Office of: -

Muhammad Ashraf Nadeem,

Advocate High Court,
28-District Courts, Multan.

To
The S.D.O. Sub-Division,
MEPCO Ltd. Bahawalpur.

LEGAL NOTICE.

The undersigned has been instructed by my client,

Ch. Muhammad Ashique, carrying out his business under the name
& style of Cholistan Cotton Ginning Factory, Noorpur Nowranga,
Bahawalpur, to serve this notice upon you on the following: -
GROUNDS
1. That you disconnected electric supply of his cotton factory on
28.12.98 without serving any prior notice, lodged F.I.R. No.
492/98 dated 28.12.98 in Police Station Musafir Khana
Bahawalpur on false allegation of theft of energy and removed
the metering equipment illegally at the same time.
2. That you served a detection bill of Rs. 956,746/- upon my
client and forced him to deposit the same and refused to
restore the supply till the recovery of detection bill. My client
was compelled to deposit the detection bill on 30.12.98, to
avoid huge financial loss due to damage of seed-cotton, which
could not be left un-ginned for indefinite period. However, the
detection bill was reduced to Rs. 8.52,000/- at your own.
3. That during investigation by the Police, the allegation could
not be proved by you and finally the case was dismissed ab-
initio by the competent authority.
4. That my client requested you to arrange for repayment of
Rs. 852,000/- (recovered as detection bill from him) but you
refused with the remarks that Police Investigation Officer was
not a technical person, so his report could not be accepted.
5. That my client filed petition before the Electric Inspector,
Govt. of the Punjab, Lahore and then the Advisory Board,
Govt. of the Punjab Lahore for technical advice/decision,
which was decided in his favour and detection bill of Rs.
 852,000/- was declared as illegal, unlawful and not payable by
the petitioner.
6. That my client contacted you on 2.9.2001 and requested to
refund/repay the amount of Rs. 852,000/- (recovered as illegal
detection bill) but your directed him to contact X.E.N./S.E.
MEPCO Ltd. Bahawalpur. My client contacted both the
officers but they turned deaf ear to him. Then he submitted
written applications to X.E.N. and S.E. MEPCO Ltcd.
Bahawalpur on 13.10.2001 and 17.10.2001 respectively but
could get no response.
7. That my client contacted you again on 5.11.2001 and asked
you to arrange for refund/repayment of the amount as you
were the MEPCO officer who lodged F.I.R., disconnected
supply and recovered the detection bill through coercive
measures. You told that you had filed appeal against the
orders/decision of the Advisory Board, Lahore and stay order
would be provided within a couple of weeks.
8. That a period of more than 60 days have been elapsed but you
have neither provided copy of stay order nor you have made
the requisite payment to my client uptil now.
In view of above circumstances, you are hereby
advised to supply copy of stay order if issued by
competent court or otherwise arrange for repayment of
Rs. 852,000/- with interest at the bank rate from
30.12.1998 to the date of repayment of amount, within
15 days of the receipt of this notice otherwise my client
will be constrained to initiate legal proceedings against
you.

A copy of this notice has been retained in my office.

This notice consists upon two pages and there is no correction
or cutting. You are advised to keep this notice with you so that it
could be produced in the court of competent jurisdiction.
Muhammad Ashraf Nadeem,
Advocate High Court,
28-District Courts, Multan.