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
2.
Steel Bin Qasim Karachi.
Principal Executive Officer (PEO) A&P Pakistan Steel Mills Bin
3.
qasim, Karachi.
SMC through Incharge Zonal Office, Pakistan Steel, Zafar Ali Road
Gulberg-V , Lahore.
DEFENDANTS
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).

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.
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)

Advocate Supreme Court Of Pakistan
Advocate High Court
5-Zahoor Chambers, 1 Mozang Road Lahore.
Verified on oath at Lahore on 28 th 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.