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IN THE LAHORE HIGH COURT

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IN THE COURT OF MUHAMMAD IMRAN KHAN,
LEARNED CIVIL JUDGE, LAHORE
Civil Suit No ................................. /16
MUHAMMAD TAHIR BHATTI Ex-Deputy Manager
(Procurement) P.No.807028 S.M.C Pakistan Steel Mills,
Lahore.
PLAINTIFF
VERSUS
1. Pakistan Steel Mills Through Chief Executive Officer (CEO) Pakistan
Steel Bin Qasim Karachi.
2. Principal Executive Officer (PEO) A&P Pakistan Steel Mills Bin
qasim, Karachi.
3. SMC through Incharge Zonal Office, Pakistan Steel, Zafar Ali Road
Gulberg-V , Lahore.
DEFENDANTS
AMENDED PLAINT
SUIT FOR DECLARATION AND RECOVERY OF ARREARS
/ DUES
OF RS.80,00,000 /- (EIGHT MILLION
APPROXIMATELY) WITH ALL BENEFITS SINCE 1996 WITH
DAMAGES
RS.70,00,000 /- (RUPEES SEVEN MILLION
APPROXIMATELY). TOTAL AMOUNT RS.150,00,000 /(FIFTEEN MILLION APPROXIMATELY).
RESPECTFULLY SUBMITTED:1. That
the
plaintiff
being
post
graduate
in
M.Sc
Chemistry from Punjab University, Lahore applied for
the post of Assistant Manager (Tech) in Pakistan Steel
and on 05-07-1981 joined as Assistant Manager (Tech)
and since then the plaintiff performed his duties with full
devotion zeal, zest and upto the entire satisfaction of his
superiors and the plaintiff has 33.5 years unblemished
service record at his credit.
2. That the plaintiff was promoted as Deputy Manager in the
year 1989 and the plaintiff deprived of his right of
promotion on one pretext to the other owing to some
baseless reasons.
It is submitted with respect that i n the meeting of
departmental promotion committee held (DPC) in the
years from 1996 to 2010, the plaintiff consecutively
suspended / deferred without any lawful justification ,
rather the blue eyed persons of the departmental
authorities have been accommodated at the cost of the
plaintiff.
3. That on the agitation of the plaintiff it was verbally
informed
to
the
plaintiff
by
the
departmental
administration that the plaintiff’s case for promotion in
next
grade
has
been
deferred
due
to
disciplinary
proceedings.
4. That the plaintiff through a letter dated 26 -09-2008 and
20-01-2009
requested
the
Defendant
No.2
for
the
redressal of his grievance regarding the promotion but no
heed was paid to the genuine request of the plaintiff and
the defendants displayed the act of apathy, stoicism and
impassivity towards the redressal of genuine grievance of
the plaintiff.
5. That on the one fold, inaction of the defendants in
respect
of
plaintiff
genuine
grievance
amounts
to
exploitation, violation of specific provision s of the
Constitution and is clear discrimination, as the plaintiff’s
junior colleagues were promoted on the basis of pick and
choose since 1996.
6. That being the aggrieved by the acts of defendants the
plaintiff filed a writ petition No.11971 -10 in Lahore High
Court in which direction was issued to the defendants for
the redressal of the plaintiff’s grievance. Later on the
plaintiff filed a 2 nd writ petition No.22259-15 and once
again direction was issued to the defendants but the
defendants once again paid no heed and the plaintiff filed
3 rd writ petition No.12402-16 before Honourable Lahore
High Court, Lahore in which the plaintiff asked to seek the
alternate
efficacious
remedy
before
competent
jurisdiction.
7. That the plaintiff is suffering since 1996 at the hands of
the defendants the defendants stopped the promotion of
the plaintiff without any justification just to fulfil their
personal vendetta.
8. That the plaintiff requested the defendants to provide
DPC minutes of meeting pertaining to year 1996 vide
letter dated
24-08-2016 but they did not provide the
same.
9. That the cause of action firstly arose in favour of the
plaintiff and against the defendants in 1996 when the DPC
held, secondly in 2010, thirdly in 2015, fourthly in 2016
which is still continuing.
10.
That the plaintiff is residing at Lahore and the cause
of action also arose Lahore, therefore this Honourable
Court is competent to entertain and adjudicate upon the
matter.
11.
That the required court fee will be affixed as per
order of the Honourable Court.
PRAYER:It is most humbly prayed that the suit in hand may kindly
be decreed in favour of the plaintiff against the defendants by
declaring that the plaintiff should be considered to be retired from
the post of the manager.
It is further prayed that the plaintiff may also be awarded
arrears / dues of RS.80,00,000 /-. (Eight Million Approximately).
It is further prayed that the plaintiff may also be given the
damages of RS.70,00,000 /- . (Seven Million Approximately) since
1996.
Any other relief which this Honourable Court deems fit and
proper may also be awarded to the plaintiff.
Arrears / Dues equal to
Rs. 80,00,000 /-
Damages
Rs. 70,00,000 /-
Total:
Rs. 1,50,00,000 /- (Approx)
PLAINTIFF
THROUGH:
GHULAM MURTAZA CHAUDHRY
Advocate Supreme Court Of Pakistan
ALI MURTAZA CHAUDHRY
Advocate High Court
5-Zahoor Chambers, 1 Mozang Road Lahore.
VERIFICATION:Verified on oath at Lahore on 28th day of January, 2019 that the
content of Para No.1 to 8 are correct to the best of my knowledge
and the rest of the Para No. 9 to 11 are true and correct to the best of
my belief.
PLAINTIFF
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