Professional Documents
Culture Documents
MULTAN.
INDEX
S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES
1 Urgent Form
2 Stamp Papers
3 Memo of Appeal.
4 Copy of judgment. A
5 Copy of writ petition. B
6 Copy of Directory-90. C
7 Cop of letter. D
8 Dispensation Application
9 Affidavit
10 Stay application.
11 Affidavit.
12 Power of Attorney
APPELLANTS
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.
Claim in Appeal: -
To set aside the impugned judgment
and to accept the writ petition.
Court Fee: -
Respectfully Sheweth: -
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.
2. That the ARCHITECTS AND TOWN PLANNERS were
working haphazardly and to regulate the architectural and town
planning work, a law namely Pakistan Council of Architects &
Town Planner Ordinance 1983 was promulgated. This ordinance
categorized the qualified and non-qualified architects and town
planners; and a safeguard to the rights of both was provided
through this ordinance. The Pakistan Council of Architects and
Town Planners is a statutory body constituted under this
ordinance.
5. That the appellants, without going deep into the controversy with
respondents, submitted applications to the respondent No. 1 for
enlistment as required under section 8 (a), 16 (1) (b) and 16 (2) as
well. These applications were for the issuance of application form
for registration and appellants desired to pay the prescribed fee.
These applications were duly received by the respondent No. 1,
but in response, the respondent No. 1 refused to issue application
form with reference to some notification. The respondent No. 1,
even not bothered to send a copy of notification referred in the
letters. It is pertinent to point out that no such notification is in
existence upto the knowledge of the appellants.
GROUNDS
ii) That the impugned judgment is against the law and facts
of the case.
vi) That the conduct, acts and steps taken by the respondents
are illegal, unlawful and unwarranted under the law,
because the respondent No. 1 had already issued a letter
stating thereby that the P.C.A.T.P. Ordinance, 1983 does
not debar the petitioners to continue the work as
“DRAFTSMEN”. Copy of letter is Annex “D”.
viii) That the acts and conduct of the respondents and the
impugned judgment as well are in the collusion with
articles 4, 18 & 25 of the constitution of Islamic
Republic of Pakistan.
ix) That the Hon’ble Single Judge decided the case in haste
and without taking the notice of prayer clause of
constitutional petition.
x) That the appellants are earning bread & butter for their
families and now going to be penniless due to the
conduct and behaviour of respondents. This situation is
seriously attacking to the fundamental rights of the
appellants, which warranted legal action in this regard.
Dated: ________
Through: -
Hamad 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: -
Advocate
Respectfully Sheweth: -
That certified copies of Annexes “C & D” 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: -
Hamad 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
AFFIDAVIT of: -
Kashif Ghafoor Qadri S/o Abdul Ghafoor Qadri, caste
Rajput, R/o Street No. 10, Main Bazar, Shah Faisal
Colony, Ghaus Pura, Multan.
DEPONENT
Verification: -
Verified on oath at Multan, this ____day of
November 2002 that the contents of this affidavit
are true & correct to the best of my knowledge
and belief.
DEPONENT
Sheweth as under: -
1. That the contents of main I.C.A. may be treated as the integral
part and parcel of this application.
3. That the applicants have also been working in the same field
since last 5/6 years successfully and there is no complaint at
all in this respect.
6. That the applicants are earning bread and butter for their
families from this job and since last two months, the
applicants have become penniless due to the act and conduct
of respondents.
Dated: __________
Through: -
Hamad 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
AFFIDAVIT of: -
Kashif Ghafoor Qadri S/o Abdul Ghafoor Qadri, caste
Rajput, R/o Street No. 10, Main Bazar, Shah Faisal
Colony, Ghaus Pura, Multan.
DEPONENT
Verification: -
Verified on oath at Multan, this 18th day of
November, 2002 that the contents of this affidavit
are true & correct to the best of my knowledge
and belief.
DEPONENT
Sr. Name Father’s name Caste Educational Technical Course Session Board Experience
No. qualification qualification duration
1 Kashif Ghafoor Abdul Ghafoor Qadri Rajput Matric Civil 2 years 8-1995 Punjab Boar of 7 years
Qadri Draftsman Technical Education,
Lahore
2 Javed Iqbal Haroon Ali Matric Civil 2 years 2-1991 Punjab Boar of 11 years
Draftsman Technical Education,
Lahore
3 Muhammad Akhtar Muhammad Hussain Lodhi Matric Civil 2 years 7-1991 Directorate of 11 years
Hussain Lodhi Lodhi Draftsman Manpower & Training
Trade Testing Board,
Punjab
4 Naseer Ahmad Saeed Ahmad Qureshi Qureshi Matric Civil 2 years 0-1989 Punjab Boar of 13 years
Qureshi Draftsman Technical Education,
Lahore
5 Abduz Zahid Abdul Khalid Sheikh Matric Civil 2 years 10-1996 Directorate of 6 years
Draftsman Manpower & Training
Trade Testing Board,
Punjab
6 Muhammad Zahid Muhammad Akbar Rana Matric Civil 2 years 8-1995 Punjab Boar of 7 years
Akbar Rana Draftsman Technical Education,
Lahore
7 Muhammad Tahir Khushi Muhammad F.A. Civil 2 years 3-1999 Directorate of 3 years
Draftsman Manpower & Training
Trade Testing Board,
Punjab
8 Muhammad Mujib Muhammad Siddique Matric Civil 1 year 4-1994 Directorate of 8 years
Draftsman Manpower & Training
Trade Testing Board,
Punjab
9 Malik Muhammad Malik Ghulam Rasool Jat Matric Civil 2 years 0-1971 Technical Training 32 years
Bakhsh Draftsman Centre,
Karachi,/Karachi Poly
Technical Institute,
Karachi.
10 Muhammad Asif Muhammad Ashraf Awan Matric Civil 3 years 12-1996 Punjab Boar of 6 years
Awan Awan Engineering Technical Education,
Lahore
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.
5. That the applicant, without going deep into the controversy with
respondents, submitted application to the respondent
No. 1 for enlistment as required under section 8 (a), 16 (1) (b)
and 16 (2) as well. These applications were for the issuance of
application form for registration and appellants desired to pay the
prescribed fee. This application was duly received by the
respondent No. 1, but in response, the respondent No. 1 refused
to issue application form with reference to some notification. The
respondent No. 1, even not bothered to send a copy of
notification referred in the letters.
GROUNDS
vii) That the acts and conduct of the respondents and the
impugned judgment as well are in the collusion with
articles 4, 18 & 25 of the constitution of Islamic
Republic of Pakistan.
Humble Appellant,
Dated: ________
Through: -
Hamad 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: -
Advocate
INDEX
S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES
1 Urgent Form
2 Stamp Paper
3 Review application
4 Affidavit
5 Copy of judgment. A
6 Copy of writ petition. B
7 Copy of Directory-90. C
8 Copy of letter. D
9 Copies of certificate and license. E,F,G
10 Copy of certificate H
11 Dispensation Application
12 Affidavit
13 Stay application.
14 Affidavit.
15 Power of Attorney
APPLICANT,
Dated: __________
Through: -
Hamad 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. _________/2002
In
R.A. No. _________/2002
In
W.P. No. _________/2002
Respectfully Sheweth: -
That certified copies of Annexes “C to H” 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: -
Hamad 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
REVIEW APPLICATION.
AFFIDAVIT of: -
M. Akhtar Hussain Lodhi S/o Muhammad Hussain
Lodhi, caste Lodhi, R/o Piran Sahib Colony No. 2,
M.D.A. Road, near Pul Bararan, Multan.
DEPONENT
Verification: -
Verified on oath at Multan, this _____day of
November 2002 that the contents of this affidavit are
true & correct to the best of my knowledge and belief.
DEPONENT
Sheweth as under: -
3. That the applicant has also been working in the same field since
last 5/6 years successfully and there is no complaint at all in
this respect.
5. That the applicant tried to get himself enlisted under the law,
but respondents No. 1 & 2 have refused to issue the application
forms after receiving the prescribed fee.
6. That the applicant is earning bread and butter for his family
from this job and since last two months, the applicant has
become penniless due to the act and conduct of respondents.
Dated: __________
Through: -
Sheweth as under: -
4. That the instant I.C.A. was ready for filing on 18.11.02, but
unfortunately, the counsel for appellants was not feeling well, so
it was filed on 20.11.02.
5. That if the appeal is hit by any type of limitation, that was not
intentional delay or fault of the applicants.
Dated: __________
Through: -
Hamad 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