audit Officer (IT), Local
11. The Audit Officer PAAS-II section (Local)
 Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No. 159 -Dir(A)/11-321/Discip/15 Dated: 01.08.2016

SHOW CAUSE NOTICE

WHEREAS, A Charge Sheet bearing No. 391-Dir(A)/11-321/Discip dated

05.11.2015 was issued against you on account of “Inefficiency”, “Misconduct” and
“Corruption” committed by you while posted as Assistant Accountant General (BPS-17)
office of the Accountant General Punjab, Lahore.

2. WHEREAS, Mr. Masood Akhter Sherwani, Deputy Military Accountant

General (BS-20) PA&AS was nominated as Inquiry Officer who has submitted his
Inquiry Report and concluded that three charges out of five have been fully proved (a
copy of the Inquiry Report is enclosed).

3. WHEREAS, the undersigned, being the Authorized Officer, under Rule

2(3) of the Government Servants (Efficiency & Discipline) Rules, 1973 is of the view that
three charges against you stand established.

4. AND WHEREAS, the undersigned has come to the provisional conclusion

that you appear to be guilty of “Inefficiency”, “Misconduct” and “Corruption” within
the meaning of the rule 3(a), (b) and (c) under the Government Servants (E&D) Rules,
1973 on account of the said acts of omission and commission on your part and your are
liable to disciplinary action, which may involve the imposition of one or more penalties,
including the penalty of “Dismissal from Service” as prescribed in Rule 4 (b) (iv) of the
said Rules.

5. NOW, therefore, you Syed Taimoor Bukhari, (PAAS/BS-17) are hereby

called upon to Show Cause in writing within fourteen (14) days of the receipt of this
notice as to why major penalty of Dismissal from Service as prescribed in Rule 4(b)
(iv) of Government Servants (Efficiency & Discipline) Rules, 1973 may not be imposed
upon you.
 -2-

6. In case no reply is received within the specified period, it would be

presumed that you have no defence to offer, and action against you would be taken
ex-parte. In your reply you should also state whether you desire to be heard in person
by the undersigned (Authorized Officer).

(Dr. Waheed Ahmed)

Deputy Auditor-General (A&C)
Authorized Officer

 Mr. Taimoor Bukhari, ACMA O/O Controller Military Accounts (Lahore

Command) Lahore Cantt (Under Suspension)
 32/N

126. PUC is a letter dated 02.08.2016 enclosed with a letter of AG Punjab, Lahore dated
15.07.2016, received from O/o the CGA, Islamabad which may kindly be seen.
127. It is submitted that after completion of inquiry report submitted by the inquiry officer,
the Authorised Officer has issued show cause notice to the accused to submit his
written defence. (P-187/C).

128. At present no action is required on the PUC. If agreed to, we may file the same.

129. It is further submitted that Syed Taimoor Bukhari, BS-17 officer of Pakistan Audit &
Accounts Service (Ex-Assistant Accountant General Punjab), was suspended vide this
office Notification bearing No.117- Dir(A)/11-321/Discip/15 dated 29.06.2016 (Page
184/C) for a period of three months w.e.f. 08.05.2016 and his suspension period has
been expired on 07.08.2106.

130. It is proposed that extension in the suspension period in respect of Syed Taimoor
Bukhari for a further three months w.e.f. 07.08.2016 and is solicited for approval of the
Competent Authority please.

131. Draft Notifications for extension of suspension period in respect of accused officer is
submitted for approval please.

132. Submitted for information and further order please.

AAO (Legal-I)

AO (Legal-I)

Director (Legal)
 (To be published in part -1 of the Gazette of Pakistan)

Office of the
Auditor General of Pakistan
(Constitution Avenue)
Islamabad

Notification
Date. .08.2016

No. Dir (A)/11-321/Discip/15. In continuation of this office Notification bearing No. 117/
Dir (A)/11-321/Discip/15 dated 29.06.2016, the Auditor General of Pakistan has been pleased
to extend the suspension period of Syed Taimoor Bukhari, BS-17 of Pakistan Audit & Accounts
Service (Ex-Assistant Accountant General Punjab) for a further period of three months w.e.f.
08.08.2016 under Rule 5(1) (i) of E&D Rules, 1973.

2. The officer will be entitled to draw subsistence grant as admissible under FR-53(b)
during his suspension period.

(Dr. Waheed Ahmed)

Deputy auditor General (A&C)/
Authorized Officer
The Manager,
Printing Corporation of Pakistan Press
Karachi.

Copy to:-
1. The Accountant General of Pakistan Revenue, Islamabad/ Sub office, Lahore.
2. S.P.S to Auditor General of Pakistan
3. P.S to Additional Auditor General -I
4. P.S to Additional Auditor General –II
5. P.S to CGA, Islamabad
6. Military Accountant General Rawalpindi Cantt.
7. Controller Military Accounts, Lahore Command, Lahore Cantt.
8. Mr. Taimoor Bukhari, ACMA O/O Controller Military Accounts (Lahore
Command) Lahore Cantt (under suspension)
9. The Audit Officer (Confidential –II), Local
10. The Assistant Audit Officer (IT), Local.
11. The Audit Officer PAAS-II section (Local)
 27/N

104. It is submitted that Syed Taimoor Bukhari, BS-17 officer of Pakistan Audit &
Accounts Service (Ex-Assistant Accountant General Punjab), was suspended
vide this office Notification bearing No.16- Dir(A)/11-321/Discip/15 dated
18.04.2016 (Page 182/C) for a period of three months w.e.f. 08.02.2016 and his
suspension period has been expired on 07-05-2106.
105. It is further proposed that extension in the suspension period in respect of Syed
Taimoor Bukhari for a further three months w.e.f. 08.05.2016 and is solicited for
approval of the Competent Authority please.
106. Draft Notifications for extension of suspension period in respect of both officers
are submitted for approval please.
 13/N

35. It is submitted that Show Cause Notice bearing No. 159-Dir (A)/11-321/Discip

dated 01.08.2016 alongwith complete copy of inquiry report was sent through

UMS mail to Syed Taimoor Bokhari, Ex-Assistant Accountant General Punjab,

Lahore, at his available residential address on which previously correspondence

has been made with him, the same has been received back undelivered with

remarks that subject premises is closed and hence the said material could not be

delivered to the accused officers.

36. Submitted for kind perusal and further orders please.

AAO (Legal-I)

AO (Legal-I)

Director (Legal)
 Through TCS
No. 159-Dir (A)/11-321/Discip/15 Dated 01.08.2016

To,

Syed Taimoor Bukhari,

(Ex-Assistant Accountant General Punjab, Lahore)
(Under Suspension)

135 J-II,
Johar Town,
Lahore
Phone: 0300-9453254

From:

Director Legal,
O/o the AGP, Islamabad.
 33/N

135. PUC is a reply to the Show Cause Notice dated 01.08.2016 submitted by Syed

Taimoor Bukhari, the accused officer, wherein he has submitted his defence to

the charges leveled against him and he has also requested to give him a chance

of personal hearing, which may kindly be seen.

136. A juxta position of the case after Show-Cause Notice reply submitted by the

accused officer is placed in linked file (Vol-II/placed below) please.

137. Submitted for kind perusal and further orders please.

AAO (Legal-I)

AO (Legal-I)

Director (Legal)
To,

Dr. Waheed Ahmad,

Deputy Auditor General (A&C) (Authorized Officer),
Office of the Auditor General of Pakistan,
Audit House, Constitution Avenue,
Islamabad.

SUBJECT: REPLY OF THE SHOW CAUSE NOTICE

Respected Sir,

Kindly refer to the Show Cause Notice bearing No. No.159-

Dir(A)/11-321,Discip/15, dated 01-08-2016. I have to make the following submissions:-

02. The proceedings were taken against the undersigned on five charges given
below:-

(i) You with the connivance of Mr. Zahid Rasheed the then Director
General DAO’s (OPS) got yourself posted back as Assistant
Accountant General, whereas you already had been surrendered on
account of misconduct from the office of Accountant General Punjab.

(ii) You obtained the possession of token punching machine in complete

disregard to standard operating procedures, during the month of
June, 2014.

(iii) You compelled your staff in Payroll-7 Section to process the

counterfeited bills without exercising proper pre-audit checks which
confirm your willful involvement in processing the counterfeited bills
in connivance with the then Director General/Accountant General (on
look after basis).

(iv) You were found to be in possession of fake stamps of the vendors, in

whose name the fake bills were got prepared and processed. This
further corroborates your active involvement in the fraud.

(v) You collaborated with the team of private persons and officials of
Accountant General Punjab mala fide deployed by Mr.Zahid Rasheed
in order to create a rush and an environment of fear in the office so
as to get the things done according to your whims.
 ON FINDINGS: Charge (i) and Charge (iv) were clearly held by the Inquiry Officer
to have not been proved. As far as charges (ii), (iii) and (v) are concerned, the Inquiry
Officer did not record any finding of guilt against the undersigned, and as a necessary
corollary thereof, these charges were also not proved. Submissions in respect of
charges No.(ii), (iii) and (v) are also briefly being made in this reply.

03. The important feature of the inquiry report is that a number of extraneous factors
to the charge-sheet have been taken into consideration by the Inquiry Officer and the
conclusions have been drawn with observations which were never part of the charge-
sheet and were beyond the scope of the inquiry because at no stage the undersigned
had an opportunity to rebut those. Reliance is respectfully placed on Government of
PakistanVs. Farheen Rashid (2011 SCMR 1) in which a civil servant was dismissed on
the allegation which was not part of the charge-sheet and Fayyaz Muhammad Vs.
Deputy Inspector-General of Police Bahawalpur Range, Bahawalpur and another
{1973 PLC (CS)361} in which, instead of proof of charge, a civil servant was punished
on extraneous considerations and the Service Tribunal interfered in both the matters.

Charge-(ii)

OBTAINING POSSESSION OF TOKEN PUNCHING MACHINE

04. As far the law laid down by the Superior Courts and the Service Tribunal, the
charge had to be proved and not an allegation which was not part of the charge-sheet.
The finding of the Inquiry Officer was that:-

“The punching machine was under the direct influence of the

outsider namely Shakeel Ahmad, installed by the AG”.

05. According to the Bill Tracking Report (BTR) Mr. Sajjad Shah had punched the
token. The only evidence to support this charge comes from Mian Ahmad Saeed, the
AO, Cheque Section.

06. According to him (A.O. Cheque) the machine was handed over to Rana Shakeel
on the verbal orders of the then Accountant General conveyed by undersigned.
However, while appearing before the Investigating Officer of the NAB, he took a
different position and stated that the undersigned conveyed the order of the Accountant
General through Muzaffar Shah to handover the machine to the concerned authority
and incidentally, he (A.O. Cheque), himself was the concerned authority. This
contradiction makes the two statements as mutually destructive. However, one thing
which is positively established is that at no stage the token machine was ever in
possession of the undersigned as alleged in the charge.

07. The Inquiry Officer clearly found that the machine was not in physical possession
of the accused and also found that:-
 “Some level of control of the machine in the last days of June by
the administration is usual but control of an outside agent of the AG
in June, 2014 is unusual”.

08. Sajjad Shah, who punched the token clearly admitted that it was Mr.Shakeel, a
private person representing the then Accountant General, at whose asking he had
punched the four bills.

09. The charge is not supported by any evidence and the ultimate finding of the
Inquiry Officer is that “It however, does not verify that the machine was in physical
possession of the accused officer” with the result that this charge was also not proved.
(underlined to supply emphasis)

10. Charge(iii)

You compelled your staff in Payroll-7 Section to process the

counterfeited bills without exercising proper pre-audit checks which
confirm your willful involvement in processing the counterfeited bills
in connivance with the then Director General/Accountant General (on
look after basis).

(a) As far the charge as framed is concerned, the Inquiry Officer has found
it disproved. Instead, the operative finding is that the undersigned
“successfully persuaded Payroll-7 Section to process fake bill in a space of 24
minutes either out of his own interest to get things done or to show
compliance of AG……..”. There is no clear finding except probabilities.

(b) Mr.Jawad Qamar, the KPO, who is not an accused, has also been
examined. He falsely stated that the undersigned handed over to him five
bills. So far recovery of stamp is concerned, the Inquiry Officer disbelieved his
statement. He has been proved to be liar of his own showing.

(c) The finding of persuasion does not amount to compelling the

concerned officials to process those bills. The witnesses examined in support
of this charge are Shahbaz Qamar, Senior Auditor, and Arshad Iqbal,
Assistant Accounts Officer, were in fact the persons responsible for this
unfortunate happening. They are also co-accused along with the undersigned
before the NAB and are also being proceeded against under the Efficiency
and Discipline Rules. So, their testimony is tainted with very strong bias to
make the undersigned a scapegoat. As Section Incharge, the undersigned
could supervise and ensure that the work of the section runs smoothly,
particularly, it was the month of June, the end of financial year and burden of
work had increased. Please see Rai Shabbir AhmadVs. Government of
Punjab {1981 PLC (CS)755} and Sarfraz KhanVs. Water and Power
Development Authority and 2 others {1991 PLC (CS)9}as to the evidentiary
value of a co-accused.
(d) The Statement of a co-accused/accomplice does not provide sufficient
evidence to sustain a charge unless it is properly corroborated by tangible
independent evidence which is totally missing in this case.

(e) That the Inquiry officer drew a totally baseless inference from the fact
that the processing of the bill was completed in 24 minutes. (It was not part of
the charge). However, he has not tried to find out that processing of many
other bills was completed even before 24 minutes. In their statement before
the Inquiry Officer the AAO and the Senior Auditor have admitted that they
were never asked to ignore pre-audit checks rather they admitted that they
were asked to process the bills swiftly and that comes within the scope of the
duty of the undersigned as a Section Incharge, particularly in view of the fact
that on 23.6.2014, on the complaint of Mr. Kamran Lashari, the Director
General of the Walled City Project Authority, the Senior Auditor and AAO
were changed and additional charge of the post of Incharge Payroll-7 was
given to the undersigned to look after the duties of the said section.

(f) The bills were allotted token on 25.6.2014 and not on 26.6.2014 as
assumed by the Inquiry Officer to draw a totally groundless presumption that
the bills were processed with undue haste. The pre-audit checks, which
according to the Inquiry Officer were overlooked, did not come within the
purview of the responsibility of the undersigned and for that the Senior Auditor
and the AAO are responsible who have clearly admitted that they were never
asked for to bypass or ignore any pre-audit check. The finding of the Inquiry
Officer that the pre-audit checks were not properly applied, clearly means that
the AAO and the Senior Auditor failed to do their duty. Thus, the evidence
brought on the record does not substantiate the charge against the
undersigned nor the Inquiry Officer has so found.

(g) Also in the inquiry report under the Efficiency and Discipline Rules
against Mr.Arshad Iqbal AAO, the Inquiry Officer, Mr.Hamza Ali, a PAAS (BS-
17 Officer) has remarked:-

"It is pertinent to mention here both Senior Auditor, Mr.M.Shahbaz

Qamar and Assistant Accounts Officer Mr.Arshad Iqbal have
alleged that they failed to perform their duty due to pressure from
Mr.Taimoor Bukhari, the then AAG. However, during the course of
inquiry, they have not been able to successfully prove their
allegation through an objective and substantial piece of evidence
to completely rule out their failure to stop the fraudulent claims.”
 (h) Under clause (d) of the opinion he has referred to five possibilities. As
to the extent of responsibility of the undersigned in this entire
unfortunate incident and under clause (e) of the opinion he finds:-

“Only detailed forensic expertise can decide which one of the above
possibilities is true. However, the documentary soft and hard
evidence prove that Mr. Taimoor Bukhari successfully persuaded
Payroll-7 section to process the fake bills in a space of just 24
minutes either out of his own interest to get things done or to show
compliance to the AG who had circumstantially obliged him by
maneuvering his posting back to AG Punjab after the disgraceful
surrender by the Ex-AG.”

(i) Thus, in fact the Inquiry Officer did not find the undersigned guilty of
this charge as well. The observations of persuasion was never the
part of the charge and even if, without conceding, persuasion is
proved, then the undersigned was only doing his duty to ensure that
the work of the section is conducted smoothly and swiftly. There is no
finding that this charge has been proved.

11. Charge (v)

You collaborated with the team of private persons and

officials of Accountant General Punjab mala fide deployed by
Mr. Zahid Rasheed in order to create a rush and an
environment of fear in the office so as to get the things done
according to your whims.

(a) The portion of the opinion under (a) as to the manner in which the
undersigned attained the charge of important section etc. was wholly
uncalled for after Charges (i) and (iv) he himself held as not proved
and regarding other charges there is no finding that these charges
stood proved.

(b) That, in any case, the charge was too vague to merit consideration,
inasmuch as, that the stated team of private persons and officials of
the Accountant General remain unidentified and also that there was no
evidence whatsoever that the undersigned was responsible for
commotion of 27th June, 2014.Rather, the charge itself says that these
private persons and officials were deployed by Mr.Zahid Rasheed. The
only allegation against the petitioner was of collaboration, but neither
any overt act was attributed to the petitioner nor was there any
evidence to substantiate this charge. (emphasis supplied)

(c) Under finding at (a), the Inquiry Officer declared the undersigned as
Incharge of Admin Section. This is not correct. The overall incharge of
 the Administration of the A.G. Office is one PAAS, BS-19 Officer, i.e.,
Additional Accountant General (Admin).

(d) The very charge, itself, is that private persons and officials of the
Accountant General were deployed by Mr. Zahid Rasheed, the then
Accountant General. In fact they were deployed by the then
Accountant General on 23.5.2014 while the undersigned had joined
the Office on 4.6.2014. Thus, the undersigned could not be blamed for
outside influence. It was the previous administration who had facilitated
their presence in the office for which the undersigned could hardly be
blamed. However, even that finding was demolished by the Inquiry
officer himself when under clause (e) he established the responsibility
of this charge on Mr.Zahid Rasheed, the then Accountant General,
Punjab.

12. It may kindly be appreciated that none of the charges against the undersigned
stands proved. The witnesses examined during the inquiry being in fact the principal
accused, were not competent witnesses. They have made false and inconsistent
statements before the Inquiry Officer and the investigating team of NAB.

13. That the observation of the Inquiry Officer that “He (undersigned) deserves a
psychological make over under a professional mentor” is wholly incorrect. It is clearly in
excess of scope of the inquiry and is wholly uncalled for and, therefore, is liable to be
expunged.

14. In Tribhuban Parkash Vs. India (AIR 1970 S.C.540), the Indian Supreme Court
held that unless there is legally admissible evidence, the conclusions could not be
based on conjectures, surmises and suspicions. The Honourable Supreme Court of
Pakistan in Samiuddin QureshiVs. Collector of Customs (PLD 1989 S.C.335)
reiterated this principle in para-10 of the Judgment which is reproduced hereunder:-

“To dismiss a civil servant or for that matter, any employee on a

charge of taking bribe or misconduct is as serious a matter as
convicting a person for a crime because his whole career is ruined.
Therefore, the order of dismissal must be based on some evidence.”

15. In Samar Peraiz Vs. Board of Intermediate and Secondary Education,

Lahore and others (PLD 1971 S.C.838), it was held:-

“A Tribunal’s decision must rest not on suspicion but

upon legal grounds established by legal evidence”.

In view of the above, it is respectfully prayed that the inquiry proceedings may kindly be
closed as none of the charges brought against the undersigned has been established
by legal and admissible evidence. I may kindly be exonerated from the charges with all
back benefits, I may also kindly be given a personal hearing.
 Yours obediently,

(Syed Taimoor Bukhari)

Assistant Controller Military Accounts (Lahore
Command) (Under Suspension),
135-JII. Johar Town, Lahore.
# 0300-9453254.

Dated: August 23, 2016

CC:

Rana Shakeel Asghar,

Director (Legal),
Office of the Auditor General of Pakistan,
Islamabad.
 STATEMENT SHOWING JUXTA POSITION IN RESPECT OF DISCIPLINARY CASE AGAINST SYED TAIMOOR BUKHARI EX-ASSISTANT AG, AG PUNJAB (BS-19) PA&AS OFFICER

Sr. No.
Charge Fact Finding Opinion Accused Reply to Show Cause Notice

1. Para 3(i) of charge sheet:
You with the connivance of Mr.
Zahhid Rasheed the then
Director General DAO’s (OPS)
got yourself posted back as
Assistant Accountant General,
whereas you already had been
surrendered on account of
misconduct from the office of
Accountant General Punjab.
i. During his first tenure of posting in
AG Punjab Lahore upto 28-01-
2014, Mr. Taimoor
Bukhari was in charge of DAO’s
Coord Cell, besides other sections.
He was on probation period then.
j. The Reporting Officer was DG
Accounts (Mr. Zahhid Rasheed),
under the then AG (Mr. Idrees
Tarar)
k. On 31-12-2013, Mr. Idrees Tarar
AG Punjab wrote a letter to Dir
Admin AGP office, signed by the
AG himself, requesting posting of
Mr. Taimoor Bukhari out of AG
Punjab immediately on the grounds
mentioned in the said letter.
(Annexure-A)
l. Mr. Taimoor Bukhari AAG was
accordingly posted out of AG
Punjab by the AGP office on 28-01-
2014. (Annexure-B)
m. The order of transfer issued by the
AGP office on 28-01-2014 did not
give any reason for the transfer of
the officer (Mr. Taimoor Bukhari).
n. On 22-05-2014, Mr. Idrees Tarar
was replaced by Mr. Zahhid
Rasheed as AG. (Annexure-C)
o. On 03-06-2014, Mr. Taimoor
Bukhari was again posted back as
Assistant AG in AG Punjab.
(Annexure-D)
d. Letter written by Mr. Idrees Tarar
as AG Punjab to Dir. Admin AGP
office on 31-02-2013 was
“confidential”. (Annexure-A)
e. AGP’s transfer orders in regard to
Mr. Taimoor Bukhari, dated: 28-
01-2014 and 03-06-2014, did not
mention ground of posting.
(Annexure-E)
f. Questionnaire regarding
background of posting of Mr.
Taimoor Bukhari again into AG
Punjab on 03-06-2014 was sent by
the inquiry officer to the present
and previous Dir. Admin. The
same are still un-responded.
c. The Charge Sheet mentions the
cause of surrender of the officer
out of AG Punjab by Mr. Idrees
Tarar AG Punjab, as
misconduct. Evidently, this
charge was not communicated
to the accused officer before this
charge sheet. Therefore, the
accused has responded that he
has no knowledge about his
surrender in January 2014 by
the then AG as a cause of his
transfer out of AG Punjab.
d. It is viewed that the choice of
words made by Mr. Idrees Tarar
in his letter dated: 31-12-2013
(Annexure-A) clearly indicates
the AG’s uneasiness in regard to
officer’s style of working under
the then DG Accounts who was
the overall in charge of DAOs.
The latter happenings in AG
Punjab during the month of June
and the acts of utter faithfulness
exhibited by Mr. Taimoor
Bukhari to Mr. Zahhid Rasheed
as AG Punjab, however do
provide a semblance of his
possible connivance with Mr.
Zahhid Rasheed for his
reposting, but cannot be proved
through evidence, unless the
former Dir. Admin disclose it.
Charge (i) and Charge (iv) were clearly
held by the inquiry officer to have not been
proved. As far as charges (ii), (iii) and (v)
are concerned, the necessary corollary
thereof, there charges were also not
proved. Submissions in respect of
charges (ii), (iii) and (v) are also briefly
being made in this reply.
The important feature of the inquiry report
is that a number of extraneous factors to
the charge sheet have been taken into
consideration by the Inquiry officer and the
conclusion have been drawn with
observations which never part of the
charge sheet and were beyond the scope
of the inquiry because at no stage the
undersigned had an opportunity to rebut
those. Reliance is respectfully placed on
Government of Pakistan Vs. Farheen
Rasheed (2011 SCMR 1) in which a civil
servant was dismissed on the allegation
which was not part of the charge sheet
and Fayyaz Muhammad Vs. Deputy
Inspector General of Police Bahawalpur
Range, Bahawalpur and another {1973
PLC (CS) 361} in which instead of proof of
charge a civil servant was punished on
extraneous considerations and the
Service Tribunal interfered in both the
matters.

p. In the intervening period, i.e

between 28-01-2014 and 03-06-
2014, probation period of the
officer was terminated.

2. Para 3(ii) of charge sheet: e. Token punching machine is held in c. Thousands of tokens were c. The statements of officers and Obtaining possession of token punch
the charge of cheque section. punched after 16-06-2014 in the officials indicate that the AG’s machine
You obtained the possession of f. SOPs are available in this regard. office of AG Punjab by the same orders regarding shift of
token punching machine in g. On 16-06-2014 AO Cheque issued token machine. These bills were possession of the token As far the law laid down by the Superior
complete disregard to standard
operating procedure, during the
month of June, 2014.
h.
a certificate regarding last cheque
punched by his section.
(Annexure-F)
The section incharge stated before
the inquiry officer that the charge of
the machine was handed over by
the cheque section on verbal
orders of the AG conveyed to the
cheque section through Mr.
Taimoor Bukhari. (Annexure-G)
entertained by various sections
just like routine / normal bills.
However, the machine was now
under the direct influence of one of
the outsiders installed by the then
AG in cheque section, namely Mr.
Shakeel. (Annexure-H)
d. As per statements of cheque
section, they handed over charge
of the machine on AG’s orders
conveyed verbally by Mr. Taimoor
Bukhari. (Annexure-I)
d.
punching machine w.e.f 16-06-
2014 was verbally conveyed
through Mr. Taimoor Bukhari,
otherwise these would not have
gained enough strength for the
cheque section to follow the
same. These statements do not
indicate that the orders came
directly from the AG but do
indicate via media of Mr.
Taimoor Bukhari .It is viewed
that in order to possess full
control over the bills to be
punched after 16-06-2014, the
influence of the cronies of the
AG over the token machine was
necessary and possibly it was
got done by the AG through Mr.
Taimoor Bukhari. It however
does not verify that the machine
was in physical possession of
the accused officer.
Some level of control over the
machine in last days of June by
the administration is usual but
control of an outside agent of
the AG in June 2014 is unusual.
Courts and the Service Tribunal the
charge had to be proved and not an
allegation which was not part of the
charge sheet. The finding of the inquiry
officer was that:-
“The punching machine was under the
direct influence of the outsider namely
Shakeel Ahmad, installed by the AG”.
According to bill tracking report (BTR) Mr.
Sajjad Shah had punched the token. The
only evidence to support this charge
comes from Mian Ahmad Saeed, the AO,
Cheque Section.
According to him (AO, Cheque Section)
the machine was handed over to Rana
Shakeel on the verbal orders of the then
Accountant General conveyed by
undersigned. However, while appearing
before the Investigating Officer of the
NAB, he took a different position and
stated that the undersigned conveyed the
order of the Accountant General through
Muzaffar shah to handover the machine to
the concerned authority and incidentally
he (AO, Cheque Section), himself was
concerned authority. This contradiction
makes the to statements as mutually
destructive. However, one thing which is
positively established is that at no stage
the token machine was ever in possession
of the undersigned as alleged n the
charge.
The inquiry officer clearly found that the
machine was not in physical passion of
the accused and also found that
“Some level of control of the machine in
the last days of June by the administration
is usual but control of an outside agent of
the AG in June, 2014 is usual”.
Sajjad Shah, who punched the token
clearly admitted that it was Mr. Shakeel a
private person representing the then AG
at whose asking he had punched the four
bills.
 The charge is not supported by any
evidence and the ultimate finding of the
Inquiry Officer is that “It however, does not
verify that the machine was in physical
possession of the accused officer”

with the result that this charge was also

not proved. (underlined to supply
emphasis)
3. Para 3(iii) of charge sheet: c. The following bills were l. The record of SAP system shows g. The chain of events ranging Charge (iii)
punched in the system in the that all the four bills crossed the from punching of token on these
You compelled your staff in last week of June 2014 by the three levels (Level-1, level-2 and four fake bills of the “Walled City You compelled your staff in
Payroll-7 Section to process the payroll-7 section of the AG level-3) within 24 minutes late at Project” to the physical presence Payroll-7 Section to process the
counterfeited bills without Punjab: (Annexure-J) night at around 2200 hrs on 26-06- of these paid vouchers in the counterfeited bills without
exercising proper pre-audit 2014. (Annexure-L) AG’s Chamber proves a nexus exercising proper pre-audit checks
checks which confirm your Bill Tracking Report m. Both the AAO and Auditor claim of common interest between all which confirm your willful
willful involvement in 03-02-2016 that the bills were handed over to those who processed, involvement in processing the
processing the counterfeited them by Mr. Taimoor Bukhari. Mr. possessed and sought for the counterfeited bills in connivance
bills in connivance with the then Toke Token Section Cost Token TaimoorPark By Bukhari
Document Park denies.
Level 1 Level 2 same.
Level 2 However,
Level 3 whatLevel
surprises
3 No of with the
Posted Tokenthen
By Director General /
n No Date Name Center Amount No date
Director General / Accountant 1892 25-6- Payroll LZ4116 16,956,4
Incidentally
51056769 AHMAD
the SAP recordDate
26-6-14
shows
26-6-14 ARSHA
isDate
a common
26-6-14 TAIMOORS
date
experience
26-6-14
bills
that
1
Date
Accountant
26-6-14 SAJJADS
General (on look after
General (on look after basis). 40 2014 07 64 57 that the
M token number was DI usually the YED culprits of such basis).HAH
punched by Mr. Sajjad Shah on wrong doing (Passing a fake bill)
Bill Tracking Report 26-06-2014 on each of these 4 either do not paste their original h) As far the charge as framed is
03-02-2016 bills. signature on fake bills or vanish concerned, the Inquiry officer has
n. Interestingly, Mr. Sajjad Shah is the same immediately after found it disproved. Instead, the
Toke Token Section Cost Token the regular
Document Park Bycharge
ParkholderLevel
of 1the Level 2 issue
Level 2 of cheque
Level 3 to remove
Level 3 anyNo of operative
Posted finding is that the
Token By
n No Date Name Center Amount No punching machine. date Date
(Annexure-M) Date
evidence of their wrongdate doing.bills Date
undersigned “successfully
1892 25-6- Payroll LZ4116 38,000,4
41 2014 07 43 o.51056769 AHMAD 26-6-14
15 At the M time of generation of
26-6-14 ARSHA
DI
26-6-14
This has TAIMOORS
not happened.
YED
26-6-14 1
All the 26-6-14 SAJJADS
persuaded
HAH Payroll-7 Section to
document numbers in payroll-7, it concerned officers of Payroll-7 process fake bill in a space of 24
Bill Tracking Report had been known that the fifth bill of have signed the bills. They have minutes either out of his own interest
03-02-2016 the same nature could not be entered them into system using to get things done or to show
accepted by the system due to their own ID. The AAO created compliance of AG…..”. there is no
Toke Token Section Cost Token non-availability
Document Park By ofParkbudget.Level
Hence
1 Level 2 anLevel 2alarm
Level at
3 the Level
time3 of
No of clear finding
Posted except probabilities.
Token By
n No Date Name Center Amount No the same was not date processed. Date commotion
Date (which took dateplace in
bills i) Mr. Jawad Qamar the KPO who is
Date
1892 25-6- Payroll LZ4116 10,961,0 51056769 AHMAD 26-6-14
p. The statements of the AAO and 26-6-14 ARSHA 26-6-14 TAIMOORS
the chamber of the AG on 27-26-6-14 1 26-6-14
not anSAJJADS
accused has also been
42 2014 07 28 56 M DI YED HAH
the Senior Auditor reflect that they 06-2014 resulting in change of examined. He falsely stated that the
applied pre-audit checks on all the command of AG) by informing undersigned handed over to him five
Bill Tracking Report
four bills but under the duress of the Additional AG and the new bills. So far recovery of stamp is
03-02-2016
urgency from the Assistant AG. AG about the possibility of concerned; the Inquiry Officer
Toke Token Section Cost Token
The Assistant
Document Park By
AG denies
Park Level 1
it. Level 2
something
Level 2
fishy about
Level 3 Level 3
these
No of
disbelieved
Posted
his statement. He has
Token By
n No Date Name Center Amount No (Annexure-N) date Date bills,
Date emanating fromdate presence bills not been proved to be liar of this
Date
1892 25-6- Payroll LZ4116 26,579,6 q.51056769
After the bills were
AHMAD passed
26-6-14 there
26-6-14 ARSHA of their paid
26-6-14 TAIMOORSvouchers on the
26-6-14 1 own showing.
26-6-14 SAJJADS
43 2014 07 74 14 M DI YED HAH
was a usual need to convey an AG’s table. j) The finding of persuasion does not
authorization from the AG about h. While the AAO and the Auditor amount to compelling the concerned
d. Both the AAO and Assistant forwarding of these bills to the remained in the office taking official to process those bills. The
AG as in charge of Payroll-7 cheque section. The same was possession of these vouchers witnesses examined in support of
were posted only a few days conveyed by Mr. Taimoor Bukhari and possibly questioning this charge are Shahbaz Qamar
ago. (Annexure-K) Assistant AG. (Annexure-O) genuineness of the bills (and Senior Auditor and Arshad Iqbal
r. There is nothing on the record to verifying the same on following Assistant Accounts Officer were in
show that these bills were formally day), Mr. Taimoor Bukhari did fact the persons responsible for the
 signed by the AG as per
requirement of the office order
dated: 26-05-2014 whereby all bills
of the value beyond five million
were to be approved by the DG.
(Annexure-P)
s. The signature of the DDO did not
match but the payroll-7 section
could not detect it. Accordingly
they relied on fake documents to
admit the bills for payment. They
overlooked the following pre-audit
requirements either intentionally or
due to lack of experience:-
(Annexure-Q)
viii. Recommendation by the
Consultant firm M/s ACE (Pvt.)
Ltd. For processing of contractor’s
bill
ix. The signatures of the DDO are
forged
x. The sequence of IPC Nos. is
incorrect
xi. The Letter Head in the forged
document is without the WCLA
watermark logo
xii. Difference in font and size of the
print
xiii. WCLA vouchers numbers and
amount to the forged bills are
incorrect
xiv. The relevant documents that show
the civil works items are missing
t. The Senior Auditor, AAO and
Assistant AG signed all the bills
and punched in the system using
their own User IDs.
u. The cheque was issued and
credited into fake bank account
until got reversed by the next AG
after 27-06-2014.
v. When the change of AG was
taking place on 27-06-2014 under
pressure from the employees /
Police, paid vouchers of these four
bills were on the table of the AG as
reported in the statements of
Senior Auditor / AAO of payroll-7
to this inquiry officer as well as in
not bother to come to the AG
office after the commotion and
change of command. In his
statement to the inquiry officer,
he claims that he did not do that
due to perceived threat to his
life. (Annexure-R)
i. It is obvious that pre audit
checks were not exercised at
any level. The section should
have been conscious that both
the AAO and Assistant AG were
just recently posted in the
section and therefore lacked
experience of the work of the
section. They should have
applied substantive checks
before admitting the claims.
j. There are various possibilities;
vi. Mr. Taimoor Bukhari knew that
the bills were fake and yet
processed them.
vii. He got them processed
expeditiously due to lack of
experience because he did not
know what checks to be applied.
viii. He got the bills processed to
appease the AG and to show his
utter faithfulness without
realizing about nature of bills.
ix. He authorized the bill on behalf
of AG on the trust that he would
sign the same.
x. He was confident that either the
wrong payment would not be
detected and even if detected
the vouchers would not be found
to fix responsibility.
k. Only detailed forensic expertise
can decide which one of the
above possibilities is true.
However, the documentary soft
and hard evidence prove that
Mr. Taimoor Bukhari
successfully persuaded Payroll-
7 section to process the fake
bills in a space of just 24
minutes either out of his own
interest to get things done or to
this unfortunate happening. They
are also co-accused alongwith the
undersigned before the NAB and are
also being proceeded against under
the E&D Rules. So, their testimony
is tainted with the very strong bias to
make the undersigned a scapegoat.
As section incharge, the
undersigned could supervise and
ensure that the work of the section
runs smoothly, particularly, it was
the month of June, the end of
financial year and burden of work
had increased. Please see Rai
Shabbir Ahmed Vs Government of
Punjab {1981 PLC (CS)755} and
Sarfraz Khan Vs. Water and Power
Development Authority and 2 Others
{1991 PLC (CS)9} as to the
evidentiary value of a co-accused.
k) The statement of a co-
accused/accomplice does not
provide sufficient evidence to
sustain a charge unless it is properly
corroborated by tangible
independent evidence which is
totally missing in this case.
l) That the inquiry officer drew a totally
baseless inference from the fact that
the processing of the bill was
completed in 24 minutes. (it was not
part of the charge). However, he
has not tried to find out that
processing of many others bills was
completed even before 24 minutes.
In their statements before the Inquiry
Officer the AAO and the Senior
Auditor have admitted that they were
never asked to ignore pre-audit
checks rather they admitted that
they were asked to process the bills
swiftly and that comes within the
scope of the duty of the undersigned
as a Section Incharge, particularly in
view of the fact of that on
23.06.2014, on the complaint of Mr.
Kamran Lashari, the Director
General of the Walled City Project
Authority, the Senior Auditor and
AAO were changed and additional
other inquiry reports. In fact, some
of the documents from the bills
were in the drawer of the AG’s
table and recovered from there
almost instantly after forceful exit
of Mr. Zahhid Rasheed from the
Chamber of the AG on
27-06-2014 after commotion.
show compliance to the AG who
had circumstantially obliged him
by maneuvering his posting
back to AG Punjab after the
disgraceful surrender by the Ex-
AG.
l. Mr. Taimoor Bukhari could claim
a benefit of doubt on account of
lack of experience, but is
ineligible on account of his blind
compliance to the system
installed by the then AG which
allowed such fake bills, as of
Walled City Project, to find easy
access to the Government’s
wallet unhindered and
unhurdled.
charge of the post of Incharge
Payroll-7 was given to the
undersigned to look after the duties
of the said section.
m) The bills were allotted token on
25.6.2014 and not on 26.6.2014 as
assumed by the Inquiry Officer to
draw a totally groundless
presumption that the bills were
processed with undue haste. The
pre-audit checks, which according to
the Inquiry Officer were overlooked,
did not come within the purview of
the responsibility of the undersigned
and for that the Senior Auditor and
the AAO are responsible who have
clearly admitted that they were
never asked for to bypass or ignore
any pre-audit check. The finding of
the Inquiry Officer that the pre-audit
checks were not properly applied,
clearly means that the AAO and the
Senior Auditor failed to do their duty.
Thus, the evidence brought on the
record does not substantiate the
charge against the undersigned nor
the Inquiry Officer has so found.
n) Also in the inquiry report under the
Efficiency and Discipline Rules
against Mr. Arshad Iqbal AAO, the
Inquiry Officer, Mr. Hamza Ali, a
PAAS (BS-17 Officer) has
remarked:-
"It is pertinent to mention here both
Senior Auditor, Mr. M. Shahbaz
Qamar and Assistant Accounts
Officer Mr. Arshad Iqbal have
alleged that they failed to perform
their duty due to pressure from Mr.
Taimoor Bukhari, the then AAG.
However, during the course of
inquiry, they have not been able to
successfully prove their allegation
through an objective and substantial
piece of evidence to completely rule
out their failure to stop the fraudulent

4. Para 3 (iv) of charge sheet:
You were found to be in
possession of fake stamps of
the vendors, in whose name the
fake bills were got prepared and
processed. This further
d. The Senior Auditor Payroll-7 and
Naib Qasid of Mr. Taimoor Bukhari
reported that the stamp of M/S
Qavi Engineers was noticed from
the room of Mr. Taimoor Bukhari
on 27-06-2014 almost at the same
time when commotion was taking
c. Mr. Taimoor Bukhari disowns
possession of any stamp. It is
obvious that before leaving the AG
office at the time of commotion he
could have removed anything from
his office without knowledge of any
one because everyone was
c. The first report about the
presence of the fake stamp
came from the Senior Auditor
(Mr. Jawwad) of Payroll-7
section who had documented
these four bills in the system.
The other Senior Auditor (Mr.
claims.”
h) Under clause (d) of the opinion he
has referred to five possibilities. As
to the extent of responsibility of the
undersigned in this entire
unfortunate incident and under
clause (e) of the opinion he finds:-
“Only detailed forensic expertise
can decide which one of the above
possibilities is true. However, the
documentary soft and hard
evidence prove that Mr. Taimoor
Bukhari successfully persuaded
Payroll-7 section to process the
fake bills in a space of just 24
minutes either out of his own
interest to get things done or to
show compliance to the AG who
had circumstantially obliged him by
maneuvering his posting back to
AG Punjab after the disgraceful
surrender by the Ex-AG.”
i) Thus, in fact the Inquiry Officer did
not find the undersigned guilty of this
charge as well. The observations of
persuasion was never the part of the
charge and even if, without
conceding, persuasion is proved,
then the undersigned was only doing
his duty to ensure that the work of
the section is conducted smoothly
and swiftly. There is no finding that
this charge has been proved.
As at para 3(i)
corroborates your active place in AG’s focused at the mob activity on the Shehbaz) teamed up with AAO
involvement in fraud. Chamber.(Annexure-S) ground floor. who created an alarm to the
e. Mr. Taimoor Bukhari went away d. Mr. Taimoor Bukhari’s room was Additional AG/ new AG about
from the AG office at the time of upstairs. He even left his cheque paid vouchers of Walled City
commotion and did not return book behind before leaving. Project Bills after the commotion
thereafter. and change of command.
f. His room was locked and was later Interestingly, the same AAO
opened in his absence. The fake played a vital role in verifying
stamp was reportedly recovered these bills as fake from the
from the room. (Annexure-T) Project Office on 28-06-
2014 resulting in eventual
recovery from the Allied Bank of
Pakistan. When asked from the
Senior Auditor (Mr. Jawwad) by
the inquiry officer as to why he
had gone to Mr. Taimoor
Bukhari’s room precisely at the
time of commotion at ground
floor, he replied that he had
been offered cold water from the
dispenser stationed in the
locked office of Mr. Taimoor
Bukhari upstairs by his Niab
Qasid from whom he had
requested a glass of water,
when standing on ground floor.
He added that while he was
having water in Mr. Taimoor
Bukhari’s room, he noticed a
stamp on the table of Mr.
Taimoor Bukhari which later
came to be found as fake.
d. It is considered that the Senior
Auditor has concocted a story of
fake stamp presence in Mr.
Taimoor Bukhari’s room
because of the following:

vi. There was no point for the

Senior Auditor to go to Mr.
Bukhari’s room at the heat of the
moment of commotion when he
was already concerned about
the Walled City vouchers.
vii. The same AAO who created an
alarm about the vouchers of
fake claims on 27-06-2014 also
reported about the fake stamp.
viii. Going upstairs merely for water
in a locked room appears to be
 farfetched.
ix. Recovery of same stamp has
been mentioned by the CGA in
her letter to NAB dated: 01-07-
2014 as having been found from
the Chamber of the AG.
(Annexure-U)
x. Mr. Taimoor Bukhari could have
easily removed the stamp before
running away from AG office on
27-06-2014 at the time of
commotion.

5. Para 3(v) of charge sheet:
You collaborated with the team of
private persons and officials of
Accountant General Punjab
malafide deployed by Mr. Zahhid
Rasheed in order to create a rush
and an environment of fear in the
office so as to get the things done
accordingly to your whims.
d. Ever since Mr. Zahhid Rasheed
took over the charge as AG
(Punjab) on 22-05-2014, he
employed various tactics to
strengthen his control over the
office and one of those was
deployment of several guards /
private persons in various sections
to watch and monitor swift
implementation of his commands.
(Annexure-V)
e. These guards / persons might also
be armed as evident from the
statement of an official of AG
Punjab. (Annexure-W).
f. These guards / persons also
occupied the Rest House in AG’s
office premises.
vi.
vii.
viii.
ix.
f. Mr. Taimoor Bukhari was in charge
of Admin Section. (Annexure-X)
g. The AG office was conscious of
the relationship of Mr. Taimoor
Bukhari with Mr. Zahhid Rasheed
from the day when Mr. Taimoor
Bukhari was in charge of DAOs
Coord cell under DG Accounts
because of which he was
surrendered by Mr. Idrees Tarar
the Ex-AG.
h. Any command of the AG
communicated by Mr. Taimoor
Bukhari even verbally was taken
seriously by the officials as evident
from the handover of token
punching machine by cheque
section on 16-06-2014 on verbal
command.
i. Free movement of private persons
and guards and its negative effect
on the office should have been a
concern for the admin section.
j. The creation of environment of
fear due to presence of guards
and private persons is reflected in
the events which took place during
the six week tenure of Mr. Zahhid
Rasheed as AG Punjab, such as:-
All Accounts Officers of AG Punjab
applied for leave to the AG.
(Annexure-Y)
Sudden mob activity /commotion
on 27-06-2014.
Presence of Police at the time of
commotion
Departure of the AG under police
b. The manner in which Mr.
Taimoor Bukhari joined AG
Punjab, attained the charge of
important sections, conveyed
the command of the AG,
facilitated the handover of the
punching machine, persuaded
payroll-7 to pass the bills of M/S
Qavi Engineering in the
presence of private guard, his
sudden disappearance from the
office of AG Punjab during
commotion, his choice not to
attend the office after joining of
new AG, his perception of life
threat etc. provide sufficient
circumstantial evidence that Mr.
Taimoor Bukhari facilitated Mr.
Zahhid Rasheed in creating an
environment in AG Punjab in
June 2014 which was conducive
to his (Mr. Zahhid Rasheed)
interests and motives as
reflected in passage of four fake
bills of Rs. 104 million and
possible attempt of clearance of
19 bills of Rs. 383 million.
You collaborated with the team of
private persons and officials of
Accountant General Punjab mala fide
deployed by Mr. Zahid Rasheed in
order to create a rush and an
environment of fear in the office so as
to get the things done according to
your whims.
(a) The portion of the opinion under (a)
as to the manner in which the
undersigned attained the charge of
important section etc. was wholly
uncalled for after Charges (i) and
(iv) he himself held as not proved
and regarding other charges there
is no finding that these charges
stood proved.
(b) That, in any case, the charge was
too vague to merit consideration,
inasmuch as, that the stated team
of private persons and officials of
the Accountant General remain
unidentified and also that there was
no evidence whatsoever that the
undersigned was responsible for
commotion of 27th June,
2014.Rather, the charge itself says
that these private persons and
officials were deployed by Mr.
 protection after the employees
reportedly threatened to physically
assault him during commotion.
x. Occupation of rest house and
DG’s office by these persons.
Zahid Rasheed. The only allegation
against the petitioner was of
collaboration, but neither any overt
act was attributed to the petitioner
nor was there any evidence to
substantiate this charge. (emphasis
supplied)

(c) Under finding at (a), the Inquiry

Officer declared the undersigned as
Incharge of Admin Section. This is
not correct. The overall incharge of
the Administration of the A.G. Office
is one PAAS, BS-19 Officer, i.e.,
Additional Accountant General
(Admin).

(d) The very charge, itself, is that

private persons and officials of the
Accountant General were deployed
by Mr. Zahid Rasheed, the then
Accountant General. In fact they
were deployed by the then
Accountant General on 23.5.2014
while the undersigned had joined the
Office on 4.6.2014. Thus, the
undersigned could not be blamed for
outside influence. It was the
previous administration who had
facilitated their presence in the office
for which the undersigned could
hardly be blamed. However, even
that finding was demolished by the
Inquiry officer himself when under
clause (e) he established the
responsibility of this charge on Mr.
Zahhid Rasheed, the then
Accountant General, Punjab.
 Office of the

Auditor General of Pakistan

Constitution Avenue, Islamabad

No. 213–Dir(A)/11-321/Discip/2015 Dated: 01.09.2016

Syed Taimoor Bukhari,

Assistant Controller Military Accounts (Lahore Command),
(Under Suspension),
O/o Controller Military Accounts, Lahore.

Syed Taimoor Bukhari,

135-J-II, Johar Town,
Lahore.
Phone: 0300-9453254

SUBJECT: PERSONAL HEARING

Please refer to your reply to the Show Cause Notice bearing No. 159-
Dir (A)/11-321/Discip dated 01.08.2016.

2. The Deputy Auditor General (A&C), being the Authorized Officer has
been pleased to give you the opportunity of personal hearing on 02.09.2016 at 1400
hours (Friday).

3. It is therefore, requested to appear before the Deputy Auditor General

(A&C), Islamabad on the said date and time positively.

(Rana Shakeel Asghar)

, Director (Legal)

Copy to:

1. SPS to the Deputy Auditor General (A&C)

 BRIEF OF THE CASE SYED TAIMOOR BUKHARI,
AGAINST
EX-ASSISTANT ACCOUNTANT GENERAL, BS-17 PA&AS (UNDER
SUSPENSION)

1. It is submitted that O/o the CGA, Islamabad a forwarded request of

Accountant General Punjab to this office to initiate disciplinary
proceedings against Syed Taimoor Bukhari, Ex-Assistant Accountant
General, BS-17/PA&AS officer along with statement of allegations and a
draft of Charge Sheet due to misconducts under Rule 5 of the
Government Servants (Efficiency & Discipline) Rules, 1973 and requested
to initiate disciplinary proceedings under the Government Servants
(Efficiency & Discipline) Rules, 1973 against the accused .

2. As such a Charge Sheet was issued dated 05.11.2015 to the accused officer
(presently under suspension) and Mr. Masood Akhtar Sherwani, Dy.MAG was
appointed as Inquiry Officer to conduct the proceedings against the officer vide
order dated 05.11.2015. Charge Sheet was received back on 16.11.2015 un-
delivered due to non-availability of the accused on his address and again
dispatched on 25.11.2015 and the same was received by the accused. Afterwards
the accused sent his request that he had not received the charge sheet and order
of inquiry and provided a new address and a photocopy of the same material was
again dispatched through TCS on his new given address on 30.12.2015 which
was delivered to him. The accused officer had submitted his defence reply to the
charges leveled against him to the Inquiry Officer on 11.01.2016. The inquiry
report and the findings of the Inquiry Officer has also been gone through. It
appears that out of five (05) charges contained in the Charge Sheet issued on
05.11.2015, three (03) charges are proved through evidence. One charge i.e.
Charge No. 1 is only circumstantially proved but could not be proved through
evidence as the same required answer of the questionnaire sent by the Inquiry
Officer to the then Director (Admn) of AGP Office.

3. The inquiry officer concluded in his findings as ‘‘Mr. Taimoor Bukhari was
surrendered by the AG when he was on probation. He joined back after the AG
who surrendered him had been replaced. With such a short experience of working
in AG Punjab, he was not expected to be at the center of such a mess in June
2014 which brought the highly respected organization of AG Punjab to open
disrepute. In deed out of his free will, he allowed himself to be used as a pawn by
the others for their own larger interest at the cost of his career and reputation.
Borrowing words from Mr. Idrees Tarar are that “it was unbecoming of a PA&AS
officer. He deserves a psychological make over under a professional mentor’’.

4. The accused officer has now replied to the Show Cause Notice of dated
01.08.2016 which was forwarded to him along with copy of inquiry report
and upon his request the Authorised Officer has given a chance of
personal hearing on 02.09.2016 vide letter dated 01.09.2016 accordingly.
MINUTES OF THE PERSONAL HEARING TO SYED TAIMOOR BUKHARI (BS-
17/PA&AS) IN SHOW CAUSE NOTICE DATED 01.08.2016

An opportunity of personal hearing was given to Syed Taimoor Bukhari

(BS-17/PA&AS), Ex-Assistant Accountant General, O/o the AG, Punjab, Lahore
on 02.09.2016 at 1400 hours in my office as requested by the officer in his reply
to the Show Cause Notice No. 159-Dir (A)/11-321/Discip/15 dated 01.08.2016
received on 25.08.2016 in accordance with Rule 6 (2) of Govt. Servants (E&D)
Rules, 1973.

2. The officer at the very start denied all the charges levelled again him and
stated that he is being victimized by the Department. He has done nothing wrong.
However, when asked about his surrender from AG Office by the Ex-AG Punjab
and transfer back to the AG Punjab when Mr. Zahhid Rasheed took over the
charge of AG Punjab he explained that he was transferred by Mr. M.S. Idrees
Tarar (Ex- AG Punjab) due to his closeness with Mr. Zahhid Rasheed (the then
DG DAOs). Therefore, when Mr. Zahhid Rasheed took charge of AG Punjab, he
got him transferred back to AG Punjab office to compensate the act of previous
AG Punjab Mr. M.S. Idrees Tarar.

3. The officer denied the charge of taking possession of token punching

machine and stated that it was with the Cheque Section throughout the month of
June, 2014. However, the statement of Accounts Officer Cheques shows that the
machine was handed over to Mr. Bukhari on verbal orders of Ex-AG Punjab Mr.
Zahhid Rasheed.

4. The officer denied the charges of compelling the staff of Pay Roll-VIII
Section to process fake bills. However, he admitted that he conveyed the verbal
orders of AG Punjab Mr. Zahhid Rasheed to process the bills on fast track. He
further stated that he did not ask the staff to ignore pre-audit checks. It is notable
here that he himself did not applied the pre-audit checks before possessing these
bills for payment.

5. About the charge of fake stamps and fake bills found in his possession, he
denied the charge and stated that had he known about the bills, he would have
destroyed then rather than leaving on his table. However, it is also fact that he
had to leave his office in hurry as he admitted that DAG Mr. Shozab advised him
to leave immediately due to unrest and development of law and order situation in
the office. Therefore, the possibility of leaving such documents on the table could
not be over ruled.

6. As far as the presence of private persons in the office premises and

creation of environment of fear due to open exhibition of Arms and Ammunitions
is concerned, the officer admitted that such persons were present in the office
premises as guards of the Ex-AG Punjab Mr. Zahhid Rasheed and he knew all
these persons.

7. The officer was further asked about the possible role of the Ex-AG Punjab,
Mr. Zahhid Rasheed in the processing of fake bills and fraudulent payments, he
said that he did not know about the previous history of Mr. Zahhid Rasheed, but
after this incident he was much disturbed and disappointed and he said that “it is
not worth to call him even a human being”. He further stated that Mr. Zahhid
Rasheed gets himself clear by involving the other innocent persons.

(Dr. Waheed Ahmed)

Deputy Auditor General (A&C)/
(Authorized Officer)
 TO BE PUBLISHED IN PART-I OF THE GAZETTE OF PAKISTAN

DEPARTMENT OF THE
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue,
ISLAMABAD

Dated: 09.09.2016

NOTIFICATION
No. 221–Dir(A)/11-326/Discip/15. Having been found guilty of the
charge of “Inefficiency” “Misconduct” and “Corruption” contained in the
Show Cause Notice bearing No.159/Dir(A)/11-321/Discip/15 dated
01.08.2016, the Auditor General of Pakistan in exercise of powers conferred
on him by Rule 3 (a) (b) & (c) read with Rule 5 (1) (iv) of Government
Servants (Efficiency & Discipline) Rules, 1973 has been pleased to impose
the major penalty of “Dismissal from Service” in terms of Rules 4 (1) (b) (iv)
of aforesaid Rules upon Syed Taimoor Bukhari, a BS-17, Officer of
Pakistan Audit and Accounts Service (under suspension) with immediate
effect.

(RANA SHAKEEL ASGHAR)

Director (Admn-I)

The Manager,
Printing Corporation of Pakistan Press,
Karachi.

Copy to:-
1. The AGPR, Islamabad
2. The AGPR, Sub-Office, Lahore
3. SPS to Auditor General of Pakistan
4. SPS to Addl. Auditor General of Pakistan-I
5. SPS to Addl. Auditor General of Pakistan-II
6. The Controller General of Accounts, Islamabad
7. The Military Accountant General, Rawalpindi
8. The Accountant General of Punjab, Turner Road, Lahore
9. PS to Deputy Auditor General (A&C) Local
10. Syed Taimoor Bukhari, a BS-17/PA&AS, 135-J-II, Johar Town,
Lahore
11. The Audit Officer PAAS-I, Local
12. The Audit Officer PAAS-II, Local
13. The Audit Officer, (Confidential) Local
14. Notification File
STATEMENT OF PARAWISE COMMENTS ON THE REPRESENTATION TO THE PRIME MINISTER OF PAKISTAN SUBMITTED BY SYED TAIMOOR BUKHARI, BPS-
17 EX-OFFICER OF PAKISTAN AUDIT & ACCOUNTS SERVICES WHO HAS BEEN DISSMISSED FROM SERVICE W.E.F. 09.09.2016
SR.
CHARGE/ALLEGATION
# OFFICER
1 You with the connivance of Mr.
Zahhid Rasheed the then
Director General DAO’s (OPS)
got yourself posted back as
Assistant Accountant General,
whereas you already had been
surrendered on account of
misconduct from the office of
Accountant General Punjab.
CONTENTION OF THE ACCUSED COMMENTS BY THE
INQUIRY OFFICER’S FINDINGS REMARKS
DEPARTMENT
a. The Charge Sheet mentions the Charge (i) was clearly held by the Untoward incidents
cause of surrender of the officer Inquiry Officer to have not been happening in the office of
out of AG Punjab by Mr. Idrees proved. the of the Accountant
Tarar AG Punjab, as General Punjab during the
misconduct. Evidently, this month of June, 2014 and
charge was not communicated the acts of faithfulness
to the accused officer before exhibited by Syed Taimoor
this charge sheet. Therefore, Bukhari proved to be a right
the accused has responded that hand man of Mr. Zahhid
he has no knowledge about his Rasheed which has
surrender in January 2014 by protracted a bad name to
the then AG as a cause of his that officer as well as for
transfer out of AG Punjab. the whole Department.
b. It is viewed that the choice of
words made by Mr. Idrees Tarar
in his letter dated: 31-12-2013
(Annexure-A) clearly indicates
the AG’s uneasiness in regard
to officer’s style of working
under the then DG Accounts
who was the overall in charge
of DAOs. The latter happenings
in AG Punjab during the month
of June and the acts of utter
faithfulness exhibited by Mr.
Taimoor Bukhari to Mr. Zahhid
Rasheed as AG Punjab,
however do provide a

2 You obtained the possession of a. The statements of officers and
token punching machine in
complete disregard to standard
operating procedures, during
the month of June, 2014.
b. Some level of control over the
semblance of his possible
connivance with Mr. Zahhid
Rasheed for his reposting, but
cannot be proved through
evidence, unless the former Dir.
Admin disclose it.
officials indicate that the AG’s
orders regarding shift of
possession of the token punching
machine w.e.f 16-06-2014 was
verbally conveyed through Mr.
Taimoor Bukhari, otherwise these
would not have gained enough
strength for the cheque section to
follow the same. These
statements do not indicate that
the orders came directly from the
AG but do indicate via media of
Mr. Taimoor Bukhari .It is viewed
that in order to possess full
control over the bills to be
punched after 16-06-2014, the
influence of the cronies of the AG
over the token machine was
necessary and possibly it was got
done by the AG through Mr.
Taimoor Bukhari. It however does
not verify that the machine was in
physical possession of the
accused officer.
machine in last days of June by
the administration is usual but
control of an outside agent of the
(i) As far the law laid down by As the Inquiry Officer has
the Superior Courts and the Service held that order of shifting of
Tribunal, the charge had to be the token punching
proved and not something which machine was verbally
was not part of the charge-sheet. conveyed by Syed Taimoor
The finding of the Inquiry Officer Bukhari as such
was that:- Department is of the view
that this misdeed occurred
“The punching machine was with the collaboration of the
under the direct influence of the Syed Taimoor Bukhari as is
outsider namely Shakeel Ahmad, evident from the statement
installed by the AG”. of the officer/officials of
Office of the Accountant
This finding conclusively defeats the General of Punjab, Lahore.
charge. The possession of token
machine was used for
(ii) According to the Bill punching the bogus bills
Tracking Report (BTR) Mr. Sajjad which was proved
Shah had punched the tokens, who circumstantially.
holds regular charge of punching
bills. There is no irregularity in this
regard. The only evidence for this
charge comes from Mian Ahmad
Saeed, the AO, Cheque Section.
His (Mian Ahmed Saeed) statement
also does not support the charge as
framed or that the appellant had
even facilitated handing over of the
Token Punching Machine to an
AG in June 2014 is unusual. outsider.

(iii) According to the IO, orders

regarding token machine were
communicated through the
appellant, which is wholly incorrect.
The A.O. Cheque stated that the
machine was handed over to Rana
Shakeel on the verbal orders of the
then Accountant General conveyed
by one Mr. Muzaffar Shah. This
clearly falsifies the findings of the
IO. Muzzafar Shah has contradicted
his(AO Cheque) statement by
stating that he asked the AO cheque
to hand over the token machine to
the “authority concerned” and not to
any outside agent. Surprisingly the
IO, despite recording the statement
of Muzzafar Shah, has not made it
part of the inquiry report for the
reasons best known to him.

(iv) While appearing before the

Investigating Officer of the NAB, the
AO cheque took a different position
and stated that the appellant
conveyed the order of the
Accountant General through
Muzaffar Shah to handover the
machine to the “concerned
authority” on 16.06.2014. It is worth
mentioning here that the appellant
neither passed any such order nor
did the AO cheque confirmed the
same from the appellant, thus, he
relied on hearsay. Above all, this
contradiction makes the two
statements as mutually destructive
which is enough to make AO
cheque a liar of his own statements.
However, one thing which is
positively established is that at no
stage the token machine was ever
in possession of the appellant as
alleged in the charge. The allegation
of conveying the message by the
appellant was false and fabricated.

Interestingly , 16.06.2014 was the

last date for submission of bills
after which the token punching
on the bills was supposed to be
stopped as per instruction of the
Finance Department Government
of the Punjab and the AG.
Banners were placed at various
places inside and outside of the
premises of the AG office as per
years long practice. Moreover,
the AO cheque section, himself,
is the relevant authority and
custodian of the said machine.

(v) The Inquiry Officer clearly

found that the machine was not in
physical possession of the appellant
and also confirmed the
aforementioned SOP that:-

“Some level of control of the

machine in the last days of June
by the administration is usual but
control of an outside agent of the
 AG in June, 2014 is unusual”.
(emphasis supplied).

(vi) Sajjad Shah, who punched

the token clearly admitted that it was
Mr. Shakeel, a private person
representing the then Accountant
General, at whose asking he had
punched the four bills. No
proceedings against him have ever
been initiated against him.
(underlined to emphasize)

(vii) The charge is not supported

by any evidence and the ultimate
finding of the Inquiry Officer is that
“It however, does not verify that
the machine was in physical
possession of the accused
officer” (underlined to supply
emphasis). With the above findings,
the Inquiry Officer did not held that
Charge No.(ii) stood proved against
the appellant. However, the findings
recorded by the Inquiry Officer left
no manner of doubt that this charge,
as brought, (underlined to
emphasize) was not proved.

3 You compelled your staff in a. The chain of events ranging (i) As far the charge as framed Being fully aware about the
Payroll-7 Section to process the from punching of token on is concerned, as per the Inquiry fake bills he pressed to the
counterfeited bills without these four fake bills of the Officer’s findings and observations, dealing staff to process
exercising proper pre-audit “Walled City Project” to the it was not proved. Nor the Inquiry those bills expeditiously
checks which confirm your physical presence of these Officer has held the charge to have due to lack of experience
willful involvement in processing paid vouchers in the AG’s been proved. Instead, the operative and caused attributes
the counterfeited bills in Chamber proves a nexus of finding is that the appellant towards such a bills of
connivance with the then common interest between all “successfully persuaded Payroll-7 heavy amounts.
Director General/Accountant
General (on look after basis).
b. While the AAO and the
those who processed,
possessed and sought for
the same. However, what
surprises is a common
experience that usually the
culprits of such wrong doing
(Passing a fake bill) either do
not paste their original
signature on fake bills or
vanish the same immediately
after issue of cheque to
remove any evidence of their
wrong doing. This has not
happened. All the concerned
officers of Payroll-7 have
signed the bills. They have
entered them into system
using their own ID. The AAO
created an alarm at the time
of commotion (which took
place in the chamber of the
AG on 27-06-2014 resulting
in change of command of
AG) by informing the
Additional AG and the new
AG about the possibility of
something fishy about these
bills, emanating from
presence of their paid
vouchers on the AG’s table.
Auditor remained in the
office taking possession of
these vouchers and possibly
questioning genuineness of
the bills (and verifying the
Section……...” The IO has failed to As pointed out by the
appreciate the fact that it comes Inquiry Officer that his blind
under the duty of the appellant to compliance to the system
pursue the timely disposal of the all installed by the then
the bills. Accountant General which
allowed such a fake bills as
(ii) Mr. Jawad Qamar, the KPO, of Walled City Project to
who is not an accused, had also find easy access to the
been examined. He falsely stated Government wallet
that the appellant handed over to unhindered and to
him five bills. So far recovery of unhurdled.
stamp is concerned in charge
No.(iv),the Inquiry Officer held that
the said charge was concocted by
Mr. Jawad-ul-Qamar. He has been
proved to be liar by his own
showing. His malice towards the
appellant is explicit. His evidence
could hardly furnish any basis for
extreme action against the
appellant.
(iii) The finding of persuasion
does not amount to compelling the
concerned officials to process those
bills. The other witnesses examined
in support of this charge were
Shahbaz Qamar, Senior Auditor,
and Arshad Iqbal, Assistant
Accounts Officer. They were, in fact,
the persons responsible for this
unfortunate happening. They are
also being proceeded against under
the Efficiency and Discipline Rules.
So, their testimony is tainted with
very strong bias to make the
appellant a scapegoat. Please see
 same on following day), Mr.
Taimoor Bukhari did not
bother to come to the AG
office after the commotion
and change of command. In
his statement to the inquiry
officer, he claims that he did
not do that due to perceived
threat to his life.(Annexure-
R)
c. It is obvious that pre audit
checks were not exercised at
any level. The section should
have been conscious that
both the AAO and Assistant
AG were just recently posted
in the section and therefore
lacked experience of the
work of the section. They
should have applied
substantive checks before
admitting the claims.
d. There are various
possibilities;
I. Mr. Taimoor Bukhari knew that
the bills were fake and yet
processed them.
II. He got them processed
expeditiously due to lack of
experience because he did not
know what checks to be applied.
III. He got the bills processed to
appease the AG and to show his
utter faithfulness without realizing
about nature of bills.
RaiShabbir AhmadVs.
Government of Punjab {1981 PLC
(CS)755} and Sarfraz KhanVs.
Water and Power Development
Authority and 2 others {1991 PLC
(CS)9} regarding the evidentiary
value of a co-accused in
departmental proceedings. Thus,
there was no reliable and
independent witness in support of
this charge. As Section Incharge,
the appellant could supervise and
ensure that the work of the section
runs smoothly. Particularly, it was
the month of June, the end of
financial year and burden of work
had increased.
(iv) That the Inquiry officer drew
a totally baseless inference from the
fact that the processing of the bill
was completed in 24 minutes. (It
was not part of the charge).
However, he has not tried to find out
that processing of many other bills
was completed even before 24
minutes. In their statement before
the Inquiry Officer the AAO and the
Senior Auditor have admitted that
they were never asked to ignore
pre-audit checks rather they
admitted that they were asked to
process the bills swiftly and that
comes within the scope of the duty
of the appellant as a Section
Incharge, particularly in view of the
IV. He authorized the bill on behalf of fact that on 23.6.2014, on the
AG on the trust that he would complaint of Mr. Kamran Lashari,
sign the same. the Director General of the Walled
V. He was confident that either the City Project Authority, the Senior
wrong payment would not be Auditor and AAO were changed and
detected and even if detected the additional charge of the post of
vouchers would not be found to Incharge Payroll-7 was given to the
fix responsibility. appellant to look after the duties of
the said section. The appellant was
posted to this section on 23.6.2014
e. Only detailed forensic expertise
while this unfortunate incident of
can decide which one of the
passing of bills was of 26.6.2016,
above possibilities is true.
only after two days of appellant’s
However, the documentary soft
taking over charge of this section,
and hard evidence prove that
and during these two days the
Mr. Taimoor Bukhari
appellant did not even know any
successfully persuaded Payroll-7
staff member personally and,
section to process the fake bills
therefore, the suspicion of the
in a space of just 24 minutes
Inquiry Officer that he might have
either out of his own interest to
been part to these irregularities is
get things done or to show
farfetched and speculative only.
compliance to the AG who had
circumstantially obliged him by
(v) The bills were allotted token
maneuvering his posting back to
on 25.6.2014 and not on 26.6.2014
AG Punjab after the disgraceful
as assumed by the Inquiry Officer to
surrender by the Ex-AG.
draw a totally baseless inference
f. Mr. Taimoor Bukhari could claim
that the bills were processed with
a benefit of doubt on account of
undue haste. This clearly denotes
lack of experience, but is
the lack of perusal and appreciation
ineligible on account of his blind
of the record/evidence on the part of
compliance to the system
the IO. The pre-audit checks, which
installed by the then AG which
according to the Inquiry Officer were
allowed such fake bills, as of
overlooked, did not come within the
Walled City Project, to find easy
purview of the responsibility of the
access to the Government’s
appellant. The Senior Auditor and
wallet unhindered and
the AAO are100% responsible for
unhurdled.
verification of signatures of the
presenter, totals, classification,
budget allocation and scrutiny of the
sanction. They clearly admitted that
they were never asked to bypass or
ignore any pre-audit check. The
finding of the Inquiry Officer that the
pre-audit checks were not properly
applied, clearly means that the AAO
and the Senior Auditor failed to do
their duty. Thus, the evidence
brought on the record does not
substantiate the charge against the
appellant nor the Inquiry Officer has
so found.

(vi) In the inquiry report under

the Efficiency and Discipline Rules
against Mr. Arshad Iqbal AAO, the
Inquiry Officer, Mr. Hamza Ali, a
PAAS (BS-17 Officer) has found:-

“It is pertinent to mention here

both Senior Auditor, Mr. Shahbaz
Qamar and Assistant Accounts
Officer Mr. Arshad Iqbal have
alleged that they failed to perform
their duty due to pressure from
Mr. Taimoor Bukhari, the then
AAG. However, during the course
of inquiry, they have not been
able to successfully prove their
allegation through an objective
and substantial piece of evidence
to completely rule out their failure
to stop the fraudulent claims.”
(vii) Under clause (d) of the
opinion he has referred to five
possibilities as to the extent of
responsibility of the appellant for this
entire unfortunate incident and
under clause (e) of his opinion he
holds:-

“Only detailed forensic expertise can

decide which one of the above
possibilities is true. However, the
documentary soft and hard evidence
prove that Mr. Taimoor Bukhari
successfully persuaded Payroll-7
section to process the fake bills in a
space of just 24 minutes either out
of his own interest to get things
done or to show compliance to the
AG who had circumstantially obliged
him by maneuvering his posting
back to AG Punjab after the
disgraceful surrender by the Ex-
AG.”

Although appellant’s posting was

subject matter of charge No.(i)
which in fact is held not to be proved
by the Inquiry Officer.

(viii) Thus, in fact the Inquiry

Officer did not find the appellant
guilty of this charge as well. The
observation of “persuasion” was
never the part of the charge and
even if, without conceding,
persuasion is proved, then the
appellant was only doing his duty to
 ensure that the work of the section
is conducted smoothly and swiftly.
There is no finding that this charge
has been proved. The inquiry officer
totally kept out of consideration that
there were more than twenty bills
presented by the Walled City Project
Authority which were followed up by
the appellant in good faith because
the said authority had some
complaints regarding their previous
bills (of undue delay) and not only
these four particular bills. Therefore,
the instructions to dispose of the
work in time were general in nature
and in accordance with the job
description of the appellant. Hence
the finding of the inquiry officer that
the appellant persuaded Payroll-7
Section only for the process four
fake bills, stands vitiated. (Extract of
the job description of the appellant
is enclosed as Annex “B”)

4 You were found to be in a. The first report about the Charge (iv) was clearly held by the This charge is also a chain
possession of fake stamps of the presence of the fake stamp Inquiry Officer to have not been of previous charge which is
vendors, in whose name the came from the Senior Auditor proved. itself an attempt to prepare
fake bills were got prepared and (Mr. Jawwad)of Payroll-7 section the bogus bills and stamp
processed. This further who had documented these four those bills with his own
corroborates your active bills in the system. The other hands
involvement in the fraud. Senior Auditor (Mr. Shehbaz)
teamed up with AAO who
created an alarm to the
Additional AG/ new AG about
paid vouchers of Walled City
 Project Bills after the commotion
and change of command.
Interestingly, the same AAO
played a vital role in verifying
these bills as fake from the
Project Office on 28-06-2014
resulting in eventual recovery
from the Allied Bank of Pakistan.
When asked from the Senior
Auditor (Mr. Jawwad)by the
inquiry officer as to why he had
gone to Mr. Taimoor Bukhari’s
room precisely at the time of
commotion at ground floor, he
replied that he had been offered
cold water from the dispenser
stationed in the locked office of
Mr. Taimoor Bukhari upstairs by
his Niab Qasid from whom he
had requested a glass of water,
when standing on ground floor.
He added that while he was
having water in Mr. Taimoor
Bukhari’s room, he noticed a
stamp on the table of Mr.
Taimoor Bukhari which later
came to be found as fake.
b. It is considered that the Senior
Auditor has concocted a story
of fake stamp presence in Mr.
Taimoor Bukhari’s room
because of the following:

i. There was no point for the

Senior Auditor to go to Mr.
Bukhari’s room at the heat of
 the moment of commotion
when he was already
concerned about the Walled
City vouchers.
ii. The same AAO who created
an alarm about the vouchers
of fake claims on 27-06-2014
also reported about the fake
stamp.
iii. Going upstairs merely for
water in a locked room
appears to be farfetched.
iv. Recovery of same stamp has
been mentioned by the CGA
in her letter to NAB dated: 01-
07-2014 as having been
found from the Chamber of
the AG. (Annexure-U)
v. Mr. Taimoor Bukhari could
have easily removed the
stamp before running away
from AG office on 27-06-2014
at the time of commotion.

5 You collaborated with the team
of private persons and officials
of Accountant General Punjab
malafide deployed by Mr. Zahhid
Rasheed in order to create a
rush and an environment of fear
in the office so as to get the
things done according to your
whims.
a. The manner in which Mr.
Taimoor Bukhari joined AG
Punjab, attained the charge of
important sections, conveyed
the command of the AG,
facilitated the handover of the
punching machine, persuaded
payroll-7 to pass the bills of M/S
Qavi Engineering in the
presence of private guard, his
sudden disappearance from the
office of AG Punjab during
(i) That the portion of the
opinion under (a) of this charge as
to the manner in which the
appellant got the charge of
important section etc. was wholly
uncalled for after Charges (i) and
(iv) were held not proved and
regarding other charges there is no
finding that these charges stood
proved.
(ii) That the circumstances
As Syed Taimoor Bukhari
has provided sufficient
circumstantial evidence that
he facilitated Mr. Zahhid
Rasheed in creating an
environment in Accountant
General Punjab, Lahore
which was conducive to Mr.
Zahhid Rasheed for his
interests as reflected in
passage of four bills of Rs.
104 Millions and possible
commotion, his choice not to
attend the office after joining of
new AG, his perception of life
threat etc. provide sufficient
circumstantial evidence that Mr.
Taimoor Bukhari facilitated Mr.
Zahhid Rasheed in creating an
environment in AG Punjab in
June 2014 which was
conducive to his (Mr. Zahhid
Rasheed) interests and motives
as reflected in passage of four
fake bills of Rs. 104 million and
possible attempt of clearance of
19 bills of Rs. 383 million.
relied upon to make adverse attempt of clearance of 19
observation against the appellant bills of Rs. 383 Millions.
were not at all supported by any
evidence except the conjectures
and surmises of the Inquiry Officer
which shows his biased and malice
against the appellant.
(iii) That, in any case, the
charge was too vague to merit
consideration, inasmuch as, that
the stated team of private persons
and officials of the Accountant
General remain unidentified and
also that there was no evidence
whatsoever that the appellant was
responsible for commotion of 27th
June, 2014. Rather, the charge
itself says that these private
persons and officials were
deployed by Mr. Zahid Rasheed
Ex-Accountant General. The only
allegation against the appellant was
of collaboration, but neither any
overt act was attributed to the
appellant nor was there any
evidence to substantiate this
charge. (emphasis supplied)
(iv) Under finding at (a), the
Inquiry Officer declared the
appellant as Incharge of Admin
Section. This is not correct. The
overall incharge of the
Administration of the A.G. Office is
one PAAS, BS-19 Officer, i.e.,
Additional Accountant General
(Admin).

(v) The very charge, itself, is

that private persons and officials of
the Accountant General were
deployed by Mr. Zahid Rasheed,
the then Accountant General. In
fact they were deployed by him on
23.5.2014 while the appellant had
joined the Office on 4.6.2014.
Thus, the appellant could not be
blamed for outside influence. It was
the previous administration who
had facilitated their presence in the
office for which the appellant could
hardly be blamed. However, even
that finding was demolished by the
Inquiry officer himself when under
clause (e) he established the
responsibility of this charge on Mr.
Zahid Rasheed, the then
Accountant General, Punjab. Also,
the IO did not give any citing of
collaboration of the appellant with
the private team of Mr. Zahid
Rasheed. (emphasis supplied)

6. That the observation of the

Inquiry Officer that “He (appellant)
deserved a psychological make
over…” is wholly incorrect. It is
clearly in excess of scope of the
inquiry and is wholly uncalled for
and, therefore, is liable to be
expunged. It only reflects his bias
and malice.
7. In Tribhuban Parkash Vs.
India (AIR 1970 S.C.540), the
Indian Supreme Court held that
unless there is legally admissible
evidence, the conclusions could not
be based on conjectures, surmises
and suspicions. The Honourable
Supreme Court of Pakistan in
Samiuddin QureshiVs. Collector
of Customs (PLD 1989 S.C.335)
referred to this judgment reiterated
this principle in para-10 of the
Judgment which is reproduced
hereunder:-

“To dismiss a civil servant or for that

matter, any employee on a charge
of taking bribe or misconduct is as
serious a matter as convicting a
person for a crime because his
whole career is ruined. Therefore,
the order of dismissal must be
based on some evidence.”

8. In Samar PeraizVs. Board

of Intermediate and Secondary
Education, Lahore and others
(PLD 1971 S.C.838), it was held:-

“A Tribunal’s decision must rest not

on suspicion but upon legal
grounds established by legal
evidence”.

9. In view of the above, it is

respectfully prayed that the appeal
against the order dated 09.09.2016
Dismissing the appellant from the
service may kindly be allowed, the
said Order may be set aside, the
appellant may kindly be exonerated
from the charges and reinstated
into service with all back benefits.
The appellant may also kindly be
granted an opportunity of
personal hearing.
To,
The Honorable Prime Minister of Pakistan,
Prime Minister's Secretariat,
Islamabad.
(Appellate Authority for BPS-17 to 19)

Through: Office of Auditor General of Pakistan, Audit House, Constitution Avenue, Islamabad.

Sub: Departmental Appeal under Section 3 of the Civil Servants (Appeal) Rules, 1977 against
the Order of "dismissal from service" passed by the Auditor General of Pakistan on the
basis of evidence derived without administering any oath to any of the witnesses, on the
basis of hearsay evidence and without following the mandatory procedure as laid down in
Rule 6 of the Government Servants (Efficiency & Discipline) Rules, 1973.

Ref: Order of Dismissal From Service bearing No.221-Dir(A)/11-326/Discp/15 dated

09/09/2016 received by the Appellant on 15/09/2016 (ANNEX-A)

Respectfully Sheweth:
SUMMARY OF THE SUBMISSIONS

1. That except the appellant, no action has so far been taken against any other person
actually responsible for this unfortunate incident.

2. It has been assumed in the impugned order that the appellant was guilty of corruption,
although there was neither any charge nor any evidence to support this.

3. The competent authority appears to have been influenced to the great detriment of the
appellant and since the order is based on irrelevant consideration, it stands vitiated.

4. That no witness was examined on oath.

5. That the order was not signed by the Auditor General. It is mechanical and shorn of reasons.

6. The impugned order does not show that any plea of fact or law or the Judgments of the
Superior Courts in support thereof were even considered by the competent authority.

7. No proper opportunity of defence was allowed. The witnesses produced were recorded but
their statements were not made part of the record.

8. Personal hearing granted to the appellant was perfunctory and meaningless.

9. That charges (i) and (iv) were held by the Inquiry Officer not to have been proved while
there was no finding about charges (ii), (iii) and (v) if they stand proved.

10. The adverse observations and findings relate to the matters which did not form part of the
charge-sheet. Thus, the extraneous consideration prevailed upon reason.

11. Charge (ii): Obtaining possession of Token Punching Machine: As per the findings of the
Inquiry Officer, it is not found proved.

12. Charge (iii) Processing of Bills: Three witnesses were examined in support. Out of which
two were co-accused with the appellant in the disciplinary proceedings and the third Mr.Jawad-ul-
Qamar was held to be responsible for concocting Charge No.(iv) against the appellant regarding
which the Inquiry Officer found, not to have been proved.
13. None of the witnesses provided adequate evidence to impose extreme penalty on the appellant.

14. Charge (v): It was vague. The details about the so called collaboration were not stated. The
discretion to impose a penalty cannot be exercised unless the guilt of the accused is proved by
legally receivable evidence.

15. In any case, without prejudice to the above, the penalty handed down to the appellant is
excessive.

16.The findings of the IO lack due analysis and appreciation of the record/evidence.

PRELIMINARY SUBMISSIONS

(a) That the Appellant is aggrieved by a highly illegal, unjustified and capricious order issued
by the Auditor General of Pakistan whereby he approved the orders of dismissal from service
against the Appellant on the basis of evidence derived without administering any oath to any of the
witnesses, on the basis of hearsay evidence and without following the mandatory procedure as laid
down in Rule 6 of the Government Servants (Efficiency & Discipline) Rules, 1973.

(b) That while doing so he did not even care to consult the so-called Inquiry Report wherein
despite all the subject stated and aforementioned deficiencies and illegalities, the Inquiry officer
has not proved any charge that could have remotely justified issuing such a drastic penalty.

(c) That worthy Auditor General while issuing the impugned orders also ignored the fact that
the entire proceedings against the Appellant started when an Ex-Director General of his, Mr.
Mubarak Shah (late) demanded from the Appellant an amount of Rupees 5 hundred thousand for
declaring the Appellant innocent and, thus, the Appellant informed ex-CGA, Mrs. Farah Ayub
Tarin and also shown her the text messages sent by Mr. Mubarak Shah about this, in presence of a
very senior BPS-20 Officer. The appellant presented a written application to her which she kept in
her drawer and took no action on it. The worthy Auditor General has explicit knowledge of the
above stated fact.

(d) That he even ignored the fact that the letter of appearing for personal hearing was issued on
01/09/2016 with direction to appear for personal hearing on 02/09/2016 while the notice was
received by the appellant on 06.09.2016 at his residence.

(e) That, unfortunately, the appellant has been victimized on an assumption that since he was
reposted in the Accountant General’s Office, he may have connections with Mr. Zahid Rasheed
and, therefore, the very initiation of the proceedings against the appellant suffers from malice of
the competent authority. It is worth mentioning here that the worthy Auditor General himself is the
posting/transfer authority of the appellant not Zahid Rasheed.

(f) That the charge sheet was served to the appellant after a lapse of more than 1 and half
year of the happening of so called acts of omission made part of the Charge Sheet/statement
of Allegations which makes the appellant believe that some elements in the office of the
AGP kept using their influence until the baseless charge sheet was issued.

(g) That the inquiry officer has the mandate to prove or disprove the allegations leveled
against an accused. In the instant case, the IO, instead of proving the charges, has
recommended that the appellant may be posted under a professional mentor.

2. ON GROUNDS

(i) That the impugned order of imposition of extreme penalty of dismissal is based on an
assumption that the appellant had been found guilty, inter alia, of corruption. This was neither part
of the charge sheet against the appellant nor there was an iota of evidence of corruption against the
appellant. Therefore, the order is based on an extraneous consideration which reflects strong
degree of bias against the appellant and stands vitiated. Although there is no good reason in the
order, yet even if it was there, the impugned order could not be saved by applying the doctrine of
severability and, thus, the entire order stands vitiated. Reliance is respectfully placed on
M.R.KhalidVs. Government of Pakistan {1994 PLC (C.S) 138}. In this precedent case the refusal
of proforma promotion of an officer was based on good reasons and the bad reasons but the entire
order was set aside by the learned Lahore High Court.

(ii) That no witness was examined on oath during the inquiry and in accordance with the
instructions of the Government of Pakistan as contained in the Annexure to Serial No.97 of the
Esta Code. It is fatal and because of this the entire proceedings stand vitiated.

(iii) That the impugned order has not even been signed by the Auditor General and is not a
speaking one. The order does not elaborate the events and proof of appellant’s guilt which
culminated into issuance of such an extreme order by the Authority. The appellant has reason to
believe and it is submitted with utmost respect that the worthy Auditor General has not addressed
himself carefully and properly to the issues arising in the case and has mechanically passed an
order without due application of the mind and without supporting reasons to hold the appellant
guilty and even of corruption. The impugned order betrays lack of application of mind. Reliance
may kindly be placed upon Federation of Pakistan VsTahirLatif. 2007 SCMR 152 (c).which
elaborated thatIt is the duty and obligation of competent authority to award minor punishment after
application of mind with reasons.

(iv) That the impugned order does not contain the reason on which it is based which is a blatant
contravention of Section 24-A of the General Clauses Act and, thus, stands vitiated. Please see
Muhammad Daiem ShattariVs State. 2007 YLR 2038(b) wherein the court observed “When any
Authority or Officer was empowered to make an order or give directions, such power was required
to be exercised reasonably, fairly, justly and for advancement of the purpose of enactment and
assigning reason for making such order.”

(v) In reply to the charge-sheet as well as to the show cause notice the appellant had raised a
number of serious issues with regard to the merits of the controversy and had relied upon a number
of Judgments of the Superior Courts, but, unfortunately neither any plea of the appellant has been
considered nor any Judgment of the Superior Courts has been adverted to.
(vi) That the appellant was not allowed proper opportunity of defence, inasmuch as, that a
number of documents were produced by him during the course of proceedings and three witnesses
were examined in favor of the appellant whose statements were also recorded, but for the reasons
best known to the Inquiry Officer, the statements of the witnesses produced by the appellant were
not made part of the record which also reflects a very strong bias of the Inquiry Officer against the
appellant. This has seriously prejudiced the appellant.

(vii) That the appellant has put in an unblemished record and has been declared “outstanding”
in the PER(s) and, without conceding that he was in any manner responsible for this unfortunate
incident, particularly, when the Government had suffered no loss nor there was any allegation that
the appellant acted for a motive, the extreme penalty of dismissal is harsh, excessive and amounts
to liquidating the outstanding service rendered by the appellant.

(viii) The important feature of the inquiry report is that a number factors extraneous to the
charge-sheet have been taken into consideration by the Inquiry Officer and the conclusions have
been drawn with observations which were never part of the charge-sheet and were beyond the
scope of the inquiry because at no stage the appellant had an opportunity to rebut those. Reliance
is respectfully placed on Government of PakistanVs. Farheen Rashid (2011 SCMR 1) in which a
civil servant was dismissed on the allegation which was not part of the charge-sheet and Fayyaz
Muhammad Vs. Deputy Inspector-General of Police Bahawalpur Range, Bahawalpur and
another {1973 PLC (CS)361} and Jam Muhammad Hayat JavedVs. Secretary, Government of
the Punjab, Excise and Taxation, Punjab Lahore and another {2005 PLC (C.S) 1251} in
which, instead of proof of charge, a civil servant was punished on extraneous considerations and
the Service Tribunal interfered in the matters and had set aside the impugned orders.

(ix) Charge (i) and Charge (iv) were clearly held by the Inquiry Officer to have not been
proved, while on charge No.(iv) his finding was that it was concocted by the Senior Auditor/KPO,
Jawad-ul-Qamar. As far as charges (ii), (iii) and (v) are concerned, the Inquiry Officer did not
record any finding of guilt against the appellant and, therefore, as a necessary corollary thereof,
these charges were also not proved. Without conceding the admissibility of the evidence and, if
otherwise, the credibility, it is humbly stated that the following specific discrepancies of the
evidence though illegally obtained are pointed out to prove that there was no substance in the
allegations. Hence submissions on charges are summarized as follows for your kind perusal:-

3.CHARGE ii- OBTAINING POSSESSION OF TOKEN PUNCHING MACHINE

(i) As far the law laid down by the Superior Courts and the Service Tribunal, the charge had to
be proved and not something which was not part of the charge-sheet. The finding of the Inquiry
Officer was that:-

“The punching machine was under the direct influence of the outsider
namely Shakeel Ahmad, installed by the AG”.

This finding conclusively defeats the charge.

(ii) According to the Bill Tracking Report (BTR) Mr. Sajjad Shah had punched the tokens,
who holds regular charge of punching bills. There is no irregularity in this regard. The only
evidence for this charge comes from Mian Ahmad Saeed, the AO, Cheque Section. His (Mian
Ahmed Saeed) statement also does not support the charge as framed or that the appellant had even
facilitated handing over of the Token Punching Machine to an outsider.

(iii) According to the IO, orders regarding token machine were communicated through the
appellant, which is wholly incorrect. The A.O. Cheque stated that the machine was handed over to
Rana Shakeel on the verbal orders of the then Accountant General conveyed by one Mr. Muzaffar
Shah. This clearly falsifies the findings of the IO. Muzzafar Shah has contradicted his(AO Cheque)
statement by stating that he asked the AO cheque to hand over the token machine to the “authority
concerned” and not to any outside agent. Surprisingly the IO, despite recording the statement of
Muzzafar Shah, has not made it part of the inquiry report for the reasons best known to him.

(iv) While appearing before the Investigating Officer of the NAB, the AO cheque took a
different position and stated that the appellant conveyed the order of the Accountant General
through Muzaffar Shah to handover the machine to the “concerned authority” on 16.06.2014. It is
worth mentioning here that the appellant neither passed any such order nor did the AO cheque
confirmed the same from the appellant, thus, he relied on hearsay. Above all, this contradiction
makes the two statements as mutually destructive which is enough to make AO cheque a liar of his
own statements. However, one thing which is positively established is that at no stage the token
machine was ever in possession of the appellant as alleged in the charge. The allegation of
conveying the message by the appellant was false and fabricated.

Interestingly , 16.06.2014 was the last date for submission of bills after which the token
punching on the bills was supposed to be stopped as per instruction of the Finance Department
Government of the Punjab and the AG. Banners were placed at various places inside and
outside of the premises of the AG office as per years long practice. Moreover, the AO cheque
section, himself, is the relevant authority and custodian of the said machine.

(v) The Inquiry Officer clearly found that the machine was not in physical possession of the
appellant and also confirmed the aforementioned SOP that:-

“Some level of control of the machine in the last days of June by the administration is
usual but control of an outside agent of the AG in June, 2014 is unusual”. (emphasis
supplied).

(vi) Sajjad Shah, who punched the token clearly admitted that it was Mr. Shakeel, a private
person representing the then Accountant General, at whose asking he had punched the four bills.
No proceedings against him have ever been initiated against him. (underlined to emphasize)

(vii) The charge is not supported by any evidence and the ultimate finding of the Inquiry Officer
is that “It however, does not verify that the machine was in physical possession of the accused
officer” (underlined to supply emphasis). With the above findings, the Inquiry Officer did not held
that Charge No.(ii) stood proved against the appellant. However, the findings recorded by the
Inquiry Officer left no manner of doubt that this charge, as brought, (underlined to emphasize) was
not proved
4. CHARGE (iii) - (PROCESSING OF THE BILLS)

(i) As far the charge as framed is concerned, as per the Inquiry Officer’s findings and
observations, it was not proved. Nor the Inquiry Officer has held the charge to have been
proved. Instead, the operative finding is that the appellant “successfully persuaded Payroll-7
Section……...” The IO has failed to appreciate the fact that it comes under the duty of the
appellant to pursue the timely disposal of the all the bills.

(ii) Mr. Jawad Qamar, the KPO, who is not an accused, had also been examined. He falsely
stated that the appellant handed over to him five bills. So far recovery of stamp is concerned in
charge No.(iv),the Inquiry Officer held that the said charge was concocted by Mr. Jawad-ul-
Qamar. He has been proved to be liar by his own showing. His malice towards the appellant is
explicit. His evidence could hardly furnish any basis for extreme action against the appellant.

(iii) The finding of persuasion does not amount to compelling the concerned officials to
process those bills. The other witnesses examined in support of this charge were Shahbaz
Qamar, Senior Auditor, and Arshad Iqbal, Assistant Accounts Officer. They were, in fact, the
persons responsible for this unfortunate happening. They are also being proceeded against
under the Efficiency and Discipline Rules. So, their testimony is tainted with very strong bias
to make the appellant a scapegoat. Please see RaiShabbir AhmadVs. Government of Punjab
{1981 PLC (CS)755} and Sarfraz KhanVs. Water and Power Development Authority and 2
others {1991 PLC (CS)9} regarding the evidentiary value of a co-accused in departmental
proceedings. Thus, there was no reliable and independent witness in support of this charge. As
Section Incharge, the appellant could supervise and ensure that the work of the section runs
smoothly. Particularly, it was the month of June, the end of financial year and burden of work
had increased.

(iv) That the Inquiry officer drew a totally baseless inference from the fact that the
processing of the bill was completed in 24 minutes. (It was not part of the charge). However,
he has not tried to find out that processing of many other bills was completed even before 24
minutes. In their statement before the Inquiry Officer the AAO and the Senior Auditor have
admitted that they were never asked to ignore pre-audit checks rather they admitted that they
were asked to process the bills swiftly and that comes within the scope of the duty of the
appellant as a Section Incharge, particularly in view of the fact that on 23.6.2014, on the
complaint of Mr. Kamran Lashari, the Director General of the Walled City Project Authority,
the Senior Auditor and AAO were changed and additional charge of the post of Incharge
Payroll-7 was given to the appellant to look after the duties of the said section. The appellant
was posted to this section on 23.6.2014 while this unfortunate incident of passing of bills was
of 26.6.2016, only after two days of appellant’s taking over charge of this section, and during
these two days the appellant did not even know any staff member personally and, therefore, the
suspicion of the Inquiry Officer that he might have been part to these irregularities is farfetched
and speculative only.

(v) The bills were allotted token on 25.6.2014 and not on 26.6.2014 as assumed by the
Inquiry Officer to draw a totally baseless inference that the bills were processed with undue
haste. This clearly denotes the lack of perusal and appreciation of the record/evidence on the
part of the IO. The pre-audit checks, which according to the Inquiry Officer were overlooked,
did not come within the purview of the responsibility of the appellant. The Senior Auditor and
the AAO are100% responsible for verification of signatures of the presenter, totals,
classification, budget allocation and scrutiny of the sanction. They clearly admitted that they
were never asked to bypass or ignore any pre-audit check. The finding of the Inquiry Officer
that the pre-audit checks were not properly applied, clearly means that the AAO and the Senior
Auditor failed to do their duty. Thus, the evidence brought on the record does not substantiate
the charge against the appellant nor the Inquiry Officer has so found.

(vi) In the inquiry report under the Efficiency and Discipline Rules against Mr. Arshad
Iqbal AAO, the Inquiry Officer, Mr. Hamza Ali, a PAAS (BS-17 Officer) has found:-

“It is pertinent to mention here both Senior Auditor, Mr. Shahbaz Qamar and Assistant
Accounts Officer Mr. Arshad Iqbal have alleged that they failed to perform their duty due to
pressure from Mr. Taimoor Bukhari, the then AAG. However, during the course of inquiry,
they have not been able to successfully prove their allegation through an objective and
substantial piece of evidence to completely rule out their failure to stop the fraudulent
claims.”

(vii) Under clause (d) of the opinion he has referred to five possibilities as to the extent of
responsibility of the appellant for this entire unfortunate incident and under clause (e) of his
opinion he holds:-

“Only detailed forensic expertise can decide which one of the above possibilities is true.
However, the documentary soft and hard evidence prove that Mr. TaimoorBukhari
successfully persuaded Payroll-7 section to process the fake bills in a space of just 24
minutes either out of his own interest to get things done or to show compliance to the AG
who had circumstantially obliged him by maneuvering his posting back to AG Punjab after
the disgraceful surrender by the Ex-AG.”

Although appellant’s posting was subject matter of charge No.(i) which in fact is
held not to be proved by the Inquiry Officer.

(viii) Thus, in fact the Inquiry Officer did not find the appellant guilty of this charge as well.
The observation of “persuasion” was never the part of the charge and even if, without
conceding, persuasion is proved, then the appellant was only doing his duty to ensure that the
work of the section is conducted smoothly and swiftly. There is no finding that this charge has
been proved. The inquiry officer totally kept out of consideration that there were more than
twenty bills presented by the Walled City Project Authority which were followed up by the
appellant in good faith because the said authority had some complaints regarding their previous
bills (of undue delay) and not only these four particular bills. Therefore, the instructions to
dispose of the work in time were general in nature and in accordance with the job description
of the appellant. Hence the finding of the inquiry officer that the appellant persuaded Payroll-7
Section only for the process four fake bills, stands vitiated. (Extract of the job description of
the appellant is enclosed as Annex “B”)

5. Charge (v) - (COLLABRATION)

(i) That the portion of the opinion under (a) of this charge as to the manner in which the
appellant got the charge of important section etc. was wholly uncalled for after Charges (i) and
(iv) were held not proved and regarding other charges there is no finding that these charges
stood proved.

(ii) That the circumstances relied upon to make adverse observation against the appellant
were not at all supported by any evidence except the conjectures and surmises of the Inquiry
Officer which shows his biased and malice against the appellant.

(iii) That, in any case, the charge was too vague to merit consideration, inasmuch as, that
the stated team of private persons and officials of the Accountant General remain unidentified
and also that there was no evidence whatsoever that the appellant was responsible for
commotion of 27th June, 2014. Rather, the charge itself says that these private persons and
officials were deployed by Mr. Zahid Rasheed Ex-Accountant General. The only allegation
against the appellant was of collaboration, but neither any overt act was attributed to the
appellant nor was there any evidence to substantiate this charge. (emphasis supplied)

(iv) Under finding at (a), the Inquiry Officer declared the appellant as Incharge of Admin
Section. This is not correct. The overall incharge of the Administration of the A.G. Office is
one PAAS, BS-19 Officer, i.e., Additional Accountant General (Admin).

(v) The very charge, itself, is that private persons and officials of the Accountant General
were deployed by Mr. Zahid Rasheed, the then Accountant General. In fact they were deployed
by him on 23.5.2014 while the appellant had joined the Office on 4.6.2014. Thus, the
appellant could not be blamed for outside influence. It was the previous administration who
had facilitated their presence in the office for which the appellant could hardly be blamed.
However, even that finding was demolished by the Inquiry officer himself when under clause
(e) he established the responsibility of this charge on Mr. Zahid Rasheed, the then Accountant
General, Punjab. Also, the IO did not give any citing of collaboration of the appellant with the
private team of Mr. Zahid Rasheed. (emphasis supplied)

6. That the observation of the Inquiry Officer that “He (appellant) deserved a psychological
make over…” is wholly incorrect. It is clearly in excess of scope of the inquiry and is wholly
uncalled for and, therefore, is liable to be expunged. It only reflects his bias and malice.

7. In TribhubanParkash Vs. India (AIR 1970 S.C.540), the Indian Supreme Court held that
unless there is legally admissible evidence, the conclusions could not be based on conjectures,
surmises and suspicions. The Honourable Supreme Court of Pakistan in Samiuddin QureshiVs.
Collector of Customs (PLD 1989 S.C.335) referred to this judgment reiterated this principle in
para-10 of the Judgment which is reproduced hereunder:-

“To dismiss a civil servant or for that matter, any employee on a charge of taking bribe or
misconduct is as serious a matter as convicting a person for a crime because his whole
career is ruined. Therefore, the order of dismissal must be based on some evidence.”

8. In Samar PeraizVs. Board of Intermediate and Secondary Education, Lahore and others
(PLD 1971 S.C.838), it was held:-
“A Tribunal’s decision must rest not on suspicion but upon legal grounds established by
legal evidence”.

9. In view of the above, it is respectfully prayed that the appeal against the order dated
09.09.2016 Dismissing the appellant from the service may kindly be allowed, the said Order
may be set aside, the appellant may kindly be exonerated from the charges and reinstated
into service with all back benefits. The appellant may also kindly be granted an
opportunity of personal hearing.

Yours obediently,

(Syed Taimoor Bukhari)

Ex-Assistant Controller Military Accounts (Lahore
Command),135-J-II. Johar Town, Lahore.
Contact # 0300 9453254.
Dated: September 30, 2016

Summary for the Prime Minister

Representation to the Prime Minister
Syed Taimoor Bukhari
BS-17/Ex-PA&AS Officer
Dismissed from Service
w.e.f. 09.09.2016
 SECRET

Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

SUMMARY FOR THE PRIME MINISTER

Subject: APPEAL AGAINST THE IMPOSITION OF MAJOR PENALTY OF “DISMISSAL

FROM SERVICE” IN RESPECT OF SYED TAIMOOR BUKHARI, BS-17 EX-
OFFICER PAKISTAN AUDIT AND ACCOUNTS SERVICE

A disciplinary case was initiated against Syed Taimoor Bukhari, a BS-17/PA&AS

officer under Government Servants (E&D) Rules, 1973 vide Order of Inquiry No.392–Dir(A)/11-
321/Discip/15 dated 05.11.2015. The Inquiry Officer proved all charges leveled against him
and Authorised Officer issued a Show Cause Notice bearing No.159/-Dir(A)/11-321/Discip/2015
dated 01.08.2016 to the accused officer which was replied by the accused officer but not found
satisfactory. Thereafter, the accused officer was given an opportunity of personal hearing on
02.09.2016 but again could not present cogent defence against the allegations leveled in the
Charge Sheet. Upon findings of the Inquiry Officer proving misconduct committed by the accused
and the recommendations of the Authorised Officer, the Authority imposed major penalty of
“Dismissal from Service” upon the accused officer Syed Taimoor Bukhari, vide order dated
09.09.2016. (Annex-A).

2. Syed Taimoor Bukhari has submitted a Representation addressed to the Prime

Minister of Pakistan against the imposition of major penalty of “Dismissal from Service” which is
being forwarded through this summary.

3. No cogent reasons or documentary evidences have been presented in the

Representation submitted by the officer in his defense. The penalty imposed on him is thus in
order under the rules as explained in para wise comments on the representation (Annex-B).

4. It is therefore proposed that the Prime Minister may reject the representation
preferred by Syed Taimoor Bukhari and confirm the orders of the Competent Authority of
imposing the major penalty of “Dismissal from Service” upon him.

5. Approval of the Prime Minister is solicited to the proposal contained in para 4

above, in his capacity as Appellate Authority under the Government Servants (E&D) Rules, 1973.

(RANA ASSAD AMIN)

Auditor-General of Pakistan

Secretary, Finance Division, Islamabad

Secretary, Establishment Division, Islamabad

Secretary, Establishment Division, Government of Pakistan, Islamabad

Auditor-General’s Summary No. -Dir(A)/11-321/Discip/2016 dated .11.2016
PUC is a letter dated 30.09.2016 received from Syed Taimoor Bukhari, Ex-
PA&AS officer BS-17, which may kindly be seen.(placed in below file).

The above name officer has requested to forward his representation addressed to
the Prime Minister of Pakistan through proper channel against the order dated
09.09.2016 of his dismissal from service.

The above representation has examined and juxta position on the representation
is submitted for kind perusal and further orders please. (placed in below file).

AAO (Legal-I)

AO (Legal-I)

Director Legal
 41/N

170. PUC is letter dated 05.12.2016 from Cabinet Secretariat, Estab. Division,
Islamabad, which may kindly be seen.

171. Vide PUC, it has been requested that parawise comments by the
Department on the representation to the appellate authority submitted by
the Syed Taimoor Bukhari, Ex-BS-17/PA&AS officer, has not been found
attached with the summary rather, it contains parawise comments on
inquiry report and also requested to provide a copy of the inquiry report
conducted by the Department.

172. This office vide referred above summary has already forwarded the
parawise comments by this Department on the representation submitted
by Syed Taimoor Bukhari, Ex-BS-17/PA&AS officer, the aggrieved civil
servant. The statement of parawise comments contains columns of
charge/allegation, Inquiry Officer’s findings, contention of the accused
officer and reply/comments by the Department on contention of the officer
which might have been overlooked by Estab. Division.

173. In this regard, a DFA for supply of requisite documents as desired by the
Cabinet Secretariat, Estab. Division, Islamabad is submitted for kind
approval / signature please.

174. Submitted please.

AAO (Legal-I)

AO (Legal-I)
 Office of the

Auditor General of Pakistan

Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .12.2016

Mr. Muhammad Usmani,

Section Officer (D-3),
Cabinet Secretariat, Establishment Division,
Islamabad.

SUBJECT: APPEAL AGAINST IMPOSITION OF MAJOR PENALTY OF DISMISSAL

FROM SERVICE IN RESPECT OF SYED TAIMOOR BUKHARI, BS-17,
EX-PA&AS OFFICER

Please refer to your O.M. No. 8/35/2016-D-3 dated 05.12.2016 on the

subject cited above.

2. Parawise Comments on the appeal has already been submitted by this

Department on the contention of the accused officer, captioned in the subject. The
Statement of Parawise Comments contains six columns i.e. Sr. No., Charge/Allegation,
Inquiry Officer’s findings, contention of the accused officer and comments by the
Department on accused officer’s representation not on the inquiry report. However, a
copy of the same is again annexed alongwith complete copy of the Inquiry Report
conducted by this Department as desired. Parawise comments on the representation on
a separate page are also added for convince please.

(RANA SHAKEEL ASGHAR)

Director (Legal)

Encl:

1. Statement of Parawise Comments containing 12-Pages.

2. Inquiry Report 107-Pages.
STATEMENT OF PARAWISE COMMENTS ON THE REPRESENTATION TO THE PRIME MINISTER OF PAKISTAN
SUBMITTED BY SYED TAIMOOR BUKHARI, BPS-17 EX-OFFICER OF PAKISTAN AUDIT & ACCOUNTS
SERVICES WHO HAS BEEN DISSMISSED FROM SERVICE W.E.F. 09.09.2016

SR. CONTENTION OF THE ACCUSED COMMENTS BY THE

CHARGE/ALLEGATION
# OFFICER
1 You with the connivance of Mr.
Zahhid Rasheed the then
Director General DAO’s (OPS)
got yourself posted back as
Assistant Accountant General,
whereas you already had been
surrendered on account of
misconduct from the office of
Accountant General Punjab.
2 You obtained the possession of
token punching machine in
complete disregard to standard
operating procedures, during
the month of June, 2014.
DEPARTMENT
Charge (i) was clearly held by the Inquiry Untoward incidents happening in
Officer to have not been proved. the office of the of the
Accountant General Punjab
during the month of June, 2014
and the acts of faithfulness
exhibited by Syed Taimoor
Bukhari proved to be a right hand
man of Mr. Zahhid Rasheed
which has protracted a bad name
to that officer as well as for the
whole Department.
(i) As far the law laid down by the As the Inquiry Officer has held
Superior Courts and the Service Tribunal, that order of shifting of the token
the charge had to be proved and not punching machine was verbally
something which was not part of the conveyed by Syed Taimoor
charge-sheet. The finding of the Inquiry Bukhari as such Department is of
Officer was that:- the view that this misdeed
occurred with the collaboration of
“The punching machine was under the the Syed Taimoor Bukhari as is
direct influence of the outsider namely evident from the statement of the
Shakeel Ahmad, installed by the AG”. officer/officials of Office of the
Accountant General of Punjab,
This finding conclusively defeats the Lahore. The possession of token
charge. machine was used for punching
the bogus bills which was proved
(ii) According to the Bill Tracking circumstantially.
Report (BTR) Mr. Sajjad Shah had punched
the tokens, who holds regular charge of
punching bills. There is no irregularity in this

Page 106 of 188

regard. The only evidence for this charge
comes from Mian Ahmad Saeed, the AO,
Cheque Section. His (Mian Ahmed Saeed)
statement also does not support the charge
as framed or that the appellant had even
facilitated handing over of the Token
Punching Machine to an outsider.

(iii) According to the IO, orders

regarding token machine were
communicated through the appellant, which
is wholly incorrect. The A.O. Cheque stated
that the machine was handed over to Rana
Shakeel on the verbal orders of the then
Accountant General conveyed by one Mr.
Muzaffar Shah. This clearly falsifies the
findings of the IO. Muzzafar Shah has
contradicted his(AO Cheque) statement by
stating that he asked the AO cheque to
hand over the token machine to the
“authority concerned” and not to any
outside agent. Surprisingly the IO, despite
recording the statement of Muzzafar Shah,
has not made it part of the inquiry report for
the reasons best known to him.

(iv) While appearing before the

Investigating Officer of the NAB, the AO
cheque took a different position and stated
that the appellant conveyed the order of the
Accountant General through Muzaffar Shah
to handover the machine to the “concerned
authority” on 16.06.2014. It is worth
mentioning here that the appellant neither
passed any such order nor did the AO
cheque confirmed the same from the
appellant, thus, he relied on hearsay.
Above all, this contradiction makes the two

Page 107 of 188

statements as mutually destructive which is
enough to make AO cheque a liar of his
own statements. However, one thing which
is positively established is that at no stage
the token machine was ever in possession
of the appellant as alleged in the charge.
The allegation of conveying the message
by the appellant was false and fabricated.

Interestingly , 16.06.2014 was the last

date for submission of bills after which
the token punching on the bills was
supposed to be stopped as per
instruction of the Finance Department
Government of the Punjab and the AG.
Banners were placed at various places
inside and outside of the premises of the
AG office as per years long practice.
Moreover, the AO cheque section,
himself, is the relevant authority and
custodian of the said machine.

(v) The Inquiry Officer clearly found that

the machine was not in physical possession
of the appellant and also confirmed the
aforementioned SOP that:-

“Some level of control of the machine in

the last days of June by the
administration is usual but control of an
outside agent of the AG in June, 2014 is
unusual”. (emphasis supplied).

(vi) Sajjad Shah, who punched the

token clearly admitted that it was Mr.
Shakeel, a private person representing the
then Accountant General, at whose asking
he had punched the four bills. No

Page 108 of 188

 proceedings against him have ever been
initiated against him. (underlined to
emphasize)

(vii) The charge is not supported by any

evidence and the ultimate finding of the
Inquiry Officer is that “It however, does
not verify that the machine was in
physical possession of the accused
officer” (underlined to supply emphasis).
With the above findings, the Inquiry Officer
did not held that Charge No.(ii) stood
proved against the appellant. However, the
findings recorded by the Inquiry Officer left
no manner of doubt that this charge, as
brought, (underlined to emphasize) was not
proved.

3 You compelled your staff in (i) As far the charge as framed is Being fully aware about the fake
Payroll-7 Section to process the concerned, as per the Inquiry Officer’s bills he pressed to the dealing
counterfeited bills without findings and observations, it was not staff to process those bills
exercising proper pre-audit proved. Nor the Inquiry Officer has held theexpeditiously due to lack of
checks which confirm your charge to have been proved. Instead, the experience and caused attributes
willful involvement in processing operative finding is that the appellant towards such a bills of heavy
the counterfeited bills in “successfully persuaded Payroll-7amounts.
connivance with the then Section……...” The IO has failed to As pointed out by the Inquiry
Director General/Accountant appreciate the fact that it comes under the Officer that his blind compliance
General (on look after basis). duty of the appellant to pursue the timely to the system installed by the
disposal of the all the bills. then Accountant General which
allowed such a fake bills as of
(ii) Mr. Jawad Qamar, the KPO, who is Walled City Project to find easy
not an accused, had also been examined. access to the Government wallet
He falsely stated that the appellant handed unhindered and to unhurdled.
over to him five bills. So far recovery of
stamp is concerned in charge No.(iv),the
Inquiry Officer held that the said charge
was concocted by Mr. Jawad-ul-Qamar. He
has been proved to be liar by his own

Page 109 of 188

showing. His malice towards the appellant
is explicit. His evidence could hardly furnish
any basis for extreme action against the
appellant.

(iii) The finding of persuasion does not

amount to compelling the concerned
officials to process those bills. The other
witnesses examined in support of this
charge were Shahbaz Qamar, Senior
Auditor, and Arshad Iqbal, Assistant
Accounts Officer. They were, in fact, the
persons responsible for this unfortunate
happening. They are also being proceeded
against under the Efficiency and Discipline
Rules. So, their testimony is tainted with
very strong bias to make the appellant a
scapegoat. Please see Rai Shabbir
Ahmad Vs. Government of Punjab {1981
PLC (CS)755} and Sarfraz KhanVs. Water
and Power Development Authority and 2
others {1991 PLC (CS)9} regarding the
evidentiary value of a co-accused in
departmental proceedings. Thus, there was
no reliable and independent witness in
support of this charge. As Section Incharge,
the appellant could supervise and ensure
that the work of the section runs smoothly.
Particularly, it was the month of June, the
end of financial year and burden of work
had increased.

(iv) That the Inquiry officer drew a totally

baseless inference from the fact that the
processing of the bill was completed in 24
minutes. (It was not part of the charge).
However, he has not tried to find out that
processing of many other bills was

Page 110 of 188

completed even before 24 minutes. In their
statement before the Inquiry Officer the
AAO and the Senior Auditor have admitted
that they were never asked to ignore pre-
audit checks rather they admitted that they
were asked to process the bills swiftly and
that comes within the scope of the duty of
the appellant as a Section Incharge,
particularly in view of the fact that on
23.6.2014, on the complaint of Mr. Kamran
Lashari, the Director General of the Walled
City Project Authority, the Senior Auditor
and AAO were changed and additional
charge of the post of Incharge Payroll-7
was given to the appellant to look after the
duties of the said section. The appellant
was posted to this section on 23.6.2014
while this unfortunate incident of passing of
bills was of 26.6.2016, only after two days
of appellant’s taking over charge of this
section, and during these two days the
appellant did not even know any staff
member personally and, therefore, the
suspicion of the Inquiry Officer that he
might have been part to these irregularities
is farfetched and speculative only.

(v) The bills were allotted token on

25.6.2014 and not on 26.6.2014 as
assumed by the Inquiry Officer to draw a
totally baseless inference that the bills were
processed with undue haste. This clearly
denotes the lack of perusal and
appreciation of the record/evidence on the
part of the IO. The pre-audit checks, which
according to the Inquiry Officer were
overlooked, did not come within the purview
of the responsibility of the appellant. The

Page 111 of 188

Senior Auditor and the AAO are100%
responsible for verification of signatures of
the presenter, totals, classification, budget
allocation and scrutiny of the sanction. They
clearly admitted that they were never asked
to bypass or ignore any pre-audit check.
The finding of the Inquiry Officer that the
pre-audit checks were not properly applied,
clearly means that the AAO and the Senior
Auditor failed to do their duty. Thus, the
evidence brought on the record does not
substantiate the charge against the
appellant nor the Inquiry Officer has so
found.

(vi) In the inquiry report under the

Efficiency and Discipline Rules against Mr.
Arshad Iqbal AAO, the Inquiry Officer, Mr.
Hamza Ali, a PAAS (BS-17 Officer) has
found:-

“It is pertinent to mention here both

Senior Auditor, Mr. Shahbaz Qamar and
Assistant Accounts Officer Mr. Arshad
Iqbal have alleged that they failed to
perform their duty due to pressure from
Mr. Taimoor Bukhari, the then AAG.
However, during the course of inquiry,
they have not been able to successfully
prove their allegation through an
objective and substantial piece of
evidence to completely rule out their
failure to stop the fraudulent claims.”

(vii) Under clause (d) of the opinion he

has referred to five possibilities as to the
extent of responsibility of the appellant for
this entire unfortunate incident and under

Page 112 of 188

clause (e) of his opinion he holds:-

“Only detailed forensic expertise can decide

which one of the above possibilities is true.
However, the documentary soft and hard
evidence prove that Mr. Taimoor Bukhari
successfully persuaded Payroll-7 section to
process the fake bills in a space of just 24
minutes either out of his own interest to get
things done or to show compliance to the
AG who had circumstantially obliged him by
maneuvering his posting back to AG Punjab
after the disgraceful surrender by the Ex-
AG.”

Although appellant’s posting was subject

matter of charge No.(i) which in fact is held
not to be proved by the Inquiry Officer.

(viii) Thus, in fact the Inquiry Officer did

not find the appellant guilty of this charge
as well. The observation of “persuasion”
was never the part of the charge and even
if, without conceding, persuasion is proved,
then the appellant was only doing his duty
to ensure that the work of the section is
conducted smoothly and swiftly. There is no
finding that this charge has been proved.
The inquiry officer totally kept out of
consideration that there were more than
twenty bills presented by the Walled City
Project Authority which were followed up by
the appellant in good faith because the said
authority had some complaints regarding
their previous bills (of undue delay) and not
only these four particular bills. Therefore,
the instructions to dispose of the work in
time were general in nature and in

Page 113 of 188

 accordance with the job description of the
appellant. Hence the finding of the inquiry
officer that the appellant persuaded Payroll-
7 Section only for the process four fake
bills, stands vitiated. (Extract of the job
description of the appellant is enclosed as
Annex “B”)

4 You were found to be in Charge (iv) was clearly held by the Inquiry This charge is also a chain of
possession of fake stamps of the Officer to have not been proved. previous charge which is itself an
vendors, in whose name the attempt to prepare the bogus bills
fake bills were got prepared and and stamp those bills with his
processed. This further own hands
corroborates your active
involvement in the fraud.

5 You collaborated with the team
of private persons and officials
of Accountant General Punjab
malafide deployed by Mr. Zahhid
Rasheed in order to create a
rush and an environment of fear
in the office so as to get the
things done according to your
whims.
(i) That the portion of the opinion
under (a) of this charge as to the manner
in which the appellant got the charge of
important section etc. was wholly uncalled
for after Charges (i) and (iv) were held not
proved and regarding other charges there
is no finding that these charges stood
proved.
(ii) That the circumstances relied upon
to make adverse observation against the
appellant were not at all supported by any
evidence except the conjectures and
surmises of the Inquiry Officer which
shows his biased and malice against the
appellant.
As Syed Taimoor Bukhari has
provided sufficient circumstantial
evidence that he facilitated Mr.
Zahhid Rasheed in creating an
environment in Accountant
General Punjab, Lahore which
was conducive to Mr. Zahhid
Rasheed for his interests as
reflected in passage of four bills
of Rs. 104 Millions and possible
attempt of clearance of 19 bills of
Rs. 383 Millions.

(iii) That, in any case, the charge was

too vague to merit consideration, inasmuch
as, that the stated team of private persons
and officials of the Accountant General

Page 114 of 188

remain unidentified and also that there was
no evidence whatsoever that the appellant
was responsible for commotion of 27th
June, 2014. Rather, the charge itself says
that these private persons and officials
were deployed by Mr. Zahid Rasheed Ex-
Accountant General. The only allegation
against the appellant was of collaboration,
but neither any overt act was attributed to
the appellant nor was there any evidence
to substantiate this charge. (emphasis
supplied)

(iv) Under finding at (a), the Inquiry

Officer declared the appellant as Incharge
of Admin Section. This is not correct. The
overall incharge of the Administration of
the A.G. Office is one PAAS, BS-19
Officer, i.e., Additional Accountant General
(Admin).

(v) The very charge, itself, is that

private persons and officials of the
Accountant General were deployed by Mr.
Zahid Rasheed, the then Accountant
General. In fact they were deployed by him
on 23.5.2014 while the appellant had
joined the Office on 4.6.2014. Thus, the
appellant could not be blamed for outside
influence. It was the previous
administration who had facilitated their
presence in the office for which the
appellant could hardly be blamed.
However, even that finding was
demolished by the Inquiry officer himself
when under clause (e) he established the
responsibility of this charge on Mr. Zahid
Rasheed, the then Accountant General,

Page 115 of 188

Punjab. Also, the IO did not give any citing
of collaboration of the appellant with the
private team of Mr. Zahid Rasheed.
(emphasis supplied)

6. That the observation of the Inquiry

Officer that “He (appellant) deserved a
psychological make over…” is wholly
incorrect. It is clearly in excess of scope of
the inquiry and is wholly uncalled for and,
therefore, is liable to be expunged. It only
reflects his bias and malice.

7. In Tribhuban Parkash Vs. India

(AIR 1970 S.C.540), the Indian Supreme
Court held that unless there is legally
admissible evidence, the conclusions could
not be based on conjectures, surmises and
suspicions. The Honourable Supreme Court
of Pakistan in Samiuddin QureshiVs.
Collector of Customs (PLD 1989 S.C.335)
referred to this judgment reiterated this
principle in para-10 of the Judgment which
is reproduced hereunder:-

“To dismiss a civil servant or for that matter,

any employee on a charge of taking bribe
or misconduct is as serious a matter as
convicting a person for a crime because his
whole career is ruined. Therefore, the order
of dismissal must be based on some
evidence.”

8. In Samar PeraizVs. Board of

Intermediate and Secondary Education,
Lahore and others (PLD 1971 S.C.838), it
was held:-

Page 116 of 188

“A Tribunal’s decision must rest not on
suspicion but upon legal grounds
established by legal evidence”.

9. In view of the above, it is

respectfully prayed that the appeal against
the order dated 09.09.2016 Dismissing the
appellant from the service may kindly be
allowed, the said Order may be set aside,
the appellant may kindly be exonerated
from the charges and reinstated into
service with all back benefits. The
appellant may also kindly be granted an
opportunity of personal hearing.

Page 117 of 188

Page 118 of 188
 Office of the

Auditor General of Pakistan

Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .02.2017

Mr. Masood Akhtar Sherwanee,

Deputy Military Accountant General / Inquiry Officer,
Rawalpindi

SUBJECT: APPEAL AGAINST IMPOSITION OF MAJOR PENALTY OF

DISMISSAL FROM SERVICE IN RESPECT OF SYED TAIMOOR
BUKHARI, BS-17, EX-PA&AS OFFICER

Kindly find enclosed a copy of Establishment Division’s letter No.

F.No.8/35/2016-D-3 dated 21.02.2017 on the subject cited above.

2. An inquiry was conducted by you in respect of Syed Taimoor Bukhari,

BS-17 / Ex-PA&AS officer. The Establishment Division has desired for provision of a
signed copy of the complete inquiry report with the signature of Inquiry Officer
appended on every page of the Inquiry Report in order to maintain / preserve its
originality.

3. It is requested a signed copy of Inquiry Report may be provided to

this office at the earliest for onward submission to the Establishment Division.

(Arif Hussain)
Director (Legal)
 43/N

179. PUC is a fax message from Establishment Division bearing No. F.No.8/35/2016-
D-3 dated 21.02.2017 which may kindly be seen.

180. An inquiry was conducted by Mr. Masood Akhtar Sherwanee, Dy. MAG,
Rawalpindi in respect of Syed Taimoor Bukhari, BS-17 / x-PA&AS officer and
the inquiry report was forwarded to Establishment Division alongwith Summary
for the Prime Minister in connection with appeal filed by Syed Taimoor Bukhari,
BS-17/Ex-PA&AS officer against imposition of major penalty upon him.

181. The Establishment Division has desired for provision of a signed copy of the
complete inquiry report with the signature of Inquiry Officer to be appended on
every page of the inquiry report in order to maintain / preserve its originality as
the provided inquiry report does not bear the signature of the Inquiry Officer.

182. In the light of above, a DFA addressed to the nominated Inquiry Officer is added
for kind signature please.

AAO(Legal-I)

AO(Legal-I)
 Office of the

Auditor General of Pakistan

Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .03.2017

Dr. Ejaz Ahmed,

Section Officer (D-3),
Cabinet Secretariat, Establishment Division,
Islamabad.

SUBJECT: APPEAL AGAINST IMPOSITION OF MAJOR PENALTY OF

DISMISSAL FROM SERVICE IN RESPECT OF SYED TAIMOOR
BUKHARI, BS-17, EX-PA&AS OFFICER

Please refer to your O.M. No. 8/35/2016-D-3 dated 21.02.2017 on

the subject cited above and find enclosed a signed copy of the complete Inquiry
Report with the signature of Inquiry Officer appended on every page of the Inquiry
Report as desired.

(SYED ABUDUSALAM ASIF)

Deputy Director (Legal)
Encl:
1. Signed Inquiry Report (Thirteen Pages).
 44/N

185. PUC is a letter dated 23.02.2017 annexed with signed Inquiry Report, received
from Mr. Masood Akhtar Sherwani, Dy. MAG, Rawalpindi / Inquiry Officer in
response to this office memo dated 23.02.2017 (Page-260/C), which may kindly
be seen.

186. As desired by the Establishment Division for provision of a signed copy of the
complete inquiry report with the signature of Inquiry Officer to be appended on
every page (Page-259/C), a DFA is added for kind signature please.

AAO (Legal-I)

AO (Legal-I)
 29/N

130. With reference to the remarks at para 128/N ante, it is submitted that
Syed Taimoor Bukhari, a BS-17, Ex-PA&AS Officer filed a
representation addressed to the Prime Minister of Pakistan against
imposition of major penalty upon him on 30.09.2016 which has
already been submitted by this office vide Summary dated
18.11.2016 to the Prime Minister of Pakistan accordingly. However,
reply thereto is still awaited.

131. Submitted please.

AAO (Legal-I)
Thursday, 06 April 2017

AO (Legal-I)
 Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .05.2017

Dr. Ejaz Ahmed,

Section Officer (D-3),
Cabinet Secretariat, Establishment Division,
Islamabad.

SUBJECT: COPY OF THE ORDERS PASSED BY THE TRIBUNAL IN

APPEAL NO. 47 (L)-17 FILED BY SYED TAIMOOR BUKHARI,
BS-17, EX-PA&AS OFFICER AGAINST AUDITOR GENERAL
OF PAKISTAN

Please refer to the subject cited above and find enclosed herewith
a copy of Judgment / Order Sheet passed by the Honorable Federal Service
Tribunal, Lahore Bench, Lahore dated 04.05.2017 in subject Appeal filed by Syed
Taimoor Bukhari, a BS-17/Ex-PA&AS officer, whereby it has been intimated by the
said Honorable Tribunal that “as such we deem it proper to remand this case to the
respondents with direction to decide the Departmental representation filed by the
appellant through a speaking and reasoned order after providing an opportunity of
personal hearing to the appellant within 30 days from the date of receipt of the copy
of this order. In case the Department fails to do so within the stipulated period, the
appellant will have the right to approach the proper forum for rederessal of his
grievance”.

2. In the light of afore referred orders of the Honorable Tribunal, it is

requested to take further necessary action in the matter under intimation to this
office so that Honorable Court could be informed the action taken in the matter
within the stipulated period given by the Honorable Court.

(SYED ABUDUSALAM ASIF)

Deputy Director (Legal)
Encl:
As above. (Two Pages)
 45/N

187. PUC is copy of Judgment / Order Sheet passed by the Honorable

Federal Service Tribunal, Lahore Bench, Lahore dated 04.05.2017 in
subject Appeal filed by Syed Taimoor Bukhari, a BS-17/Ex-PA&AS
officer, which may kindly be seen. (Page-278-279/C)

188. Vide Order Sheet it has been intimated by the said Honorable Tribunal
that “as such we deem it proper to remand this case to the respondents
with direction to decide the Departmental representation filed by the
appellant through a speaking and reasoned order after providing an
opportunity of personal hearing to the appellant within 30 days from the
date of receipt of the copy of this order. In case the Department fails to do
so within the stipulated period, the appellant will have the right to
approach the proper forum for rederessal of his grievance”.

189. In this regard, it is submitted that representation filed by Syed Taimoor

Bukhari, a BS-17/Ex-PA&AS officer has already been forwarded to the
Estab. Division, Islamabad, vide this office Summary dated 18.11.2016
(Page-254/C).

190. In the light of above, a DFA is added to forward the Order Sheet to the
Estab. Division, Islamabad, for taking further necessary action in the
matter please.

191. Submitted please.

AAO (Legal-I)
11.05.2017

AO (Legal-I)
 47/N

194. PUC is a letter dated 21.06.2017 received from the Secretary to the Prime
Minister’s Office; Islamabad in response to this office Summary to the PM
dated 18.11.2016 forwarded in the disciplinary case of Syed Taimoor
Bukhari, a BS-17/Ex-PA&AS Officer (Page-283/C), which may kindly be
seen.
195. Vide PUC it has been intimated that the Prime Minister / Appellate
Authority has seen the case and is pleased to observe that Inquiry Officer
failed to mention clearly whether any charge has been proved against the
accused or not. Instead, the report is full of contradictory statements by
the Inquiry Officer himself. Award of maximum major penalty on the basis
of such an Inquiry Report, prima-facie, can hardly be justified. At the same
time, the allegations of inefficiency, misconduct and corruption leveled
against the ex-officer are quite serious and require through investigation in
proper manner.
196. In view of the above, the Prime Minister while agreeing with the
observations of Establishment Division at the Para 7 (P-281/C), has been
pleased to approve proposal of Estab. Division at Para 9 of the Summary
(P-281/C).
197. The Establishment Division, vide Para 9 of the Summary has
recommended that the Prime Minister / Appellate Authority may remand
the case to the Authority / Auditor-General of Pakistan for initiation of de
novo inquiry against Syed Taimoor Bukhari so as to reach clear findings
by establishing or otherwise, the said charges.
198. In compliance of kind directives of the Prime Minister dated 21.06.2017
(Page-284/C), approval of the worthy Auditor-General of Pakistan /
Authority for initiating denovo inquiry is solicited to proceed further in the
matter.
199. As such, a draft Charge Sheet coupled with Statement of Allegations and
Order of Inquiry, in pursuance of Rule 6-A (2) of the E&D Rules, 1973, are
submitted for kind approval signature of the DAG (A&C) / Authorised
Officer please. The said Rule is placed below, which may read as follow:
 48/N

6-A Revision. (1) Subject to sub-rule (2), the authority may call for the
record of any case pending before, or disposed of by, the authorized
officer and pass such order in relation thereto as it may deem fit;

(2) No order under sub-rule (1) shall be passed in respect of an accused

unless the authorized officer to be designated by the authority has
informed him in writing of the grounds on which it is proposed to make the
order and has been given an opportunity of showing cause against it,
including an opportunity of personal hearing if requested by the accused or
is otherwise necessary in the interest of justice, in particular, when the
authority contemplates to pass an order adverse to the interest of the
accused:

Provided that no such opportunity shall be given where the authority, for
reasons to be recorded in writing, is satisfied that, in the interest of
security of Pakistan or any part thereof, it is not expedient to give such an
opportunity.

200. A copy of seniority lists, in respect of BS-19 & BS-20 / PA&AS officers are
submitted for appointment of an inquiry officer in the instant case, please.
201. Submitted for kind consideration and perusal please.

(Muhammad Bilal Sharif)

AAO Discip. (Legal-I)
July 3, 2017
AO (Legal-I)
 Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .07.2017

CHARGE SHEET

WHEREAS, I, Muhammad Ikram Khan, Deputy Auditor General (A&C) /

Authorized Officer have decided to proceed against you, Syed Taimoor Bukhari, Ex-
Assistant Accountant General (Ex-BPS-17/PA&AS), under Rule 5 (1) (ii) read with
Rule 6-A (2) of the Government Servants (Efficiency & Discipline) Rules, 1973 and in
pursuance of the orders of the Prime Minister / Appellate Authority vide letter No.
1841/SPM/17 dated 21.06.2017 on your appeal / representation against the imposition
of major penalty of “Dismissal from Service”.

2. WHEREAS, I consider that in the light of facts of the case and in the
interest of justice, it is necessary to hold denovo inquiry against you through an
Inquiry Committee.

3. WHEREAS, you, Syed Taimoor Bukhari, Ex-Assistant Accountant

General (Ex-BPS-17/PA&AS), office of the Accountant General Punjab Lahore, failed
to discharge your duties efficiently and committed the following acts of
omission/commission which are tantamount to “Inefficiency”, “Misconduct” and
“Corruption” within the meaning of Rule 3 (a) (b) & (c) of the Government Servant
(E&D) Rules, 1973.

(i) You with the connivance of Mr. Zahhid Rasheed the then Director
General DAO’s (OPS) got yourself posted back as Assistant
Accountant General, whereas you already had been surrendered on
account of misconduct from the office of Accountant General
Punjab.
(ii) You obtained the possession of token punching machine in
complete disregard to standard operating procedures, during the
month of June, 2014.
(iii) You compelled your staff in Payroll-7 Section to process the
counterfeited bills without exercising proper pre-audit checks which
confirm your willful involvement in processing the counterfeited bills
in connivance with the then Director General/Accountant General
(on look after basis).
 (iv) You were found to be in possession of fake stamps of the vendors,
in whose name the fake bills were got prepared and processed. This
further corroborates your active involvement in the fraud.
(v) You collaborated with the team of private persons and officials of
Accountant General Punjab malafide deployed by Mr. Zahhid
Rasheed in order to create a rush and an environment of fear in the
office so as to get the things done according to your whims.

4. AND WHEREAS, by reasons of above read with the details given in the
enclosed Statement of Allegations, you are liable to disciplinary action under the
Government Servants (E&D) Rules, 1973, which may include imposition of one or
more penalties including the major penalty of “Dismissal from Service” as prescribed
in Rule 4 of the ibid Rules.

5. WHEREAS, in pursuance of sub-rule (ii) of Rule 5 of the Government

Servants (E&D) Rules, 1973 Mrs. Fizza Pervez Afzaal, Controller Military Accounts
(L.C.), Lahore and Mr. Osman Jawed Loan, Addl. AGPR, Lahore have been
appointed by the undersigned as Inquiry Officers / Inquiry Committee, who will conduct
the proceedings in this case against you.

6. NOW THEREFORE, you are hereby required to submit your written

defence to the above charge sheet, within fourteen (14) days on its receipt to the above
named Inquiry Committee, failing which it shall be presumed that you have nothing to say
and action against you will be initiated ex-parte.

7. Statement of Allegations explaining the charges is enclosed.

(Muhammad Ikram Khan)

Deputy Auditor-General (A&C) /
Authorized Officer
Copy for information and necessary action to:

 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore and Mr.
Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officers along with a copy
of the Statement of Allegations. Inquiry should be completed as early as possible
in accordance with the provisions of Government Servants (Efficiency &

PTO
 Discipline) Rules, 1973. The original record containing of three files
pertaining to the instant case are also enclosed.

 Syed Taimoor Bukhari, Ex-BS-17 PA&AS Officer, 135-JII, Johar Town, Lahore.
Cell No. 0300-9453254.
 Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

STATEMENT OF ALLEGATIONS

Syed Taimoor Bukhari, Ex-BS-17 PA&AS Officer, Ex-Assistant Accountant

General, in the office of Accountant General Punjab, Lahore, committed the
following acts of omission/commission:-

i. That you in connivance with Mr. Zahid Rasheed, Director General

DAOs (OPS) also holding the charge of Accountant General (on
look after basis) illegally, maneuvered to get yourself posted as
Assistant Accountant General (AAG) in the office of the Accountant
General Punjab in June, 2014 despite the fact that you were
surrendered as AAG, by the then Accountant General Punjab on
account of misconduct in December 2013 (Annexure-A & B).

ii. That you obtained the possession of Token Punching Machine in

complete disregard of standard operating procedures during the

month of June, 2014. During the period that the Token Punching

Machine remained in your custody, you used it for punching tokens

on counterfeited/bogus bills (Annexure- C, D, E, F, G & H).

iii. You being the officer in-charge compelled Mr. Jawad-ul-Qamer,

Key Punch Operator, Mr. Muhammad Shahbaz Qamer, Senior
Auditor and Assistant Accounts Officer viz Mr. Muhammad Arshad
Iqbal of Payroll-7 Section to process the counterfeited bills of
“Sustainable Development of Walled City Lahore Project” and
cleared those bills without applying proper pre-audit checks. You
then forwarded those bills from the computer terminal in the section
hurriedly, without applying the prescribed pre-audit checks. After
clearing the bills in a swift manner and without applying proper pre-
audit checks, you recorded the following statement on the passed
bills statement “Necessary approval has been taken by the Director
 General/Accountant General”. These actions on your part confirm
your willful involvement in processing the counterfeited bills in
connivance with the then Director General/Accountant General Mr.
Zahid Rasheed (Annexure- I, J, K, L, M, N & O).
iv. As per statement of Mr. Jawad-ul-Qamer, Senior Auditor/Key
Punch Operator and Syed Shiraz Hussein, Naib Qasid, you were in
possession of the fake stamps, used on the bogus bills of the fake
vendor, of the Sustainable Development of the Walled City Project
Lahore. The name of the fake vendor was M/s Qavi Engineering
(Annexure- I, O & P).
v. You operated through private armed persons and placed officials
violating all the prescribed standard operating procedures, created
a rush and an environment of fear in order to clear bills in lieu of
handsome bribes. You and the private armed guards acted in
connivance with the then ex-Accountant General Punjab Mr. Zahhid
Rasheed. (Annexure-Q).

2. By reasons of the above, Syed Taimoor Bukhari, Ex-Assistant Accountant

General, office of Accountant General Punjab, has rendered himself liable for
disciplinary action under the Government Servants (Efficiency & Discipline) Rules,
1973 which may include imposition of one or more penalties including major penalty
of “ Dismissal from Service”.

(Muhammad Ikram Khan)

Deputy Auditor-General (A&C) /
Authorized Officer
Copy to:

 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (L.C.), Lahore and Mr.
Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officers along with a copy
of the Statement of Allegations. Inquiry should be completed as early as possible
in accordance with the provisions of Government Servants (Efficiency &
Discipline) Rules, 1973. The original record containing of three files
pertaining to the instant case are also enclosed.

 Syed Taimoor Bukhari, Ex-BS-17 PA&AS Officer, 135-JII, Johar Town, Lahore.
Cell No. 0300-9453254.
 Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip Dated: .07.2017

ORDER

In pursuance of Rule-5 (1) (ii) read with Rule 6-A (2) of the Government
Servants (Efficiency & Discipline) Rules, 1973 Mrs. Fizza Pervez Afzaal, Controller
Military Accounts (LC), Lahore and Mr. Usman Jawed Loan, Addl. AGPR, Lahore
are hereby appointed to be the Inquiry Officers to conduct the denovo inquiry
proceedings against Syed Taimoor Bukhari, a BS-17/Ex-PA&AS, while posted as Ex-
Assistant Accountant General, in the office of Accountant General Punjab, Lahore, in
Charge Sheet No. /Dir (A)/11-321/Discip dated: .07.2017.

2. The inquiry shall be conducted on day to day basis in accordance with the
provisions contained in the Government Servants (Efficiency & Discipline) Rules,
1973, and instructions issued from time to time. The inquiry report should be
submitted within 10 days of the conclusion of the proceedings. The intervening period
between dismissal from service and reinstatement into service depends on outcome of
the denovo inquiry proceedings.

(Muhammad Ikram Khan)

Deputy Auditor-General (A&C) /
Authorized Officer

Copy for information and necessary action to:

 The Secretary to the Prime Minister of Pakistan, Prime Minister’s Office,

Islamabad w.r.t. letter No. 1841/SPM/17 dated 21.06.2017.
 The Secretary Establishment, Establishment Division, Islamabad
 The Secretary Finance, Finance Division, Islamabad
 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore and
Mr. Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officers along with a
copy of the Statement of Allegations. Inquiry should be completed as early as
possible in accordance with the provisions of Government Servants (Efficiency
& Discipline) Rules, 1973.
 Syed Taimoor Bukhari, Ex-BS-17 PA&AS Officer, 135-JII, Johar Town,
Lahore.
 Audit Officer PA&AS-II / Confidential
1. PUC is letter dated 05.07.2017 received from the Establishment Division,
Islamabad, which may kindly be seen.

2. Vide PUC, it has been intimated that the Prime Minister / Appellate Authority
may remand the case to the Authority / Auditor-General of Pakistan for
initiation of de novo inquiry against Syed Taimoor Bukhari, a Ex-BS-
17/PA&AS officer, so as to reach clear findings by establishing or otherwise,
the said charges.

3. In compliance of kind directives of the Prime Minister dated 21.06.2017

(Page-284/C), the worthy Auditor-General of Pakistan / Authority has
approved the case for conducting of denovo inquiry. As such, a Charge
Sheet coupled with Statement of Allegations and Order of Inquiry, in
pursuance of Rule 6-A (2) of the E&D Rules, 1973, have been issued to the
accused officer.

4. Furthermore, the Competent Authority has been pleased to constitute an

inquiry committee to conduct the denovo inquiry proceedings in the instant
case. The inquiry committee comprise of two inquiry officers namely i.e. Mr.
a BS-20/PA&AS Officer and Mr. a BS-20/PA&AS Officer, who have been
nominated vide order of inquiry dated .07.2017 (Page /C).

5. With reference to the kind remarks recorded by the Director (Legal) dated
11.07.2017 on the face of PUC, regarding rule position in the instant matter
as to whether we need to reinstate the accused officer into the Government
service before initiating of the denovo inquiry proceedings?

6. The Establishment Division vide letter dated 14.010.2002 as printed at Sr.

No. 88 of Esta Code, Vol.-II, has clarified that if a person is dismissed /
removed from service or compulsory retired, he does not retain the status of
a civil servant for the purpose of any other disciplinary proceedings or
imposition of any other penalty. There is a concept of law that the process of
appeal is the continuation of the original proceedings, therefore, if a
dismissed, removed or retired employee moves a Departmental Appeal or
 Representation or files an appeal before the appropriate judicial forum he
deemed to be a civil servant for that particular matter only under the said
concept of continuation of status during the process of appeal.

7. As such, a draft disposal letter addressed to S.O. (D-II), Estab. Division,

Islamabad is submitted for kind approval / signature please.

(Muhammad Bilal Sharif)

AAO Discip. (Legal-I)
AO (Legal-I)
 Most Immediate / Through Special Courier

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .08.2017

Mrs. Fizza Pervez Afzaal,

Controller Military Accounts (LC) / Inquiry Officer,
Lahore.

SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF

SYED TAIMOOR BUKHARI, BS-17, EX-PA&AS OFFICER
AGAINST AUDITOR GENERAL OF PAKISTAN

Kindly refer to this office Order of even number dated 03.08.2017

on the subject cited above (copy enclosed) and find enclosed herewith original
inquiry material containing three disciplinary case files as detailed below for taking
further necessary action in the instant matter.

1. Dir(A)/11-321/Discip./2015 (Vol-I) (containing 305 pages on

Correspondence Side and 53 pages on note side)
2. Dir(A)/11-321/Discip./2015 (Vol-II) (contains inquiry report conducted by Mr.
Masood Sherwani, Dy. MAG, Rawalpindi / the then Inquiry Officer) and
reply of the accused officer to the charges leveled against the accused
officer, juxta position of the case and brief of the case)
3. A complete summary folder containing representation of the accused officer
forwarded to the Prime Minister of Pakistan in the wake of imposition of
major penalty of dismissal from service.

3. It is further requested to acknowledge the receipt of

aforementioned record.

(Qudratullah Khan)
Director (Legal)
Encl: As above (Three Folders).

Copy to:
 Mr. Osman Jawed Loan, Addl. AGPR (Sub-Office) / Member of Inquiry
Committee, Lahore with reference to this office Orders dated
03.08.2017.
 1/N

1. PUC is a letter dated 04.08.2017 received from Syed Taimoor Bukhari, a BS-
17/Ex-PA&AS officer (dismissed from service), in response to the issued
Charge Sheet dated 03.08.2017 for holding denovo proceedings, which may
kindly be seen.

2. The inquiry committee comprising of two inquiry officers namely i.e. Mrs.
Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore and Mr.
Osman Jawed Loan, Addl. AGPR (Sub-Office) Committee, Lahore have been
nominated vide order of inquiry dated 03.08.2017 to conduct the denovo
inquiry proceedings. The original record pertaining to the instant case has
also been forwarded to nominated inquiry officers vide this office memo dated
03.08.2017 (P-7/C).

3. Through the PUC, accused officer has observed towards the following items:

a) The aforesaid charge sheet is fresh in nature and has been issued
without approval of the designated “Authority” under Govt.
Servants (E&D) Rules, 1973, hence the same is illegal and void
ab-initio.

b) The Honorable Prime Minister of Pakistan while disposing off my

appeal against the dismissal from service ordered vide letter dated
21.06.2017 that a denovo inquiry may be conducted as the
dismissal on the basis of the previous inquiry report could hardly
be justified. A denovo inquiry warrants the Department to reinstate
the Civil Servant first and then proceed. The Govt. Servants (E&D)
Rules, 1973, are only applicable to the Government Servants;
hence a fresh Charge Sheet cannot be treated as continuation of
my previous Charge Sheet because Honorable Prime Minister
while examining my Departmental Appeal had clearly ordered a
fresh inquiry and not issuance of a fresh Charge Sheet.

c) That even otherwise your good self has not appended any
document with the aforesaid Charge Sheet without which he can’t
put up his defense reply.

4. Keeping in view the above, the officer has requested to reinstate him into
service and legal lacunas as pointed out by him may be addressed to
proceed further in the matter.

5. The legal position of the case with reference to the aforementioned

observations / lacunas observed by accused officer are as follow:

a) Incorrect. The said Charge Sheet is not fresh issue in nature as it

has clearly been described the nature of matter in first and
 2/N

second paras of the ibid Charge Sheet, which may read as follow:
(P-5-6/C)

“WHEREAS, I, Muhammad Ikram Khan, Deputy Auditor General

(A&C) / Authorized Officer have decided to proceed against you,
Syed Taimoor Bukhari, Ex-Assistant Accountant General (Ex-
BPS-17/PA&AS), under Rule 5 (1) (ii) read with Rule 6-A (2) of the
Government Servants (Efficiency & Discipline) Rules, 1973 and in
pursuance of the orders of the Prime Minister / Appellate Authority
vide letter No. 1841/SPM/17 dated 21.06.2017 on your appeal /
representation against the imposition of major penalty of
“Dismissal from Service”.

2. WHEREAS, I consider that in the light of facts of the case

and in the interest of justice, it is necessary to hold denovo inquiry
against you through an Inquiry Committee”.

b) Incorrect. The Establishment Division vide letter dated

14.010.2002 as printed at Sr. No. 88 of Esta Code, Vol.-II, has
clarified that if a person is dismissed / removed from service or
compulsory retired, he does not retain the status of a civil servant
for the purpose of any other disciplinary proceedings or imposition
of any other penalty. There is a concept of law that the process of
appeal is the continuation of the original proceedings, therefore, if
a dismissed, removed or retired employee moves a Departmental
Appeal or Representation or files an appeal before the appropriate
judicial forum he deemed to be a civil servant for that particular
matter only under the said concept of continuation of status during
the process of appeal. (P-12/C). Hence, the question of
reinstatement into Government Servants does not arise.

c) Incorrect. The complete documents were annexed with the ibid

charge sheet and were dispatched to the officer accordingly. The
original record pertaining to the instant case has already been
forwarded to nominated inquiry officers vide this office memo
dated 03.08.2017 for conducting of inquiry proceedings through
special courier service (P-7/C). However, the same can be
obtained by him from the inquiry committee officers, as requested
by him for provision of the same.

6. The case is submitted for kind consideration and further orders please.

(Muhammad Bilal Sharif)

AAO Discip. (Legal-I)
August 10, 2017
AO (Legal-I)
 Most Immediate / Confidential

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .08.2017

Syed Taimoor Bukhari,

Ex-BS-17 PA&AS Officer,
135-JII, Johar Town,
Lahore.

SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF

SYED TAIMOOR BUKHARI, BS-17, EX-PA&AS OFFICER
AGAINST AUDITOR GENERAL OF PAKISTAN

Please refer to your request letter bearing No. nil dated

04.08.2017 on the subject cited above.

2. It is intimated that legal lacunas observed vide your letter under

reference have been considered and parawise comments to aforementioned
observations are as follow:

a) Incorrect. The Charge Sheet dated 03.08.2017 for conducting

denovo inquiry is not fresh in nature as it has widely been
described in first and second para of the same Charge Sheet.
Moreover, the said Charge Sheet has been issued in pursuance
of Competent Authority’s order dated 21.06.2017. Hence, no
violation of Rules.

b) Incorrect. The Establishment Division vide letter dated

14.010.2002 as printed at Sr. No. 88 of ESTA Code, Vol.-II, has
clarified that if a person is dismissed / removed from service or
compulsory retired, he does not retain the status of a civil servant
for the purpose of any other disciplinary proceedings or
imposition of any other penalty. There is a concept of law that the
process of appeal is the continuation of the original proceedings,
therefore, if a dismissed, removed or retired employee moves a
Departmental Appeal or Representation or files an appeal before
the appropriate judicial forum he is deemed to be a civil servant
for that particular matter only under the said concept of
continuation of status during the process of appeal (copy
enclosed for ready reference). Hence, the question of
reinstatement into Government Service does not arise.
PTO
 c) Incorrect. The complete documents were annexed with the ibid
charge sheet at the time of dispatching. The original record
pertaining to the instant case has already been forwarded to
nominated inquiry officers vide this office memo dated
03.08.2017 for conducting of inquiry proceedings. However, the
same can be taken from the inquiry committee officers.

3. You are advised to join the de-novo inquiry proceedings and

cooperate with Inquiry Committee during the initiated denovo proceedings against
you.

(Qudratullah Khan)
Director (Legal)
Encl: As above.

Copy for information to:

 SPS to the Deputy Auditor General (A&C) / Authorized Officer
 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC) / Inquiry
Officer, Lahore with reference to accused officer’s letter under reference
and it is requested to inquiry committee to provide the photocopies of
necessary documents to the accused officer as requested him for
preparation of his written defense reply to the leveled charges.
 Mr. Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officers.
 Most Immediate / Confidential

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .08.2017

Sarah Ahmed,
Section Officer (D-III),
Establishment Division, Islamabad.

SUBJECT: APPEAL AGAINST IMPOSITION OF MAJOR PENALTY OF

DISMISSAL FROM SERVICE IN RESPECT OF SYED TAIMOOR
BUKHARI, BS-17, EX-PA&AS OFFICER

Please refer to your office memo No. 8/35/2016-D-3 dated

05.07.2017 on the subject cited above.

2. It is requested to intimate that while conducting the denovo inquiry

proceedings against the subject ex-Officer of PA&AS, in the light of above referred
letter of your office, whether the officer has to be reinstated into service for the
purpose of denovo inquiry or this office may proceed against him otherwise. Rule
position / guidelines may be conveyed to this office.

3. An early response in this matter would be appreciated.

(Qudratullah Khan)
Director (Legal)

Copy for information to:

 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore / Inquiry
Officer
 Mr. Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officers.
 Syed Taimoor Bukhari, Ex-BS-17 PA&AS Officer, 135-JII, Johar Town,
Lahore with reference to his letter dated 04.08.2017 addressed to the Deputy
Auditor General (A&C) / Authorised Officer.
 5/N

19. PUC-I & PUC-II are letters dated 28.08.2017 and 18.08.2017, received from Ms.
Fizza Parvez Afzaal, CMA (LC) / Inquiry Officer, which may kindly be seen.
20. In PUC-I, the inquiry officer has acknowledged the receipt of inquiry material sent to
her vide this office memo dated 03.08.2017 (P-7/C) and vide PUC-II, the inquiry
officer has forwarded a letter dated 23.08.2017 of Syed Taimoor Bukhari, whereby
it has been requested by accused officer to halt the inquiry proceedings till the
decision of the AGP on his representation dated 24.08.2017 addressed to the AGP
(P-16-23/C), which may kindly be seen.
21. PUC-III & IV are letter dated 23.08.2017 addressed to the Inquiry Committee and
Representation to the Authority dated 24.08.2017 addressed to the Auditor General
of Pakistan, which has been received from Syed Taimoor Bukhari, Ex-BS-
17/PA&AS Officer (the accused officer), respectively, which may kindly be seen.
22. The afore-named accused officer has submitted his representation to the AGP
being Authority in his denovo inquiry proceedings conducting in the wake of his
appeal / representation filed by him to the Prime Minister of Pakistan against
imposition of major penalty of “Dismissal from Service”.
23. Vide PUC-IV / Representation of ex-officer has pointed out legal lacunas and
requested for rederessal of the same.
24. With reference to the remarks dated 25.08.2017 of the worthy AGP recorded on the
PUC-IV, the instant representation has been examined and parawise comments on
his observations raised by him are as follow:

Sr.
Observation Reply
No.
1. I respectful draw your kind attention towards No comments
some acts of high-headedness committed by
the administration of AGP office that has
virtually destroyed my life. The details are as
follows:

a. That I was served with a Charge Sheet
No.391-Dr(A)/11-321/Discip. (Annex-A)
b. That Mr. Masood Akhtar Sherwani was
appointed as Inquiry Officer who submitted his
report without fulfilling any of the legal
formalities such as (i) examination of
witnesses under oath;(ii) allowing me to cross
examination the witnesses being examined;
(iii) provision of critical record; and (iv) refusing
to allow Mr. Irfan Jahangir Wattoo (BPS-20
PA&AS) to appear as witness despite a written
request by him.
c. That despite this, he was only able to prove
Correct. A Charge Sheet was issued dated
05.11.2015 to the ex-PA&AS officer on account
of five misconduct, inefficiency and corruption
charges.
The CGA office, Islamabad forwarded request
of Accountant General Punjab, Lahore to this
office to initiate disciplinary proceedings against
Syed Taimoor Bukhari, Assistant Accountant
General, BS-17 Ex-PA&AS officer along with
statement of allegations and a draft of charge
sheet due to misconducts under Rule 5 of the
Government Servants (Efficiency & Discipline)
Rules, 1973.
A Charge Sheet was issued dated 05.11.2015
to the accused officer and Mr. Masood Akhtar
Sherwani, Dy.MAG was appointed as Inquiry
Officer to conduct the proceedings against the
officer vide order dated 05.11.2015.
Mr. Masood Akhter Sherwani, the then Deputy
Sr.
Observation
No.
one charge against me and that too was
partially and based on hearsay opinions of
certain people.
d. That the present MAG, illegally and immorally
proved 3 charges without providing a lawful
opportunity of personal Hearing to me.
e. That to my surprise, ex-AGP dismissed me
from service and while forwarding my
Departmental appeal to the honorable Prime
Minister of Pakistan, stated that all the 5
charges stood proved against me which was
diametrically opposite to the findings of the
Inquiry officer and the contents of the show
Cause notice.
f. That on my departmental appeal, honorable
Prime Minister raised serious observations on
the quality of Inquiry proceedings and on the
quantum of punishment awarded to me and
ordered fresh Inquiry into the matter.
Reply
Military Accountant General (BS-20) PA&AS /
Inquiry Officer who submitted his Inquiry Report
and concluded that three charges out of five
have been fully proved. An opportunity of fair
and just was given to the accused through
issuing Show Cause Notice along with copy of
the Inquiry Report was supplied to the accused
to put his final defense.
Not correct. An opportunity of personal hearing
was given by the DAG (A&C) / Authorised
Officer to Syed Taimoor Bukhari (BS-17/Ex-
PA&AS), Ex-Assistant Accountant General, O/o
the AG, Punjab, Lahore on 02.09.2016 at 1400
hours in his office as requested by the ex-officer
in his reply to the Show Cause Notice No. 159-
Dir (A)/11-321/Discip/15 dated 01.08.2016
received on 25.08.2016 in accordance with
Rule 6 (2) of Govt. Servants (E&D) Rules, 1973.
Vide this office Notification bearing No. 221–
Dir(A)/11-326/Discip/15 dated 09.09.2016,
having been found guilty of the charge of
“Inefficiency” “Misconduct” and “Corruption”
contained in the Show Cause Notice bearing
No.159/Dir(A)/11-321/Discip/15 dated
01.08.2016, the Auditor General of Pakistan in
exercise of powers conferred on him by Rule 3
(a), (b) & (c) read with Rule 5 (1) (iv) of
Government Servants (Efficiency & Discipline)
Rules, 1973 imposed the major penalty of
“Dismissal from Service” in terms of Rules 4 (1)
(b) (iv) of aforesaid Rules upon Syed Taimoor
Bukhari, a BS-17, Ex-PA&AS Officer.
Vide PM office letter dated 21.06.2017 it was
intimated that the Prime Minister / Appellate
Authority has seen the case and is pleased to
observe that Inquiry Officer failed to mention
clearly whether any charge has been proved
against the accused or not. Instead, the report
is full of contradictory statements by the Inquiry
Officer himself. Award of maximum major
penalty on the basis of such an Inquiry Report,
prima-facie, can hardly be justified. At the same
time, the allegations of inefficiency, misconduct
and corruption leveled against the ex-officer are
quite serious and require through investigation
in proper manner.
In view of the above, the Prime Minister while
agreeing with the observations of Establishment
Division at the Para 7, has been pleased to
approve proposal of Estab. Division at Para 9 of
the Summary.
The Establishment Division, vide Para 9 of the
Summary has recommended that the Prime
Minister / Appellate Authority may remand the
case to the Authority / Auditor-General of
Sr.
Observation
No.
g. That Mr. Ikram Khan, Deputy Auditor General
(A&C) instead of complying with the directions
of worthy Prime Minister has issued to me a
fresh Charge Sheet and that too without re-
instating me into service. For reference kindly
see Charge Sheet bearing No. 732-Dir(A)/11-
321/Discip dated 03-08-2017. (Annex-B)
Reply
Pakistan for initiation of de novo inquiry
against Syed Taimoor Bukhari so as to reach
clear findings by establishing or otherwise, the
said charges.
Not correct.
1) In compliance of kind directives of the Prime
Minister dated 21.06.2017, with approval of
the worthy Auditor-General of Pakistan /
Authority for initiating denovo inquiry was
solicited to proceed further in the matter.
As such, for conducting of denovo inquiry
proceedings, a Charge Sheet coupled with
Statement of Allegations in pursuance of
Rule 6-A (2) of the Govt. Servants (E&D)
Rules, 1973, has been issued by the DAG
(A&C) / Authorised Officer to the accused
officer accordingly.
2) The Establishment Division vide letter dated
14.010.2002 as printed at Sr. No. 88 of
ESTA Code, Vol.-II, has clarified that if a
person is dismissed / removed from service
or compulsory retired, he does not retain the
status of a civil servant for the purpose of
any other disciplinary proceedings or
imposition of any other penalty. There is a
concept of law that the process of appeal is
the continuation of the original proceedings,
therefore, if a dismissed, removed or retired
employee moves a Departmental Appeal or
Representation or files an appeal before the
appropriate judicial forum he is deemed to
be a civil servant for that particular matter
only under the said concept of continuation
of status during the process of appeal (copy
enclosed for ready reference) (Page-12/C).
Hence, the question of reinstatement into
Government Service does not arise.
However, this office vide letter dated 06.09.2017
(P-15/C) has requested to Estab. Division to
provide rule position / guidance as to whether
the ex-officer has to be reinstated into Govt.
service for the purpose of denovo inquiry or this
office may proceed against him otherwise,
however, reply thereto is still awaited.
Sr.
Observation
No.
h. That an Inquiry Committee comprising, Mrs.
Fizza Pervez Afzal CMA LC and Mr. Osman
Jawed Lone, has been constituted which has
summoned me to appear before them on 28-
08-2017. (Annex-C)
2 That in this regard I wish to draw your kind
attention towards the following important
issues:
(a) The Government Servants (E&D) Rules, 1973
are only applicable to the Government
Servants; hence you cannot issue a fresh
Charge Sheet to me without first re-instating
me into Government service and thereby
giving me the status of a Government Servant.
This Charge Sheet because Honorable Prime
Minister while examining my Departmental
Appeal had clearly ordered a fresh inquiry and
not issuance of a fresh Charge Sheet.
(b) The aforesaid Charge Sheet is fresh in nature
and has been issued without approval of the
designated “Authority” under Government
Servants (E&D) Rules, hence it is also in
violation of Rule 3 ibid which requires such an
approval, hence, the same is illegal and void
ab-initio.
(c) I can present myself in front of any
committee/officer and prove my innocence
beyond any doubt, if, given a proper chance
according to law. Since, I am dismissed from
service, so, in the capacity of a private person,
I cannot attend an official proceeding.
(d) That in view of the foregoing facts, I request
that I may kindly be re-instated into service
and the legal lacunas as pointed above may
kindly be addressed to proceed further in the
matter and a new Inquiry Officer/Inquiry
Committee may kindly be constituted. I
request that if possible the same may be
chosen from amongst the following officers:
 Mr. Khurram Humayun, (AGPR)
 Mr. Sher Bahadar Arbab, (AG,KPK)
 Mr. Farooq Mohsin, (CF&AO, Cabinet
Division)
Reply
Inquiry committee has been constituted by the
Competent Authority under the prevalent rules
to proceed in the case.
The Authorised Officer initiated proceedings
against ex-civil servant being departmental
inquiry upon directive of the worthy Prime
Minister / Appellate Authority and the officers
entrusted with inquiry task had special
knowledge and practice prevalent in the
department and are in better position to find out
alleged charges.
No comments
As at para g. (2) above.
However, this office vide letter dated
06.09.2017 (P-15/C) has requested to Estab.
Division to provide rule position / guidance as to
whether the ex-officer has to be reinstated into
Govt. service for the purpose of denovo inquiry
or this office may proceed against him
otherwise, however, reply thereto is still
awaited.
Not correct. The Charge Sheet dated
03.08.2017 for conducting of denovo inquiry
proceedings is not fresh in nature as it has
widely been described in first and second para
of the same Charge Sheet. Moreover, said
Charge Sheet has been issued in pursuance of
Prime Minister / Appellate Authority’s order
dated 21.06.2017. Hence, no violation of Rules.
No comments
The accused officer has yet not participated in
the de novo inquiry proceedings initiated
against him vide order of inquiry dated
03.08.2017. The Inquiry Committee also issued
a summons dated 22.08.2017 (P-16/C) to
accused officer for appearance before Inquiry
Committee on 28.08.2017, but accused officer
failed to appear.
The accused officer has requested to
reconstitute inquiry committee of his choice
without giving / assigning any lawful reasons
thereto.
Sr.
Observation Reply
No.
 Mr. Hassan Latif, (DG,AG Punjab)
 Mr. Hassan Masood, (CMA,ISO) The accused officer has no right to give a penal
of his own choice to select the inquiry officer(s) /
inquiry committee and such right is only vested
with designated Authorised Officer / Authority.
(e) For this act of kindness I shall be ever No comments
grateful.

25. Submitted for kind perusal and further orders please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
September 8, 2017
AO (Legal-I)
 Most Immediate / Through Special Courier

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .09.2017

Mrs. Fizza Pervez Afzaal,

Controller Military Accounts (LC) / Inquiry Officer,
Lahore.

SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF

SYED TAIMOOR BUKHARI, BS-17, EX-PA&AS OFFICER
AGAINST AUDITOR GENERAL OF PAKISTAN

Kindly refer to your office memos bearing No. dated 03.08.2017

and 24.08.2017 on the subject cited above.

2. It is requested that original inquiry material (containing three

disciplinary case files) earlier forwarded to your office vide this office memo of even
number dated 03.08.2017, may kindly be returned to this office for record and also
retain complete set of photocopy of the aforesaid inquiry material for the constituted
inquiry committee with the intent of conducting of inquiry proceedings against the
accused officer.
3. The decision of the Authority on accused officer’s representation
dated 23.08.2017, addressed to the Auditor General of Pakistan, is under
consideration, presently, and will be communicated to the constituted inquiry
committee, in the due course of time, accordingly.

(Qudratullah Khan)
Director (Legal)

Copy for information to:

 SPS to the Deputy Auditor General (A&C) / Authorised Officer
 Mr. Osman Jawed Loan, Addl. AGPR (Sub-Office) / Member of Inquiry
Committee, Lahore.
 11/N

37. PUC is a letter dated 14.09.2017 received from the Estab. Division in response to
this office memo of dated 06.09.2017 (P-15/C), whereby it was requested to
provide rule position / guidelines as to whether accused officer be reinstated into
service for the purpose of conducting denovo inquiry against him.

38. Vide PUC, it has been intimated that since the Appellate Authority has not
agreed with the outcome of the previous inquiry report and ordered for a denovo
inquiry in the matter, therefore, any action based on findings of earlier inquiry
report also stands void ab-initio. Before a fresh inquiry is initiated against Mr.
Taimoor Bukhari, Auditor General of Pakistan is required to reinstate him in the
service in accordance with the procedure laid down under Rule 6 of the
Government Servants (E&D) Rules, 1973. The aforesaid rule may be read as
under:

6. Procedure to be observed by the Inquiry Officer and Inquiry Committee.–

Where an Inquiry Officer or Inquiry Committee is appointed, the authorized officer
shall–
(1) Frame a charge and communicate it to the accused together with statement of the
allegations explaining the charge and of any other relevant circumstances which are
proposed to be taken into consideration.
(2) Require the accused within a reasonable time, which shall not be less than seven
days or more than fourteen days from the day the charge has been communicated to
him, to put in a written defense and to state at the same time whether he desires to be
heard in person.
(3) The Inquiry Officer or the Committee, as the case may be, shall enquire into the
charge and may examine such oral or documentary evidence in support of the charge
or in defense of the accused as may be considered necessary and the accused shall
be entitled to cross-examine the witnesses against him.
 (4) The Inquiry Officer or the Committee, as the case may be, shall hear the case from
day to day and no adjournment shall be given except for reasons to be recorded in
writing. However, every adjournment, with reasons therefore shall be reported forthwith
to the authorized officer. Normally no 8 adjournment shall be for more than a week.
(5) Where the Inquiry Officer or the Committee, as the case may be, is satisfied that the
accused is hampering, or attempting to hamper, the progress of the enquiry he or it
shall administer a warning, and if thereafter he or it is satisfied that the accused is
acting in disregard of the warning, he or it shall record a finding to that effect and
proceed to complete the enquiry in such manner as he or it thinks, best suited to do
substantial justice.
(6) The Inquiry Officer or the Committee, as the case may be, shall within ten days of
the conclusion of the proceedings or such longer period as may be allowed by the
authorized officer, submit his or its findings and the ground thereof to the authorized
officer.

6-A. [Revision.–(1) Subject to sub-rule (2), the authority may call for the record of
any case pending before, or disposed of by, the authorized officer and pass
such order in relation thereto as it may deem fit;
(2) No order under sub-rule (1) shall be passed in respect of an accused unless the
authorized officer to be designated by the authority has informed him in writing of the
grounds on which it is proposed to make the order and has been given an opportunity
of showing cause against it, including an opportunity of personal hearing if requested
by the accused or is otherwise necessary in the interest of justice, in particular, when
the authority contemplates to pass an order adverse to the interest of the accused:
Provided that no such opportunity shall be given where the authority, for reasons to be
recorded in writing, is satisfied that, in the interest of security of Pakistan or any part
thereof, it is not expedient to give such an opportunity].

39. Submitted for kind perusal and further orders please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
September 21, 2017
AO (Legal-I)
 Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .10.2017

NOTIFICATION

In pursuance of the decision of the Prime Minister of Pakistan / Appellate

Authority vide letter No. 1841/SPM/17 dated 21.06.2017 and Establishment Division’s
U.O. No. 8/35/2016-D-3 dated 14.09.2017, the Auditor General of Pakistan has been
pleased to reinstate Syed Taimoor Bukhari, a BS-17/PA&AS Officer, into service with
immediate effect for the purpose of conducting of denovo inquiry proceedings against
him vide Charge Sheet bearing No. 732-Dir(A)/11-321/Discip/2015 dated 03.08.2017.

2. This reinstatement into service of Syed Taimoor Bukhari is subject to

findings of the denovo inquiry proceedings and final decision thereto of the Appellate
Authority.

(FAISAL SAEED CHEEMA)

Director Administration

Copy for information and necessary action to:

 The Secretary to the Prime Minister of Pakistan, Prime Minister’s Office,

Islamabad
 The Secretary Establishment, Establishment Division, Islamabad
 The Secretary Finance, Finance Division, Islamabad
 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore and Mr.
Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officers with directions to
proceed against the officer in accordance with the provisions of Government
Servants (Efficiency & Discipline) Rules, 1973.
 Syed Taimoor Bukhari, BS-17 PA&AS Officer, 135-JII, Johar Town, Lahore
with directions to participate in the initiated denovo disciplinary proceedings
immediately.
 Audit Officer PA&AS-II / Confidential-II
Subject: SUMMARY OF THE DISCIPLINARY CASE IN RESPECT OF SYED TAIMOOR
BUKHARI, BS-17 EX-OFFICER PAKISTAN AUDIT AND ACCOUNTS SERVICE

60. Reference preceding paras 37-58/N.

61. A disciplinary case was initiated against Syed Taimoor Bukhari, a BS-17/PA&AS
officer under Government Servants (E&D) Rules, 1973 vide Order of Inquiry
No.392–Dir(A)/11-321/Discip/15 dated 05.11.2015. The Inquiry Officer proved
all charges leveled against him and Authorised Officer issued a Show Cause Notice
bearing No.159/-Dir(A)/11-321/Discip/2015 dated 01.08.2016 to the accused officer
which was replied by the accused officer but not found satisfactory. Thereafter, the
accused officer was given an opportunity of personal hearing on 02.09.2016 but
again could not present cogent defence against the allegations leveled in the
Charge Sheet. Upon findings of the Inquiry Officer proving misconduct committed
by the accused and the recommendations of the Authorised Officer, the Authority
 imposed major penalty of “Dismissal from Service” upon Syed Taimoor Bukhari,
the accused officer vide order dated 09.09.2016.

62. Syed Taimoor Bukhari submitted a representation addressed to the Prime Minister
of Pakistan being Appellate Authority against the imposition of major penalty of
“Dismissal from Service” on him. Upon considering the representation, the Prime
Minister of Pakistan being Appellate Authority remanded the case of Syed Taimoor
Bukhari to the Department for initiation of de-novo inquiry proceedings against the
appellant under the Government Servants (E&D) Rules, 1973.

63. In compliance of the directive of the Appellate Authority, this office vide order dated
03.08.2017 (P-3/C) issued a charge sheet along with statement of allegations for
conducting of denovo inquiry proceedings and constituted an inquiry committee
comprising of two inquiry officers. The aggrieved officer vide his request letter dated
23.08.2017 (P-27-28/C) requested to reinstate him into Government service to
participate in the initiated denovo inquiry proceedings against him being holding the
status of a civil servant.

64. This office vide letter dated 06.09.2017, sought necessary clarification from
Establishment Division as to whether the officer has to be reinstated into service for
the purpose of denovo inquiry. In response to our letter, the Establishment Division
vide letter dated 14.09.2017 (Page-30/C) has advised that before a fresh inquiry is
initiated against Mr. Taimoor Bukhari, Auditor General of Pakistan is required to
reinstate him in the service in accordance with the procedure laid down under Rule
6 of the Government Servants (E&D) Rules, 1973.

65. In the light of approval accorded by the DAG (A&C) contained at para 48/N ante, a
draft notification regarding reinstatement into service, in respect of Syed Taimoor
Bukhari, is submitted for kind approval of the worthy AGP please.

66. Submitted please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
October 10, 2017
AO (Legal-I)
 (To be published in Part-I of the gazette of Pakistan)
Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No.1026 –Dir(A)/11-321/Discip/2015 Dated: 05.01.2017

NOTIFICATION
(Corrigendum)

In continuation of this office Notification of even number dated 23.10.2017,

the Auditor General of Pakistan has been pleased to reinstate Syed Taimoor Bukhari,
a BS-17/PA&AS Officer, into service with effect from 09.09.2016 instead of
23.10.2017 for the purpose of conducting of denovo inquiry proceedings against him
vide Charge Sheet bearing No. 732-Dir(A)/11-321/Discip/2015 dated 03.08.2017
which has been issued in pursuance of the decision of the Prime Minister of Pakistan
/ Appellate Authority vide letter No. 1841/SPM/17 dated 21.06.2017 and also in
pursuance of Establishment Division clarification vide U.O. No. 8/35/2016/-D-3 dated
18.12.2017.

2. This reinstatement into service of Syed Taimoor Bukhari is subject to

findings of the denovo inquiry proceedings and final decision thereto of the Appellate
Authority.

(FAISAL SAEED CHEEMA)

Director Administration
The Manager,
Printing Corporation of Pakistan Press,
Karachi.

Copy for information and necessary action to:

 The Secretary to the Prime Minister of Pakistan, Prime Minister’s Office,

Islamabad
 The Secretary Establishment, Establishment Division, Islamabad
 The Secretary Finance, Finance Division, Islamabad
 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore and Mr.
Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officers w.r.t. letter No.
CMA(LC)/INQUIRY/2017-1 dated 12.12.2017. It is further advised to
proceed against the officer in accordance with the provisions of Government
Servants (Efficiency & Discipline) Rules, 1973.
 The AGPR, Islamabad
 AGPR, Sub Office Lahore.
  Syed Taimoor Bukhari, BS-17 PA&AS Officer, House No. 21-A, Block “G”,
Johar Town, Lahore with directions to participate in the initiated denovo
disciplinary proceedings immediately.
 Audit Officer PA&AS-II / Confidential-II

Page-22/N

Subject: DISCIPLINARY CASE IN RESPECT OF SYED TAIMOOR BUKHARI, BS-

17 EX-OFFICER PAKISTAN AUDIT AND ACCOUNTS SERVICE

84. Reference extract of noting paras 143-146/N taken from personal file of Syed
Taimoor Bukhari, maintained in PA&AS-II Section, which may kindly be
seen. The above referred file is placed below current file.
85. A disciplinary case was initiated against Syed Taimoor Bukhari, a BS-
17/PA&AS officer under Government Servants (E&D) Rules, 1973 vide
Order of Inquiry No.392–Dir(A)/11-321/Discip/15 dated 05.11.2015. The
Inquiry Officer proved all charges leveled against him and Authorised Officer
issued a Show Cause Notice bearing No.159/-Dir(A)/11-321/Discip/2015
dated 01.08.2016 to the accused officer which was replied by the accused
officer but not found satisfactory. Thereafter, the accused officer was given
an opportunity of personal hearing on 02.09.2016 but again could not
present cogent defence against the allegations leveled in the Charge Sheet.
Upon findings of the Inquiry Officer proving misconduct committed by the
accused and the recommendations of the Authorised Officer, the Authority
imposed major penalty of “Dismissal from Service” upon Syed Taimoor
Bukhari, the accused officer vide order dated 09.09.2016.
86. Syed Taimoor Bukhari submitted a representation addressed to the Prime
Minister of Pakistan being Appellate Authority against the imposition of major
penalty of “Dismissal from Service” on him. Upon considering the
representation, the Prime Minister of Pakistan being Appellate Authority
remanded the case of Syed Taimoor Bukhari to the Department for initiation
of de-novo inquiry proceedings against the appellant under the Government
Servants (E&D) Rules, 1973.
87. In compliance of the directive of the Appellate Authority, this office vide order
dated 03.08.2017 (P-03/C) issued a charge sheet along with statement of
allegations for conducting of denovo inquiry proceedings and constituted an
inquiry committee comprising of two inquiry officers. The aggrieved officer
 vide his request letter dated 23.08.2017 (P-27-28/C) requested to reinstate
him into Government service to participate in the initiated denovo inquiry
proceedings against him being holding the status of a civil servant.
PTO

Page-23/N

From pre-page

88. This office through letter dated 06.09.2017, sought necessary clarification
from Establishment Division as to whether the officer has to be reinstated
into service for the purpose of denovo inquiry. In response to our letter, the
Establishment Division vide letter dated 14.09.2017 (Page-30/C) has
advised that before a fresh inquiry is initiated against Mr. Taimoor Bukhari,
Auditor General of Pakistan is required to reinstate him in the service in
accordance with the procedure laid down under Rule 6 of the Government
Servants (E&D) Rules, 1973. Accordingly in the light of afore stated
clarification from Estab. Division, Syed Taimoor Bukhari was reinstated vide
notification dated 23.10.2017 with immediate effect (Page-40/C) and he
submitted his joining on 14.11.2017.
89. The PA&AS Section sought necessary clarification from Regulation Wing (of
this office) regarding his date of reinstatement into service and opined that
accused officer is required to be reinstated w.e.f. 09.09.2016 (date of his
dismissal).
90. Forgoing in view, a draft corrigendum to this office Notification dated
23.10.2017 (Page-40/C) to reinstate the officer w.e.f. 09.09.2016 instead of
23.10.2017 is added for kind approval / signature of the Director
(Administration).
91. Submitted please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
November 22, 2017
AO (Legal-I)
Subject: DISCIPLINARY CASE IN RESPECT OF SYED TAIMOOR BUKHARI, BS-
17 EX-OFFICER PAKISTAN AUDIT AND ACCOUNTS SERVICE

147. Reference paras 143-146/N ante refers.

148. It is stated that a disciplinary case was initiated against Syed Taimoor Bukhari, a
BS-17/PA&AS officer under Government Servants (E&D) Rules, 1973 vide
Order of Inquiry No.392–Dir(A)/11-321/Discip/15 dated 05.11.2015. The Inquiry
Officer proved all charges leveled against him and Authorised Officer issued a
Show Cause Notice bearing No.159/-Dir(A)/11-321/Discip/2015 dated
01.08.2016 to the accused officer which was replied by the accused officer but
not found satisfactory. Thereafter, the accused officer was given an opportunity
of personal hearing on 02.09.2016 but again could not present cogent defence
against the allegations leveled in the Charge Sheet. Upon findings of the Inquiry
Officer proving misconduct committed by the accused and the recommendations
of the Authorised Officer, the Authority imposed major penalty of “Dismissal
from Service” upon Syed Taimoor Bukhari, the accused officer vide order
dated 09.09.2016.
149. Syed Taimoor Bukhari submitted a representation addressed to the Prime
Minister of Pakistan being Appellate Authority against the imposition of major
penalty of “Dismissal from Service” on him. Upon considering the
 representation, the Prime Minister of Pakistan being Appellate Authority
remanded the case of Syed Taimoor Bukhari to the Department for initiation of
de-novo inquiry proceedings against the appellant under the Government
Servants (E&D) Rules, 1973.
150.
151. In compliance of the directive of the Appellate Authority, this office vide order
dated 03.08.2017 issued a charge sheet along with statement of allegations for
conducting of denovo inquiry proceedings and constituted an inquiry
committee comprising of two inquiry officers. The aggrieved officer vide his
request letter dated 23.08.2017 requested to reinstate him into Government
service to participate in the initiated denovo inquiry proceedings against him
being holding the status of a civil servant.
152. This office through letter dated 06.09.2017, sought necessary clarification from
Establishment Division as to whether the officer has to be reinstated into service
for the purpose of denovo inquiry. In response to our letter, the Establishment
Division vide letter dated 14.09.2017 has advised that before a fresh inquiry is
initiated against Mr. Taimoor Bukhari, Auditor General of Pakistan is required to
reinstate him in the service in accordance with the procedure laid down under
Rule 6 of the Government Servants (E&D) Rules, 1973. Accordingly in the light
of afore stated clarification from Estab. Division, Syed Taimoor Bukhari was
reinstated vide notification dated 23.10.2017 with immediate effect and in
compliance he has submitted his joining on 14.11.2017.
153. The PA&AS Section vide para 144/N ante sought necessary clarification from
Regulation Wing (of this office) regarding his date of reinstatement into service
and opined that accused officer is required to be reinstated w.e.f. 09.09.2016
(date of his dismissal).
154. Forgoing in view, a draft corrigendum to this office Notification dated 23.10.2017
to reinstate the officer into service w.e.f. 09.09.2016 instead of 23.10.2017 is
being processed on another file of Legal wing file maintained in respect of officer
for kind approval / signature of the Director (Administration).
155. Submitted please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
November 24, 2017
AO (Legal-I)
 Most Immediate / Confidential

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad
No. –Dir(A)/11-321/Discip/2015 Dated: .11.2017

Dr. Ejaz Ahmad,

Section Officer (D-III),
Establishment Division, Islamabad.

SUBJECT: APPEAL AGAINST IMPOSITION OF MAJOR PENALTY OF

DISMISSAL FROM SERVICE IN RESPECT OF SYED TAIMOOR
BUKHARI, BS-17, EX-PA&AS OFFICER

Please refer to your office memo No. 8/35/2016-D-3 dated

14.09.2017 on the subject cited above.

2. Specific date on which Syed Taimoor Bukhari is required to be

reinstated into service and whether a fresh charge sheet is required to be served upon
the afore named officer for the purpose of denovo inquiry or otherwise need
clarification. Rule position / guidelines may also be conveyed to this office.

3. An early response in this matter would be appreciated.

(SHEENA ALI MANSOOR)

Director (Legal)

Copy for information to:

 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore / Inquiry
Officer.
 Mr. Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officer.
 Syed Taimoor Bukhari, BS-17 PA&AS Officer, House No. 21-A, Block “G”,
Johar Town, Lahore
 98. PUC is letter dated 12.12.2017 received from Mrs. Fizza Parvez Afzaal, CMA
(LC), Lahore, which may kindly be perused.
99. The office vide letter dated 30.11.2017 (P-43/C) requested to the Estab.
Division to clarify under the prevalent rules about the specific date on which
Syed Taimoor Bukhari is required to be reinstated into service and whether a
fresh charge sheet is required to be served upon the afore named officer for
the purpose of denovo inquiry or otherwise. However, response thereto from
Estab. Div. is still awaited.
100. Inquiry officer vide PUC has requested to clarify if the inquiry proceedings
should be stopped till response from Estab. Division, or otherwise.
101. Submitted for kind consideration and further orders please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
15.12.2017
AO (Legal-I)

25/N
40. PUC is a letter dated 18.12.2017 received from the Estab. Division in response to
this office memo of dated 30.11.2017 (P-45/C), which may kindly be seen.
41. The Establishment Division has opined that inquiry should be for the same charges
by another inquiry officer. Addition of fresh charges at this stage of the case may
lead to malafide in case of judicial adjudication of the matter. For the purpose of re-
instatement of the officer is concerned, he has to be re-instated from the date of
dismissal from Government service.
42. A draft notification in the light of above clarification from Estab. Div. is placed at
Page-42/C please. It is further submitted that competent authority has already
appointed inquiry committee comprising of two inquiry members to conduct
denovo inquiry proceedings on the same charges (as contained in previous charge
sheet) against the accused officer (P-3/C).
43. The previous inquiry was conducted by Mr. Masood Akhtar Sherwani, the then Dy.
MAG, Rawalpindi.
44. Submitted for kind consideration and further orders please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
20.12.2017
AO (Legal-I)
 Most Immediate / Through Special Courier

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .01.2018

Mrs. Fizza Pervez Afzaal,

Controller Military Accounts (LC) / Head of Inquiry Committee,
Lahore.

SUBJECT: PROVISION OF INQURIY REPORT IN DISCIPLINARY CASE

INITIATED AGAINST SYED TAIMOOR BUKHARI, BS-17 /
PA&AS OFFICER (DENOVO INQUIRY PROCEEDINGS)
Kindly refer to the subject cited above.

2. In pursuance of the orders of the Prime Minister / Appellate

Authority vide letter No. 1841/SPM/17 dated 21.06.2017; denovo inquiry
proceedings have been initiated against Syed Taimoor Bukhari, a BS-17/PA&AS
officer vide order of inquiry dated 03.08.2017.

3. The inquiry report is still awaited on which an update and timeline

may be forwarded for record.

(SHEENA ALI MANSOOR)

Director (Legal)

Copy for information to:

 SPS to the Deputy Auditor General (A&C) / Authorised Officer
 Mr. Osman Jawed Loan, Addl. AGPR (Sub-Office) / Member Inquiry
Committee, Lahore.
 30/N

SUBJECT: PROVISION OF INQURIY REPORT IN DISCIPLINARY CASE

INITIATED AGAINST SYED TAIMOOR BUKHARI, BS-17 / PA&AS
OFFICER

(DENOVO INQUIRY PROCEEDINGS)

126. In pursuance of the orders of the Prime Minister / Appellate Authority

vide letter No. 1841/SPM/17 dated 21.06.2017 (P-51/C); denovo
inquiry proceedings have been initiated against Syed Taimoor Bukhari, a
BS-17/PA&AS officer vide order of inquiry dated 03.08.2017.
127. The Competent Authority constituted an inquiry committee comprising
of two members and appointed Mrs. Fizza Pervez Afzaal, Controller
Military Accounts (LC) as Head of Inquiry Committee, Lahore and Mr.
Osman Jawed Loan, Addl. AGPR (Sub-Office) / Member Inquiry
Committee, Lahore vide order of inquiry dated 03.08.2017 (P-3/C).
However, Inquiry Report is still awaited.
128. As such a draft reminder is added for signature please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
12.01.2018
AO (Legal-I)
 (To be published in Part-I of the gazette of Pakistan)
Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No.1026 –Dir(A)/11-321/Discip/2015 Dated: 05.01.2017

NOTIFICATION
(Corrigendum)

In continuation of this office Notification of even number dated 23.10.2017, the

Auditor General of Pakistan has been pleased to reinstate Syed Taimoor Bukhari, a BS-
17/PA&AS Officer, into service with effect from 09.09.2016 instead of 23.10.2017 for the
purpose of conducting of denovo inquiry proceedings against him vide Charge Sheet bearing
No. 732-Dir(A)/11-321/Discip/2015 dated 03.08.2017 which has been issued in pursuance of
the decision of the Prime Minister of Pakistan / Appellate Authority vide letter No.
1841/SPM/17 dated 21.06.2017 and also in pursuance of Establishment Division clarification
vide U.O. No. 8/35/2016/-D-3 dated 18.12.2017.

3. This reinstatement into service of Syed Taimoor Bukhari is subject to findings of

the denovo inquiry proceedings and final decision thereto of the Appellate Authority.

(FAISAL SAEED CHEEMA)

Director Administration
The Manager,
Printing Corporation of Pakistan Press,
Karachi.

Copy for information and necessary action to:

 The Secretary to the Prime Minister of Pakistan, Prime Minister’s Office, Islamabad
 The Secretary Establishment, Establishment Division, Islamabad
 The Secretary Finance, Finance Division, Islamabad
 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore and Mr.
Osman Jawed Loan, Addl. AGPR, Lahore / Inquiry Officers w.r.t. letter No.
CMA(LC)/INQUIRY/2017-1 dated 12.12.2017. It is further advised to proceed
against the officer in accordance with the provisions of Government Servants
(Efficiency & Discipline) Rules, 1973.
 The AGPR, Islamabad
 AGPR, Sub Office Lahore.
 Syed Taimoor Bukhari, BS-17 PA&AS Officer, House No. 21-A, Block “G”, Johar
Town, Lahore with directions to participate in the initiated denovo disciplinary
proceedings immediately.
 Audit Officer PA&AS-II / Confidential-II
 Most Immediate / Through Special Courier

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .01.2018

Mrs. Fizza Pervez Afzaal,

Controller Military Accounts (LC) / Head of Inquiry Committee,
Lahore.

SUBJECT: INQUIRY INTO ALLEGED FRAUD OCCURRED IN THE OFFICE

OF ACCOUNTANT GENERAL PUNJAB, LAHORE
Kindly refer to the subject cited above and find enclosed herewith
a copy of Accountant General Punjab letter No. E&D/CD-2392 dated 19.12.2017
along with enclosures (copy annexed).

2. The Chief Minister of Punjab constituted an inquiry committee to

probe into the alleged fraud occurred in the office of Accountant General Punjab in
June, 2014. The inquiry team under the chairmanship of Mr. Pervaiz Masood, former
Chief Secretary has submitted its detailed inquiry report dated 10.07.2014 on the
subject matter. The aforementioned inquiry report is relevant to denovo inquiry
proceedings initiated against Syed Taimoor Bukhari, a BS-17/PA&AS being co-
accused in the cited matter. The aforesaid inquiry report is being forwarded for
consideration and making it part as part of the initiated inquiry proceedings.

(SHEENA ALI MANSOOR)

Director (Legal)
Encl: As above.

Copy for information to:

 SPS to the Deputy Auditor General (A&C) / Authorised Officer
 Mr. Osman Jawed Loan, Addl. AGPR (Sub-Office) / Member Inquiry
Committee, Lahore.
SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF SYED
TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER

139. PUC-I is letter dated 23.01.2018 (P-74/C) from Mr. Osman Jawed Lone,
Addl. AG (AG Punjab) / Inquiry Officer, which may kindly be seen.
140. Inquiry Officer has intimated that a Charge Sheet dated 03.08.2017 (P-
6/C) was issued to Mr. Bukhari who was not in service at that time and
resumed the status of government servant upon reinstatement w.e.f.
09.09.2016 (P-49/C) solely for the purpose of inquiry. Since the denovo
inquiry proceedings are to be conducted afresh, therefore, it is requested
 that the original charge sheet dated 05.11.2015 may be revived through
re-notification for the purpose of conducting denovo inquiry.
141. Brief facts of the case is that in pursuance of the orders of the Prime
Minister / Appellate Authority vide letter No. 1841/SPM/17 dated
21.06.2017 (P-51/C); denovo inquiry proceedings were initiated against
Syed Taimoor Bukhari, a BS-17/PA&AS officer vide order of inquiry
dated 03.08.2017 (P-6/C) the Competent Authority constituted an
inquiry committee comprising of two members and appointed Mrs.
Fizza Pervez Afzaal, Controller Military Accounts (LC) as Head of
Inquiry Committee, Lahore and Mr. Osman Jawed Loan, Addl. AGPR
(Sub-Office) / Member Inquiry Committee, Lahore.
142. Proposal/contention of the Inquiry Officer conveyed vide Para -2 of PUC-
I is submitted for kind consideration please.
143. PUC-II & III are letters dated 11.01.2018 and 21.01.2018 received from
Syed Taimoor Bukhari, accused officer, which may kindly be seen.
144. Vide PUC-I, delinquent officer have raised the following observations
pertaining to his denovo disciplinary proceedings. The observations
pointed out has been commented in the table mentioned below, which
may read as follow:
S. Accused Officer’s Observations Facts
No.
(a) That the charge sheet bearing No.732- Charge sheet dated 03.08.2017 (P-6/C) was
Dir(A)/11-321/Discip, upon which I am issued in pursuance of the orders of the
being proceeded against, was issued on PM/Appellate Authority vide letter dated
03-08-2017 when I was not civil servant 21.06.2017 to hold denovo inquiry proceedings
as I had not been re-instated into in the wake of his departmental appeal filed to
service. the PM/Appellate Authority against the
imposition of major penalty of dismissal from
service (P-51/C). The officer has been
reinstated into service w.e.f. 09.09.2016 (the
date of dismissal) (P-50/C), therefore, the
issued charge sheet is valid document of
inquiry proceedings initiated.
Since the officer has been reinstated w.e.f.
09.09.2016, therefore, charge sheet dated
03.08.2017 to conduct denovo inquiry is in
order.
(b) That the aforesaid charge sheet was Not correct. The Charge Sheet dated
fresh in nature and had been issued 03.08.2017 duly approved by the AGP for
without approval of the designated conducting of denovo inquiry proceedings is
“Authority” under Government Servant not fresh in nature but issued in pursuance of
(E&D) Rule, 1973, hence it is in violation the orders of the PM/Appellate Authority vide
of Rule 3 ibid which requires such an letter dated 21.06.2017 and under Rule 6 (A-2)
approval, hence the same is illegal and of E&D Rules, 1973 as it has clearly been
void ab-initio. Kindly read the same and described in first and second paras of the
see for yourself that there is no mention Charge Sheet dated 03.08.2017 (P-6/C).
if the approval of “Authority” therein and As the Appellate Authority has declared void
also, the previous charge sheet was not abinitio the findings of the inquiry officer
withdrawn.
therefore there is no question arise to
withdraw the previous charge sheet dated
05.11.2015 (P-21-20/C).
Moreover, no additional charge has been
added in the charge sheet for holding denovo

(c) That the Government Servants (E&D)
Rules, 1973 are only applicable to the
Government Servants, however the
aforementioned charge sheet was issued
to a dismissed civil Servant. This charge
sheet cannot be treated as continuation
of my previous charge sheet because
Honorable Prime Minister while
examining my Departmental Appeal and
clearly ordered a fresh inquiry and not
issuance of a fresh charge sheet.
(d) That despite my repeated requests and
concerns respected Mrs. Fizza Pervaiz
Afzaal has not been replaced with a new
inquiry officer, I draw kind attention
towards the fact that first charge in the
charge sheet was that I got myself
posted to AG office Punjab from the
office of the DG PT&T. One of the inquiry
officers, respected Madam Mrs. Fizza
Pervaiz was my Director during the
incumbency as Assistant Director, PT&T
Audit. Since she can be a witness/party
in the ongoing proceedings, she cannot
be appointed as my inquiry officer
proceedings. Hence, no violation of Rules.
The officer has been reinstated into service
upon clarification sought from Estab. Division
w.e.f. 09.09.2016 (P-50/C), therefore, the
issued charge sheet dated 03.08.2017 is valid
document of denovo inquiry proceedings
initiated against reinstated civil servant.
A second charge sheet on the same allegations
against the officer who has been proceeded
already; cannot be issued twice to avoid double
jeopardy.
To hold the denovo proceedings issuance of
charge sheet is necessary to convey the
charges to the accused officer to submit his
proper defence as well as to the inquiry officer /
inquiry committee to conduct inquiry afresh in
pursuance of PM/Appellate Authority.
The first charge leveled against him pertains to
the case of AG Punjab instead of PT&T and
have no relevancy with it. Service history paper
in respect of respected Mrs. Fizza Pervaiz
Afzaal, Head of Inquiry Committee is placed at
page 75/C please.

145. Through PUC-III (P-67/C), the accused officer has requested for
provision of annexures as mentioned in the charge sheet dated
03.08.2017 and further contended that vide para 3 (i) to provide fact
finding report conducted by the Mr. Mubarak Shah, DG O/o the CGA and
Dr. Luqman Masood, Addl. AG Punjab to defend his self.
146. The annexures to the charges issued vide charge sheet dated 03.08.2017
were forwarded to him complete in all respects with charge sheet. Later
on the all original files of the case were forwarded to the inquiry
committee for the purpose of conducting of denovo inquiry.
147. In this regard it is proposed that Inquiry Committee may be requested to
provide the relevant documents to the accused officer as desired by him.
148. Submitted for kind consideration and further orders; please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
29.01.2018
AO (Legal-I)
 Most Immediate / Through Special Courier

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .02.2018

Mr. Osman Jawed Lone,

Addl. Accountant General / Inquiry Officer,
O/o the AGPR (SO),
Lahore.

SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF

SYED TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER
Kindly refer to your office letter No. AGPR/SOL/CD/279 dated
23.01.2018 on the subject captioned above.

2. In pursuance of orders of the Prime Minister / Appellate Authority

vide letter No. 1841/SPM/17 dated 21.06.2017 whereby the case was remanded
back to the Authority/AGP to hold “denovo inquiry proceedings” in the wake of
appeal / representation filed by Syed Taimoor Bukhari, Ex-Assistant Accountant
General (BPS-17/PA&AS) against his major penalty of “Dismissal from Service”
w.e.f. 09.09.2016.

3. The Deputy Auditor General (A&C) being Authorized Officer, in

terms of Rule 5 (1) (ii) read with Rule 6-A (2) of the Government Servants (Efficiency
& Discipline) Rules, 1973 issued a Charge Sheet of even number dated 03.08.2017
to hold “denovo inquiry proceedings” on the same allegations as served earlier
vide Charge Sheet dated 05.11.2015 upon delinquent officer, so as to reach clear
findings by establishing or otherwise, the said charges.

4. It is clarified that where “Appellate Authority” decides to proceed

afresh against civil servant under Rule 6-A (2) (copy attached) of the Rules ibid,
then Authority is legally bound to serve a fresh notice/Charge Sheet for the purpose
upon civil servant, who should be given fair opportunity of showing cause against
proposed action as no one could be condemned unheard in violation of maxim “audi
alteram partem”.

Continued Page…….2
 -2-

5. However, since the charged officer has been reinstated into

service w.e.f. 09.09.2016, therefore, the Charge Sheet issued on 03.08.2017 is in
field for holding denovo proceedings.

6. Syed Taimoor Bukhari (accused officer) may be provided all the

relevant copies of annexures referred in the Charge Sheet dated 03.08.2017 as
desired by him vide letter 21.01.2018 (copy enclosed) as the original disciplinary
case files are resting with Inquiry Committee. The date of corrigendum Notification of
even number issued for reinstatement into service may be read as 05.01.2018
(copy annexed).

7. Foregoing in view, it is requested to complete the inquiry

proceedings under the prevalent rules for onward submission to the “Appellate
Authority/Prime Minister” for his decision in terms of Rule 6-A (2) of E&D Rules,
1973 without any further delay.

(SHEENA ALI MANSOOR)

Director (Legal)
Encl: As above.

Copy for information to:

 SPS to the Deputy Auditor General (A&C) / Authorised Officer
 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC) / Head of
Inquiry Committee, Lahore.
 Syed Taimoor Bukhari, Ex-Assistant Accountant General (BPS-
17/PA&AS) w.r.t. to request letter dated 11.01.2018 and 21.01.2018 with
directions to submit written defence to the Inquiry Committee
immediately under the rules.
 Most Immediate / Through Special Courier

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .02.2018

SUBJECT: CORRIGENDUM

DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF SYED

TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER

Kindly refer to Charge Sheet bearing even number dated 03.08.2017 issued
against Syed Taimoor Bukhari (BS-17/PA&AS) for conducting of denovo inquiry
proceedings.

2. The Auditor General being Authority has ordered to withdraw the above
referred Charge Sheet dated 03.08.2017 and has been pleased to proceed against Syed
Taimoor Bukhari (BS-17/PA&AS), on the Charge Sheet issued earlier against him on
05.11.2015; in pursuance of orders of the Prime Minister / Appellate Authority vide letter
No. 1841/SPM/17 dated 21.06.2017 and under Rule 5 (1) (ii) read with Rule 6-A (2) of the
Government Servants (Efficiency & Discipline) Rules, 1973.

(Muhammad Siddique Tariq Joya)

Deputy Auditor-General (A&C) /
Authorized Officer

Copy for information to:

1. SPS to the Auditor General / Authority
2. Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC) / Head of Inquiry
Committee, Lahore.
3. Mr. Osman Jawed Lone, Addl. Accountant General / Inquiry Officer, O/o the AGPR
(SO), Lahore w.r.t. letter No. AGPR/SOL/CD/279 dated 23.01.2018.
4. Syed Taimoor Bukhari, (BPS-17/PA&AS) w.r.t. request letter dated 11.01.2018 and
21.01.2018.
 35/N
SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF
SYED TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER
152. With reference to the remarks at para 151/N ante, the matter was discussed on
12.02.2018 in detail with Director (Legal).
153. Brief facts of the case are that in pursuance of orders of the Prime Minister /
Appellate Authority vide letter No. 1841/SPM/17 dated 21.06.2017 whereby the
case was remanded back to the Authority/AGP to hold “denovo inquiry
proceedings” in the wake of appeal / representation filed by Syed Taimoor
Bukhari, Ex-Assistant Accountant General (BPS-17/PA&AS) against his major
penalty of “Dismissal from Service” w.e.f. 09.09.2016.
154. The Deputy Auditor General (A&C) being Authorized Officer, in terms of Rule 5
(1) (ii) read with Rule 6-A (2) of the Government Servants (Efficiency &
Discipline) Rules, 1973 issued a Charge Sheet on 03.08.2017 to hold “denovo
inquiry proceedings” on the same allegations as served earlier vide Charge
Sheet dated 05.11.2015 upon delinquent officer, so as to reach clear findings by
establishing or otherwise, the said charges.
155. Syed Taimoor Bukhari, aggrieved officer, was not reinstated into service before
issuance of said charge sheet dated 03.08.2017 and his status was deemed to
be a Civil Servant as prescribed in Establishment Division letter dated
14.01.2002 (P-12/C).
156. However, upon clarification sought by this office from Establishment Division;
Syed Taimoor Bukhari, BS-17/PA&AS was reinstated into service w.e.f.
09.09.2016 (the date of dismissal) (P-47/C).
157. It is submitted that where “Appellate Authority” decides to proceed afresh
against civil servant under Rule 6-A (2) of the Rules ibid, then Authority is
legally bound to serve a fresh notice/Charge Sheet for the purpose upon civil
servant, who should be given fair opportunity of showing cause against
proposed action as no one could be condemned unheard in violation of maxim
“audi alteram partem”.
158. In the light of above rules position, it is submitted that since the delinquent
officer has been reinstated into service w.e.f. 09.09.2016, therefore, the Charge
Sheet issued on 03.08.2017 is in field for holding denovo inquiry proceedings.
159. Submitted for kind perusal and further orders please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
12.02.2018
AO (Legal-I) on CL

Deputy Director (Legal)

Director (Legal)
 Most Immediate / Through Special Courier

Office of the
Auditor General of Pakistan
Constitution Avenue, Islamabad

No. 1032–Dir(A)/11-321/Discip/2015 Dated: 21.02.2018

Mr. Osman Jawed Lone,

Addl. Accountant General / Inquiry Officer,
O/o the AGPR (SO),
Lahore.

SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF SYED

TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER

Kindly refer to your office letter No. AGPR/SOL/CD/279 dated

23.01.2018 on the subject captioned above.

2. In pursuance of orders of the Prime Minister / Appellate Authority vide

letter No. 1841/SPM/17 dated 21.06.2017 whereby the case was remanded back to the
Authority/AGP to hold “denovo inquiry proceedings” in the wake of appeal /
representation filed by Syed Taimoor Bukhari, Ex-Assistant Accountant General (BPS-
17/PA&AS) against his major penalty of “Dismissal from Service” w.e.f. 09.09.2016.

3. The Deputy Auditor General (A&C) being Authorized Officer, in terms of

Rule 5 (1) (ii) read with Rule 6-A (2) of the Government Servants (Efficiency & Discipline)
Rules, 1973 issued a Charge Sheet of even number dated 03.08.2017 to hold “denovo
inquiry proceedings” on the same allegations as served earlier vide Charge Sheet dated
05.11.2015 upon delinquent officer, so as to reach clear findings by establishing or
otherwise, the said charges. While issuing the Charge Sheet dated 03.08.2017, the status
of Appellant was deemed to be a Civil Servant as prescribed in Establishment Division letter
dated 14.01.2002 (copy attached).

4. It is clarified that where “Appellate Authority” decides to proceed

afresh against civil servant under Rule 6-A (2) (copy attached) of the Rules ibid, then
Authority is legally bound to serve a fresh notice/Charge Sheet for the purpose upon civil
servant, who should be given fair opportunity of showing cause against proposed action as
no one could be condemned unheard in violation of maxim “audi alteram partem”.

Continued Page…….2
 -2-

5. However, since the charged officer has been reinstated into service
w.e.f. 09.09.2016, therefore, the Charge Sheet issued on 03.08.2017 is in field for
holding denovo proceedings.

6. Syed Taimoor Bukhari (accused officer) may be provided all the

relevant copies of annexures referred in the Charge Sheet dated 03.08.2017 as desired
by him vide letter 21.01.2018 (copy enclosed) as the original disciplinary case files are
resting with Inquiry Committee. The date of corrigendum Notification of even number
issued for reinstatement into service may be read as 05.01.2018 (copy annexed).

7. Foregoing in view, inquiry proceedings under the prevalent rules may

be completed for onward submission to the “Appellate Authority/Prime Minister” for his
decision in terms of Rule 6-A (2) of E&D Rules, 1973 without any further delay.

(SHEENA ALI MANSOOR)

Director (Legal)
Encl: As above.

Copy for information to:

 SPS to the Deputy Auditor General (A&C) / Authorised Officer
 Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC) / Head of Inquiry
Committee, Lahore.
 Syed Taimoor Bukhari, Ex-Assistant Accountant General (BPS-17/PA&AS)
w.r.t. to request letter dated 11.01.2018 and 21.01.2018 with directions to
submit written defence to the Inquiry Committee immediately under the
rules.
SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF SYED
TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER

168. PUC is a letter dated 21.02.2018 received from Syed Taimoor Bukhari, BS-
17/PA&AS Officer, which may kindly be seen (P-86-87/C).
169. Vide Para 3 of PUC, the accused officer has invited attention towards issues
pertaining to his case, which are self explanatory, the same may be glanced
through, please.
170. The issues mentioned above, has already been discussed on each issue ibid in detail
vide Para 144/N ante, which may kindly be seen.
171. In response to Para 4 of PUC, a comprehensive reply has already been issued
recently vide this office memo dated 21.02.2018 (P-84-85/C).
172. Submitted for kind perusal and further orders.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
23.02.2018
AO (Legal-I)
SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF SYED
TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER
168. PUC is a letter dated 26.02.2018 received from Syed Taimoor Bukhari, BS-
17/PA&AS Officer, which may kindly be seen.
169. The contents of the PUC are of self explanatory, which may kindly be perused.
170. Vide Para 10 of PUC, the accused officer has requested followings;

a. to withdraw one charge sheet dated 03.08.2017 or earlier charge

sheet dated 05.11.2015 and
b. replacement of one of the member of constituted inquiry committee
respected Mrs. Fizza Pervez Afzaal (one of the senior officer of
PA&AS Mr. Irfan Jehangir Wattoo, BS-20) is going to appear as
witness in the instant case.

171. W.r.t. para 170 (a)/N, it is stated that fresh charge sheet was issued on same
charges to the accused officer for the purpose of holding of denovo inquiry
proceedings. Hence, the previous charge sheet dated 05.11.2015 has lose its
efficacy and is no more in field, accordingly.
172. However, w.r.t. para 170 (b)/N, no request / comment / proposal has yet been
received from Mrs. Fizza Pervez Afzaal, CMA (LC) / Head Inquiry Committee,
Lahore.
173. Submitted for kind perusal and further orders.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
05.03.2018
AO (Legal-I)
 39/N

BRIEF ON DISCIPLINARY CASE IN RESPECT OF SYED TAIMOOR BUKHARI, BS-17

EX-OFFICER PAKISTAN AUDIT AND ACCOUNTS SERVICE

Reference is invited to discussion with Deputy Director (legal) on 12.03.2018. A brief of the
case is submitted for kind perusal as desired.

A disciplinary case was initiated against Syed Taimoor Bukhari, a BS-17/PA&AS officer
under Government Servants (E&D) Rules, 1973 vide Order of Inquiry No.392–Dir(A)/11-
321/Discip/15 dated 05.11.2015. Mr. Masood Akhtar Sherwani, Dy. MAG being Inquiry
Officer proved all charges leveled against him and Authorised Officer issued a Show
Cause Notice bearing No.159/-Dir(A)/11-321/Discip/2015 dated 01.08.2016 to the accused
officer which was replied by the accused officer but not found satisfactory. Thereafter, the
accused officer was given an opportunity of personal hearing on 02.09.2016 but again
could not present cogent defence against the allegations leveled in the Charge Sheet.
Upon findings of the Inquiry Officer proving misconduct committed by the accused and the
recommendations of the Authorised Officer, the Authority imposed major penalty of
“Dismissal from Service” upon Syed Taimoor Bukhari, the accused officer vide order
dated 09.09.2016.

Syed Taimoor Bukhari submitted a representation addressed to the Prime Minister of

Pakistan being Appellate Authority against the imposition of major penalty of “Dismissal
from Service” upon him. However, on considering the filed representation, the Prime
Minister of Pakistan being Appellate Authority remanded back the case of Syed Taimoor
Bukhari to the Department for initiation of de-novo inquiry proceedings against the
appellant under the Government Servants (E&D) Rules, 1973.

In compliance of the directive of the Appellate Authority, this office vide order dated
03.08.2017 issued a charge sheet along with statement of allegations on the same
allegations for conducting of denovo inquiry proceedings and constituted an inquiry
committee comprising of two inquiry officers i.e. Mrs. Fizza Pervez Afzaal, CMA (LC) /
Head Inquiry Committee and Mr. Osman Javed Loan, Addl. AG / Inquiry Member, AGPR
(SO), Lahore. The aggrieved officer vide his request letter dated 23.08.2017 requested to
reinstate him into Government service to participate in the initiated denovo inquiry
proceedings against him being holding the status of a civil servant.

AGP office vide letter dated 06.09.2017, sought necessary clarification from Establishment
Division as to whether the officer has to be reinstated into service for the purpose of
denovo inquiry. In response to our letter, the Establishment Division vide letter dated
14.09.2017 has advised that before a fresh inquiry is initiated against Mr. Taimoor Bukhari,
Auditor General of Pakistan is required to reinstate him in the service in accordance with
the procedure laid down under Rule 6 of the Government Servants (E&D) Rules, 1973.
Accordingly in the light of afore stated clarification from Estab. Division, Syed Taimoor
Bukhari was reinstated into service vide Notification dated 05.01.2018 with effect from
date of dismissal i.e. 09.09.2016.

The accused officer vide his letter dated 21.02.2018 (P-88-89/C) has raised certain
observation which have been discussed in detail. In this regard para 144/N may kindly be
seen. He further contended vide another letter dated 26.02.2018 and has requested the
followings;
a. to withdraw one charge sheet dated 03.08.2017 or earlier charge
sheet dated 05.11.2015 and
b. replacement of one of the member of constituted inquiry committee
respected Mrs. Fizza Pervez Afzaal (one of the senior officer of
PA&AS Mr. Irfan Jehangir Wattoo, BS-20) is going to appear as
witness in the instant case.

In this regard, it is stated that fresh charge sheet was issued on same charges to the
accused officer for the purpose of holding of denovo inquiry proceedings. Hence, the
previous charge sheet dated 05.11.2015 has lose its efficacy and is no more in field,
accordingly.
However, w.r.t. request contained at point (b), no request / comment / proposal has yet
been received from Mrs. Fizza Pervez Afzaal, CMA (LC) / Head Inquiry Committee,
Lahore.

Submitted for kind perusal and further orders.

 Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .03.2018

ORDER
In pursuance of Rule-5 (1) (ii) of the Government Servants (Efficiency & Discipline)
Rules, 1973, the Deputy Auditor-General (A&C) being Authorised Officer has been pleased to
appoint Mr. Hassan Latif, Director General (DAOs), O/o the Accountant General Punjab,
Lahore as new Inquiry Officer in place of Inquiry Committee comprising of two members i.e. Mrs.
Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore and Mr. Osman Jawed Loan, Addl.
AGPR, Lahore who were appointed previously vide order No.733–Dir(A)/11-321/Discip dated
03.08.2017, to conduct the denovo inquiry proceedings against Syed Taimoor Bukhari, a BS-17
/ PA&AS officer, in the Charge Sheet bearing No.732-Dir-(A)/11-321/Discip dated 03.08.2017.

2. The inquiry shall be conducted on day to day basis in accordance with the
provisions contained in the Government Servants (Efficiency & Discipline) Rules, 1973, and
instructions issued from time to time. The inquiry report should be submitted on or before
30.04.2018 after the conclusion of the denovo proceedings.

(Muhammad Siddique Tariq Joiya)

Deputy Auditor-General (A&C) /
Authorized Officer
Copy for information and necessary action to:-

1. SPS to the Auditor General of Pakistan

2. The AGPR, Islamabad.
3. The Controller General of Accounts, Islamabad
4. Mr. Hassan Latif, Director General (DAOs) / Inquiry Officer, O/o the Accountant
General Punjab, Lahore with directions to complete inquiry proceedings at the
earliest in accordance with the provision of the Government Servants (Efficiency &
Discipline) Rules, 1973. A copy of afore mentioned charge sheet / statement of
allegations are enclosed.
5. Mrs. Fizza Pervez Afzaal, Controller Military Accounts (LC), Lahore and Mr. Osman
Jawed Loan, Addl. AGPR, Lahore being Inquiry Committee members are requested
to forward the original case files and any other material carried out during the
instant inquiry proceedings to new Inquiry Officer under intimation to this office.
6. Director (Admn-I), Local
7. Syed Taimoor Bukhari, BS-17 PA&AS Officer, House No. 21-A, Block “G”, Johar
Town, Lahore with directions to participate in the initiated denovo disciplinary
proceedings immediately. It is further clarified w.r.t. letter 26.02.2018 that fresh
charge sheet dated 03.08.2017 was issued on same charges for the purpose of
holding of denovo inquiry proceedings. Hence, the previous charge sheet dated
05.11.2015 has lose its efficacy and is no more in field.
8. Audit Officer (PA&AS-II)
9. Audit Officer (Confidential-II)
 Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

No. –Dir(A)/11-321/Discip/2015 Dated: .03.2018

CHARGE SHEET

WHEREAS, I, Muhammad Siddique Tariq Joiya, Deputy Auditor

General (A&C) / Authorized Officer have decided to proceed against you, Syed
Taimoor Bukhari, Ex-Assistant Accountant General (BPS-17/PA&AS), under Rule 5
(1) (ii) read with Rule 6-A (2) of the Government Servants (Efficiency & Discipline)
Rules, 1973 and in pursuance of the orders of the Prime Minister / Appellate Authority
vide letter No. 1841/SPM/17 dated 21.06.2017 on your appeal / representation
against the imposition of major penalty of “Dismissal from Service” and in
continuation of Charge Sheet of even number dated 03.08.2017 containing the same
charges and in continuance of issuance of order of even number dated 19.03.2018 to
avoid any anomaly.

2. WHEREAS, I consider that in the light of facts of the case and in the
interest of justice, it is necessary to hold denovo inquiry against you through an
Inquiry Committee.

3. WHEREAS, you, Syed Taimoor Bukhari, Ex-Assistant Accountant

General (BPS-17/PA&AS), office of the Accountant General Punjab Lahore, failed to
discharge your duties efficiently and committed the following acts of
omission/commission which are tantamount to “Inefficiency”, “Misconduct” and
“Corruption” within the meaning of Rule 3 (a) (b) & (c) of the Government Servant
(E&D) Rules, 1973.

(i) You with the connivance of Mr. Zahhid Rasheed the then Director
General DAO’s (OPS) got yourself posted back as Assistant
Accountant General, whereas you already had been surrendered on
account of misconduct from the office of Accountant General Punjab.
(ii) You obtained the possession of token punching machine in complete
disregard to standard operating procedures, during the month of June,
2014.
(iii) You compelled your staff in Payroll-7 Section to process the
counterfeited bills without exercising proper pre-audit checks which
confirm your willful involvement in processing the counterfeited bills in
 connivance with the then Director General/Accountant General (on
look after basis).
(iv) You were found to be in possession of fake stamps of the vendors, in
whose name the fake bills were got prepared and processed. This
further corroborates your active involvement in the fraud.
(v) You collaborated with the team of private persons and officials of
Accountant General Punjab malafide deployed by Mr. Zahhid
Rasheed in order to create a rush and an environment of fear in the
office so as to get the things done according to your whims.

4. AND WHEREAS, by reasons of above read with the details given in

the enclosed Statement of Allegations, you are liable to disciplinary action under the
Government Servants (E&D) Rules, 1973, which may include imposition of one or
more penalties including the major penalty of “Dismissal from Service” as
prescribed in Rule 4 of the ibid Rules.

5. WHEREAS, in pursuance of sub-rule (ii) of Rule 5 of the Government

Servants (E&D) Rules, 1973 Mr. Hassan Latif, Director General (DAOs), O/o the
Accountant General Punjab, Lahore has been appointed by the undersigned as
Inquiry Officers, who will conduct the proceedings in this case against you.

6. NOW THEREFORE, you are hereby required to submit your written

defence to the above charge sheet, within fourteen (14) days on its receipt to the
above named Inquiry Committee, failing which it shall be presumed that you have
nothing to say and action against you will be initiated ex-parte.

7. Statement of Allegations explaining the charges is enclosed.

(Muhammad Siddique Tariq Joiya)

Deputy Auditor-General (A&C) /
Authorized Officer
Copy for information and necessary action to:

 Mr. Hassan Latif, Director General (DAOs), O/o the Accountant General
Punjab, Lahore along with a copy of the Statement of Allegations. Inquiry
should be completed as early as possible in accordance with the provisions of
Government Servants (Efficiency & Discipline) Rules, 1973.
 Syed Taimoor Bukhari, BS-17 PA&AS Officer, 135-JII, Johar Town, Lahore.
Cell No. 0300-9453254.
 Office of the
AUDITOR GENERAL OF PAKISTAN
Constitution Avenue, Islamabad

STATEMENT OF ALLEGATIONS

Syed Taimoor Bukhari, BS-17 PA&AS Officer, Ex-Assistant Accountant

General, in the office of Accountant General Punjab, Lahore, committed the
following acts of omission/commission:-

i. That you in connivance with Mr. Zahid Rasheed, Director

General DAOs (OPS) also holding the charge of Accountant
General (on look after basis) illegally, maneuvered to get
yourself posted as Assistant Accountant General (AAG) in the
office of the Accountant General Punjab in June, 2014 despite
the fact that you were surrendered as AAG, by the then
Accountant General Punjab on account of misconduct in
December 2013 (Annexure-A & B).

ii. That you obtained the possession of Token Punching Machine

in complete disregard of standard operating procedures during
the month of June, 2014. During the period that the Token
Punching Machine remained in your custody, you used it for
punching tokens on counterfeited/bogus bills (Annexure- C, D,
E, F, G & H).

iii. You being the officer in-charge compelled Mr. Jawad-ul-Qamer,

Key Punch Operator, Mr. Muhammad Shahbaz Qamer, Senior
Auditor and Assistant Accounts Officer viz Mr. Muhammad
Arshad Iqbal of Payroll-7 Section to process the counterfeited
bills of “Sustainable Development of Walled City Lahore
Project” and cleared those bills without applying proper pre-
audit checks. You then forwarded those bills from the computer
terminal in the section hurriedly, without applying the
prescribed pre-audit checks. After clearing the bills in a swift
manner and without applying proper pre-audit checks, you
recorded the following statement on the passed bills statement
“Necessary approval has been taken by the Director
General/Accountant General”. These actions on your part
confirm your willful involvement in processing the counterfeited
bills in connivance with the then Director General/Accountant
General Mr. Zahid Rasheed (Annexure- I, J, K, L, M, N & O).

iv. As per statement of Mr. Jawad-ul-Qamer, Senior Auditor/Key

Punch Operator and Syed Shiraz Hussein, Naib Qasid, you
were in possession of the fake stamps, used on the bogus bills
of the fake vendor, of the Sustainable Development of the
 Walled City Project Lahore. The name of the fake vendor was
M/s Qavi Engineering (Annexure- I, O & P).

v. You operated through private armed persons and placed

officials violating all the prescribed standard operating
procedures, created a rush and an environment of fear in order
to clear bills in lieu of handsome bribes. You and the private
armed guards acted in connivance with the then ex-Accountant
General Punjab Mr. Zahhid Rasheed. (Annexure-Q).

2. By reasons of the above, Syed Taimoor Bukhari, Ex-Assistant

Accountant General, office of Accountant General Punjab, has rendered himself
liable for disciplinary action under the Government Servants (Efficiency &
Discipline) Rules, 1973 which may include imposition of one or more penalties
including major penalty of “ Dismissal from Service”.

(Muhammad Siddique Tariq Joiya)

Deputy Auditor-General (A&C) /
Authorized Officer

Copy for information and necessary action to:

 Mr. Hassan Latif, Director General (DAOs), O/o the Accountant General
Punjab, Lahore along with a copy of the Statement of Allegations. Inquiry
should be completed as early as possible in accordance with the provisions of
Government Servants (Efficiency & Discipline) Rules, 1973.
 Syed Taimoor Bukhari, BS-17 PA&AS Officer, 135-JII, Johar Town, Lahore.
Cell No. 0300-9453254.
 44/N
SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF
SYED TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER
(WRITTEN DEFENCE REPLY TO CHARGE SHEET SUBMITTED
BY THE ACCUSED OFFICER)
197. PUC is a letter dated 04.04.2018 received from Syed Taimoor
Bukhari, BS-17/PA&AS Officer (accused officer), which may kindly
be seen.
198. Through PUC accused officer has submitted his reply to the
charges leveled against him to the new Inquiry Officer (Mr. Hassan
Latif, Director General DAOs, Lahore), which are self explanatory,
which may kindly be perused.
199. The inquiry report from nominated Inquiry Officer in the wake reply
submitted by accused officer is still awaited.
200. At present, PUC requires no action at our end. If agreed to, the
same may please be filed.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
09.04.2018
AO (Legal-I)
 45/N
SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF
SYED TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER
(FORWARDING OF INQUIRY MATERIAL TO NEW INQUIRY
OFFICER BY THE THEN INQUIRY COMMITTEE)
201. PUC is a letter dated 09.04.2018 received from Ms. Fizza Parvez
Afzaal, CMA (LC), Lahore the then Inquiry Officer in disciplinary
case of Syed Taimoor Bukhari, BS-17/PA&AS Officer (accused
officer), which may kindly be seen.
202. Through PUC, the then inquiry committee has forwarded the
original case files and related material of subject inquiry to new
Inquiry Officer (Mr. Hassan Latif, Director General DAOs, Lahore),
in response to this office order dated 21.03.2018 (P-103/C) which
may kindly be perused.
203. The accused officer has submitted his reply to the new Inquiry
Officer (P-157/C). However, inquiry report from new Inquiry Officer
thereto is still awaited.
204. At present, PUC requires no action at our end. If agreed to, the
same may please be filed.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
10.04.2018
AO (Legal-I)
 46/N
SUBJECT: DISCIPLINARY CASE (DENOVO INQUIRY) IN RESPECT OF
SYED TAIMOOR BUKHARI, BS-17 / PA&AS OFFICER

(NON-SUBMISSION OF INQUIRY REPORT BY THE NEW

INQUIRY OFFICER DUE ON 30.04.2018)
205. Reference is invited to this office order of inquiry dated 21.03.2018
(P-103/C) whereby Mr. Hassan Latif, Director General DAOs,
Lahore has been appointed as new Inquiry Officer to conducted
denovo inquiry proceedings against Syed Taimoor Bukhari, BS-
17/PA&AS Officer (accused officer) with directions to furnish
inquiry report on or before 30.04.2018, which may kindly be seen.
206. The Prime Minister vide letter 21.06.2017 (Page-51/C) ordered to
hold denovo disciplinary proceedings in the wake of appeal filed by
Syed Taimoor Bukhari, BS-17/PA&AS Officer against imposition of
major penalty of dismissal from service.
207. Ms. Fizza Parvez Afzaal, CMA (LC), Lahore the then Inquiry
Officer in disciplinary case of Syed Taimoor Bukhari, BS-
17/PA&AS Officer (accused officer), vide her letter dated
09.04.2018 (Page-158-159/C) has forwarded the original case files
and related material of subject inquiry to new Inquiry Officer (Mr.
Hassan Latif, Director General DAOs, Lahore), in response to this
office order dated 21.03.2018 (P-103/C) which may kindly be
perused.
208. It is further submitted that accused officer has already submitted
his reply to the new Inquiry Officer vide letter dated 04.04.2018
(P-146-157/C).
209. However, inquiry report from new Inquiry Officer despite clear
directions of worthy DAG (A&C) / Authorised Officer is still awaited.
210. Submitted for kind perusal and further orders of the worthy DAG
(A&C) being Authorised Officer, please.

(MUHAMMAD BILAL SHARIF)

AAO Discip. (Legal-I)
02.05.2018
AO (Legal-I)