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Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
I, Abdul Hai s/o Abdul Majeed, Muslim, adult, r/o R/o A. No.
A-640, Block-N, North Nazimabad, Karachi holding CNIC # 42101-
1779552-3, Cell No. 0334-3153554 do hereby state on oath as
under:-
3. That for the sake of brevity I have not repeated the contents of
the accompanying memo of petition therefore, the same may
be treated as part and parcel of this affidavit.
Deponent
Karachi
Dated -07-2018
Identify by me;
Advocate
Verification
Solemnly affirmed before me at Karachi on this ___ day of July, 2018 by
the deponent above named who is identified to me by Masood Ahmed
Bhatti Advocate who is personally known to me.
C.M.A. No.___________/2018
in
C. P. No. D-___________/2018
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
Karachi
Dated: -07-2018
IN THE HIGH COURT OF SINDH AT KARACHI
C.M.A. No.___________/2018
in
C. P. No. D-___________/2018
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
AFFIDAVIT
I, Abdul Hai s/o Abdul Majeed, Muslim, adult, r/o R/o A. No. A-
640, Block-N, North Nazimabad, Karachi holding CNIC # 42101-
1779552-3, Cell No. 0334-3153554 do hereby state on oath as under:-
4. That for the sake of brevity I have not repeated the contents of the
accompanying memo of petition therefore, the same may be treated
as part and parcel of this affidavit.
Karachi Deponent
Dated: -07-2018
Identify by me
Advocate
Verification
Solemnly affirmed before me at Karachi on this ___ day of July,
2018 by the deponent above named who is identified to me by Masood
Ahmed Bhatti Advocate who is personally known to me.
C.M.A. No.___________/2018
in
C. P. No. D- ___________/2018
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
Karachi
Dated: -07-2018
IN THE HIGH COURT OF SINDH AT KARACHI
C.M.A. No.___________/2018
in
C. P. No. D-___________/2018
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
AFFIDAVIT
I, Abdul Hai s/o Abdul Majeed, Muslim, adult, r/o R/o A. No. A-
640, Block-N, North Nazimabad, Karachi holding CNIC # 42101-
1779552-3, Cell No. 0334-3153554 do hereby state on oath as under:-
3. That for the sake of brevity I have not repeated the contents of the
accompanying memo of petition therefore, the same may be treated
as part and parcel of this affidavit.
Karachi Deponent
Dated: -07-2018
Identify by me
Advocate
Verification
Solemnly affirmed before me at Karachi on this ___ day of July,
2018 by the deponent above named who is identified to me by Masood
Ahmed Bhatti Advocate who is personally known to me.
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
Karachi
C.M.A. No._______________/2018
in
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
AFFIDAVIT
I, Abdul Hai s/o Abdul Majeed, Muslim, adult, r/o R/o A. No. A-
640, Block-N, North Nazimabad, Karachi holding CNIC # 42101-
1779552-3, Cell No. 0334-3153554 do hereby state on oath as under:-
Karachi Deponent
Dated -07-2018
Identify by me
Advocate
Verification
Solemnly affirmed before me at Karachi on this ___ day of July, 2018 by
the deponent above named who is identified to me by Masood Ahmed
Bhatti Advocate who is personally known to me.
C.M.A. NO._____________/2018
in
C. P. No. D- ___________/2018
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
Respectfully Sheweth;
2. That the Petitioner brought his case before the Respondent No. 2 &
3 but who deliberately failed to discharge their Constitutional
commitments as required under Art. 190 of the Constitution. It was
not an optional for the Respondents to follow judicial orders at their
own sweat will and choice.
3. That the respondents conduct speaks that they are not willing to
decide pension issue case as it is pending with them for about more
than last 5 years.
6. That the petitioner has brought to the notice of this Hon’ble Court
an established willful and deliberate delay in settling the pension
case of the Petitioner therefore in the view of such circumstances
and the settled law, it is the statutory duty of this Hon’ble Court to
take serious view of this situation and pass appropriate orders for
establishing the rule of law in the respondent organization as its
management is bent upon violation of the secured rights of the
petitioner.
PRAYER
PETITIIONER
Karachi
Dated: -07-2018
C.M.A. NO._____________/2018
in
C. P. No. D- / 2018
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
I, Abdul Hai s/o Abdul Majeed, Muslim, adult, r/o R/o A. No. A-
640, Block-N, North Nazimabad, Karachi holding CNIC # 42101-
1779552-3, Cell No. 0334-3153554 do hereby state on oath as under:-
Karachi Deponent
Dated: -07-2018
Identify by me
Advocate
Verification
Solemnly affirmed before me at Karachi on this ___ day of July, 2018 by
the deponent above named who is identified to me by Masood Ahmed
Bhatti Advocate who is personally known to me.
C.M.A. NO._____________/2018
in
C. P. No. D- /2018
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
Respectfully Sheweth;
2. That the Petitioner brought his case vide applications dated 25-03-
2018, 18-01-2018, 19-10-2011 etc before the Respondent No.1 but
who deliberately failed to discharge his Constitutional commitments
as required under Art. 190 of the Constitution. It was not an
optional for the Respondent No.1 to follow judicial orders at his own
sweat will and choice.
3. That the respondents conduct speaks that they are not willing to
decide issues of the instant pension case as it is pending for about
more than last 5 years.
4. That the petitioner has brought to the notice of this Hon’ble Court
an established willful and deliberate failure of the Respondent
No.1State functionary to apply legal principles brought to his
knowledge which clearly and unambiguously attracted to the
instant case therefore he has liable to proceedings under Art. 204(2)
(a) of the Constitution. In the view of such circumstances and the
settled law, it is the statutory duty of this Hon’ble Court to take
serious view of this situation and pass appropriate orders for
establishing the rule of law in the respondent organization as its
management is bent upon violation of the secured rights of the
petitioner.
PRAYER
Karachi PETITIIONER
Dated: -07-2018
C.M.A. NO._____________/2018
in
C. P. No. D- / 2018
Abdul Hai………………….……...………………….………….....Petitioner
VERSUS
I, Abdul Hai s/o Abdul Majeed, Muslim, adult, r/o R/o A. No. A-
640, Block-N, North Nazimabad, Karachi holding CNIC # 42101-
1779552-3, Cell No. 0334-3153554 do hereby state on oath as under:-
3. That for the sake of brevity I have not repeated the contents of the
accompanying memo of application/petition therefore, the same
may be treated as part and parcel of this affidavit.
Karachi Deponent
Dated: -07-2018
Identify by me
Advocate
Verification