Professional Documents
Culture Documents
MULTAN.
W.P. No._____________/2001
Allah Nawaz Khan S/o Haq Nawaz Khan, R/o H. No. 2088, Gali
No. 5, Behind the Old Bakkramandi, Bagh Road, Multan city.
Petitioners
VERSUS
1. Pakistan Railways, through General Manager, Railway Head
Quarters, Lahore.
2. Divisional Superintendent, Pakistan Railways, Multan.
3. Divisional Engineer, Property and Land, Pakistan Railways, D.S.
Office, Multan.
4. Assistant Engineer, Pakistan Railways, Multan.
5. Inspector of Works, Pakistan Railways, Multan.
Respondents
Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.
Humble Petitioner,
Dated: ___________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
CERTIFICATE: -
Certified as per instructions of the client,
that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.
Advocate
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
Respectfully Sheweth: -
1. That the petitioner has filed the titled writ petition in this Hon’ble
Court, with all the sanguine hope of its success.
2. That the averments of the main petition may be read as part and
parcel of the application.
3. That the petitioner has a prima facie case and balance of
convenience also tilts in his favours.
4. That the relief sought for, if not granted, the petitioner would
suffer an irreparable loss.
In view of the above humble submissions, it is
respectfully prayed that the respondents may please be
directed not to restrain the petitioner/applicant from
harvesting the ripen crops standing on 10 acres of land,
on plot No. 8, till the final disposal of the titled writ
petition. Meanwhile, it is also prayed that a
Commission may please be appointed to observe the
position of the standing crop to save it from being
perished.
Humble Applicant,
Dated: __________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
AFFIDAVIT of: -
Allah Nawaz Khan S/o Haq Nawaz Khan, R/o H. No.
2088, Gali No. 5, Behind the Old Bakkramandi, Bagh
Road, Multan city.
DEPONENT
Verification: -
Verified on oath at Multan, this _____ day
of May 2001 that the contents of this affidavit are
true & correct to the best of my knowledge and
belief.
DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
Respectfully Sheweth:-
That certified copies of Annexures “A to N” are not
available. However, uncertified/photo state copies of the
same have been annexed with the petition, which are true
copies of original documents.
Dated: __________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
DISPENSATION APPLICATION.
AFFIDAVIT of: -
Allah Nawaz Khan S/o Haq Nawaz Khan, R/o H. No.
2088, Gali No. 5, Behind the Old Bakkramandi, Bagh
Road, Multan city.
DEPONENT
Verification: -
Verified on oath at Multan, this _____ day
of May 2001 that the contents of this affidavit are
true & correct to the best of my knowledge and
belief.
DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
INDEX
S. No. NAME OF DOCUMENTS ANNEXES PAGES
1 Urgent Form
2 Stamp Paper worth Rs. 500/-
3 Writ Petition.
4 Affidavit
5 Copy of Press Clipping. A
6 Copy of Receipt. B
7 Copy of Approval & Letter. C&D
8 Copy of Direction & Receipt. E&F
9 Application U/o 26, R-9 C.P.C.
10 Affidavit.
11 Dispensation Application.
12 Affidavit.
13 Vakalatnama
PETITIONER
Dated: ____________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
W.P. No._____________/2001
Allah Nawaz Khan S/o Haq Nawaz Khan, R/o H. No. 2088, Gali
No. 5, Behind the Old Bakkramandi, Bagh Road, Multan city.
Petitioners
VERSUS
1. Pakistan Railways, through General Manager, Railway Head
Quarters, Lahore.
2. Divisional Superintendent, Pakistan Railways, Multan.
3. Divisional Engineer, Property and Land, Pakistan Railways, D.S.
Office, Multan.
4. Assistant Engineer, Pakistan Railways, Multan.
5. Inspector of Works, Pakistan Railways, Multan.
Respondents
Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly
been given for the purpose of their summons and citations.
10. That the petitioner has been left with no alternate, efficacious,
adequate and speedy remedy available except to invoke the
extra-ordinary constitutional jurisdiction of this Hon’ble Court
for his grievance.
Humble Petitioner,
Dated: ___________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
CERTIFICATE: -
Certified as per instructions of the client,
that this is the first petition on the subject
matter. No such petition has earlier been
filed before this Hon’ble Court.
Advocate
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
INDEX
S. No. NAME OF DOCUMENTS ANNEXES PAGES
1 Urgent Form
2 Stamp Paper worth Rs. 500/-
3 Writ Petition.
4 Affidavit
5 Copy of the advertisement. A
6 Copy of auction proceeding & sketch. B&C
7 Copy of receipt. D
8 Copies of applications & letter. E, F, G & H
9 Copies of affidavit, approval, J, K, L & M
depositing letter and receipt.
10 Copy of letter. N
11 Application U/o 26, R-9 C.P.C.
12 Affidavit.
13 Dispensation Application.
14 Affidavit.
15 Vakalatnama
PETITIONER
Dated: ____________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
Respectfully Sheweth: -
1. That the applicant is the only petitioner in the above titled Civil
Revision.
2. That the titled Revision Petition was filed by the applicant and
the same was fixed for hearing on 25.1.2000 in first instance. The
case was adjourned to 15.2.2000 for the engagement of the
counsel and with the enlistment of the other similar civil revision
Petition No. 745-D/1999 between the same parties.
3. That the case was fixed on 15.2.2000. The father of the applicant
was present. No power of attorney was placed by any counsel,
but it was stated by the applicant’s father that he has engaged a
counsel from Khanewal, who could not appear due to his
indisposition and the case was adjourned to 13.3.2000.
4. That, however, before the fixed date i.e. 13.3.2000, a C.M. No.
324-C/2000 was moved by Dur Muhammad (Zar Muhammad as
stated in the order), on which an order dated 10.3.2000 was
passed, by which the following cases: -
(i) C.R. No. 746-D/1999
(ii) C.R. No. 747-D/1999
(iii) C.R. No. 748-D/1999
(iv) C.R. No. 749-D/1999
were consolidated with C.R. No. 744-D/99 and C.R. No. 745-
D/99 for regular hearing before the same judge for 4.4.2000.
On 4.4.2000, the revision petitioner Sikandar Hayat, in
Revision Petition No. 744-D/1999, 745-D/1999 and petitioner
Waqar Hussnain in C.R. No. 746-D/1999 to C.R. No. 749-
D/1999 were present. Abid Hussain Advocate for the
respondents in all the revision petitions, was also present. In
this order, it was also directed that W.P. No. 2236/90 shall also
be fixed along-with all these 6 cases on 18.5.2000. However,
this case was fixed for hearing on 4.7.2000, instead of
15.5.2000. No one was present and the case was dismissed for
non-prosecution. Copy of proceeding is Annex “A”.
5. That the applicant seeks restoration of the above titled case and
the order dated 4.7.2000 is impugned inter alia on the following
mentioned: -
GROUNDS
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
Respectfully Sheweth: -
1. That the applicant is the only petitioner in the above titled Civil
Revision.
2. That the titled Revision Petition was filed by the applicant and
the same was fixed for hearing on 25.1.2000 in first instance. The
case was adjourned to 15.2.2000 and was to be listed with the
other similar civil revision Petition No. 744-D/1999 between the
same parties.
3. That the case was fixed on 15.2.2000 along-with C.R. No. 744-
D/1999 and was adjourned for 13.3.2000. This case was fixed on
4.4.2000 instead of 13.3.2000 and the next date for hearing was
18.5.2000. Again the case was fixed on 4.7.2000 instead of
18.5.2000 and on 4.7.2000, the case was dismissed for non-
prosecution. Copy of proceeding is Annex “A”.
GROUNDS
i) That the order is against the natural justice and law of
equity.
ii) That the case was not fixed as per directions of the
learned judge.
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
Respectfully Sheweth: -
1. That the applicant is the only petitioner in the above titled Civil
Revision.
2. That the titled Revision Petition was filed by the applicant and
the same was fixed for hearing on 10.2.2000 in first instance. The
case was adjourned to 22.2.2000 after issuing of pre-admission
notice. On 22.2.2000, none was present from the other side and
the case was adjourned for 29.2.2000.
ii) That the case was not fixed as per directions of the
learned judge.
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
C.M. No. ________/2001
In
C.R. No. 747-D/1999
AFFIDAVIT of: -
Rizwan Ahmad Naseem S/o Gul Muhammad, caste
Sheikh Magoo, R/o Chak No. 8/9-R, Tehsil Mian
Channu, District Khanewal (through Special Power of
Attorney).
DEPONENT
Verification: -
Verified on oath at Multan, this _____ day
of May 2001 that the contents of this affidavit are
true & correct to the best of my knowledge and
belief.
DEPONENT
Respectfully Sheweth: -
1. That the applicant was appearing in the above-titled case through
Special Power of Attorney.
2. That the applicant remained present in this Hon’ble Court when
the case was listed as fixed by the court. At last instance, the case
was not fixed as per given date and no intimation/notice was
given to the applicant for the appearance in the above titled case.
3. That there was no fault of the applicant in respect of absence and
neither the absence was willful.
4. That as soon as the matter of the dismissal of the case was known
to the applicant, the application is filed within the stipulated
period.
It is, therefore, respectfully prayed that if any
delay is caused in filing the application of restoration, it
may kindly be condoned.
Any other relief, which this Hon’ble Court deems
fit, may please be extended towards the applicant to
meet the ends of justice.
Humble Applicant,
Dated: __________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176