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CM Application in Main Writ

This document is a miscellaneous application filed in the Peshawar High Court seeking to place additional documents on record in support of a pending writ petition. Specifically, the petitioner seeks to submit copies of official memorandums, letters, pay bills, and a letter of the petitioner that are relevant to determining the writ petition regarding the admissibility of certain allowances. The petitioner argues that these documents are important for the court to reach a just conclusion and their exclusion would cause irreparable harm. An affidavit of the petitioner is also submitted verifying the contents of the application. Relief is sought for the documents to be admitted as part of the main writ petition.

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2K views3 pages

CM Application in Main Writ

This document is a miscellaneous application filed in the Peshawar High Court seeking to place additional documents on record in support of a pending writ petition. Specifically, the petitioner seeks to submit copies of official memorandums, letters, pay bills, and a letter of the petitioner that are relevant to determining the writ petition regarding the admissibility of certain allowances. The petitioner argues that these documents are important for the court to reach a just conclusion and their exclusion would cause irreparable harm. An affidavit of the petitioner is also submitted verifying the contents of the application. Relief is sought for the documents to be admitted as part of the main writ petition.

Uploaded by

wahabmaths
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
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Download as DOCX, PDF, TXT or read online on Scribd
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IN THE PESHAWAR HIGH COURT, PESHAWAR

(ABBOTABAD BENCH)

CM No. __________/2015
in
Writ Petition No. 796-A/2014
Dr. Hafiz Abdul Wahab

Vs.

Hazara University, Mansehra etc.

WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF ISLAMIC


REPUBLIC OF PAKISTAN 1973, R/W ALL OTHER ENABLINJG PROVISIONS OF
LAWS OF THE LAND

MISCELLENOUS. APPLICATION UNDER SECTION 151 CPC R/W ALL


ENABLING PROVISIONS OF LAWS OF THE LAND FOR PLACEMENT
ON RECORD FOLLOWING IMPORTANT DOCUMENTS WITH TITLED
WRIT PETITION
May it please your Lordship!
1. That the titled Writ Petition is fixed for hearing before this honourable Court on
10.02.2015 in which comments/report has already been called from Respondents.
2. That the humble petition intends to place on record following important documents which
have been discovered during pendency of main Writ Petition:a. Copy of an Office Memorandum bearing number F. No. 1(5)Imp/2011(Pt)-902
dated 21.10.202013 issued by Mr. Muhammad Azam Awan, Section Officer
(Imp) of Finance Division (Regulations Wing) Government of Pakistan regarding
admissibility of allowances, which are the subject matter of this Writ Petition, to
the New Entrants. Copy is placed as (ANNEXURE-E).
b. Copy of a letter number No. FD.PC 2-2/2010 dated 02.05.2013 issued by Mr.
Tariq Muhammad Mirza, Deputy Secretary (PC) of Finance Department ,
Government of Punjab, Lahore, in connection with clarification regarding
admissibility of the subject allowances. Copy is placed as (ANNEXURE-F).
c. Copy of a letter number F. No. 4(1)-HU/Reg/2014/3075 dated 12.12.2014 issued
by Mr. Jehanzeb Khattak, Deputy Registrar (Establishment) of M/s Hazara
University Mansehra, in which clarification/guidelines have been sought from
Joint Secretary (Regulation Wing) of Finance Division, Ministry of Finance,
Islamabad regarding admissibility of subject allowances to two of the Assistant
Professors of Respondent University. Copy is placed as (ANNEXURE-G).
d. Copy of two Pay Bills pertaining to Mr. Zahid Khan and Miss Sumaira Saleem,
both Assistant Professors of Respondent University, who are junior in
experience/seniority as against the humble Petitioner, but no deduction in salary
has been made from their salaries. Copy is placed as (ANNEXURE-H).

e. Copy of the letter of humble Petitioner Dispatch No. 33 dated 27.01.2015


regarding payment of paper setting fee, having endorsement thereon of
Controller of Examination dated 27.01.2015 which is the proof of
indiscrimination and mental tension giving to the humble Petitioner for filing
subject Writ Petition.
3. That above annexures are very important to enable this honourable Court to reach at just
conclusion of this Writ Petition which otherwise are public documents and no question of
forgery or fabrication can be arises.
4. That if the above annexures are not brought on record or be read with Main Writ Petition,
the humble Petitioner would suffer irreparable loss & injury.
5. That it would be just and in fitness of things if this miscellaneous application is allowed
in the interest of justice.
In view of the above humble submission, this honourable Court is most respectfully prayed that
present CM may kindly be allowed in the interest of justice and the documents as placed
therewith may very kindly be allowed to be brought on record as integral part & parcel of main
Writ Petition. Any other relief which this honourable Court may deems fit or which have been
accrued during pendency of this Writ Petition may also be granted to the humble Petitioner.

Humble Petitioner
Through:
ABDUL RAUF
Advocate High Court
CC: POK-5989
Dated: 09.02.2015
CERTIFICATE
Certified that this FIRST miscellaneous application on the subject and contents of which
are accepted to me to best of belief & knowledge; and nothing has been concealed
therein.
Humble Petitioner

Advocate

IN THE PESHAWAR HIGH COURT, PESHAWAR


(ABBOTABAD BENCH)

CM No. __________/2015
in
Writ Petition No. 796-A/2014
Dr. Hafiz Abdul Wahab

Vs.

Hazara University, Mansehra etc.

WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF ISLAMIC


REPUBLIC OF PAKISTAN 1973, R/W ALL OTHER ENABLINJG PROVISIONS OF LAWS
OF THE LAND
MISCELLENOUS. APPLICATION UNDER SECTION 151 CPC R/W ALL ENABLING
PROVISIONS OF LAWS OF THE LAND FOR PLACEMENT ON RECORD FOLLOWING
IMPORTANT DOCUMENTS WITH TITLED WRIT PETITION

AFFIDAVIT OF DR. HAFIZ ABDUL WAHAB S/O ABDUL GHAFOOR, CASTE


KHOKHAR, R/O ASSISTANT PROFESSOR (MATHEMATICS DEPARTMENT)
HAZARA UNIVERSITY (MANSEHRA) R/O SAWABI STREET, LOWER
JINNAHABAD, ABBOTTABAD.
Respectfully Sheweth:I the above-named deponent do hereby solemnly affirm on oath that contents of the above CM are
true to best of my belief & knowledge; and nothing has been concealed therein.
DEPONENT
CERTIFICATE
Certified that the contents of above Affidavit are true to my best of belief & knowledge.
DEPONENT
Dated: 09.02.2015, Abbotabad.

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