Zafar Iqbal

IN THE LABOUR COURT NO. 9, MULTAN.
In re:
Ahmad Hassan Ghazi Vs. The Agricultural Engineer,
Multan.
Petition U/s 22-A (8) (g) of the I.R.O 1969.

Petition Under Regulation 32 (2) of the
N.I.R.C. (P &F) Regulation 1973.
This application for vacation of

Stay order dated 15.09.1996.
Respectfully Sheweth: -
1. Facts of the case are that the petitioner Mr. Ahmad Hassan Ghazi,
an employee of the Respondent as electrician, was served with a
charge Sheet for acts of misconduct. An enquiry was held into the
Charges. He was found guilty. A Show Cause Notice Under Rule
6(3) of E & D Rules, 1975 was served and after completing legal
formalities and personal hearing, vide order dated 11.2.96, was
compulsory retired.
2. That the Petitioner, then accepting the said order of his
retirement, had collected and availed all the benefits such as
commutation and gratuity Rs. 1,59,604.36.
3. That after availing of all the benefits of his retirement, he
malafidely, on 13.6.96 i.e. after more than 4 months of the order,
filed the above captioned Petition u/s 22-A (8) (g) of the I.R.O
1969 before N.I.R.C.
4. That along with the Petition, he also made an application under
Regulation 32 (2) of the N.I.R.C (P & F) 1973, praying for
suspension of operation of impugned order dated 11.2.96 of his
compulsory retirement during the pendency and till the final
decision of the main case.
5. That this application was taken up on 15.9.96 without notice to
the Respondent and same day an ex-parte order was passed by
the learned member, of course on wrong statement of facts by the
Petitioner, admitting the Petition to regular hearing, order to issue
notice to the Respondent, meanwhile the impugned order dated
11.2.96 was ordered to be held in abeyance.
6. That thereafter the Respondent was served with the notice who
filed the written reply of the Petition on 5.11.98 but due to one
reason or the other, the Petitioner under regulation 32 (2) of the
N.I.R.C (P & F) 1973 has not been taken up for decision uptill
today.
7. That vide order of the learned member N.I.R.C dated 11.8.99, the
case has been transferred to this Hon’ble Court for disposal,
hence this application for vacation of the interim stay order is
being submitted before this Hon’ble Court inter alia on the
following
GROUNDS
(i) That the interim relief in the form of ex-parte order dated
15.9.96 could not be granted without first coming to
conclusion that an unfair labour practice had been
committed. The order in fact amounts to suspending a
portion of the law empowers the employer to institute an
enquiry against the employee for his misconduct and to
pass orders in accordance with law. No power vests in the
N.I.R.C to grant any interim relief without first coming to
the conclusion that an unfair labour practice has been
committed. PLD 1976 Lah. 611, PLJ 1979 Kar. 171 and
1969 PLC 216 are the authorities on the point Petitioner,
having no prima facie case, was not entitled to any interim
relief. Balance of convenience also tilts in favour of the
Respondent and question of any irreparable loss does arise
at all in the facts and circumstances of the case.
(ii) That the interim order was passed ex-parte without notice
to the Respondent on the Petitioner’s application under
regulation 32 (2) without adopting the mandatory
procedural provision of Clause (a) & (b) which lay down
that an enquiry or hearing be held in presence of both the
parties to ascertain the factors giving rise to an unfair
Labour practice. It is thereafter the N.I.R.C could pass an
order of interim relief or otherwise without first restoring
steps laid down in the Clause (a) to (c), the order thus
passed is illegal & not maintainable.
(iii) That N.I.R.C had no jurisdiction to convert the Petitioner
under Regulation 32 (2) to 32 (1) by passing an iterim
order amounting to re-instatement of a retired person the
interim order thus passed is without jurisdiction.
(iv) That under sec 2 (xxviii0 and 25–A I.R.O 1969, person
who had been retired from employment was no more a
worker. Hence the Petitioner has no lucus standie to move
Petition before N.I.R.C. Petition itself is not maintainable,
the question of interim relief does not arise at all and as
such the interim order is liable to be vacated.
(v) That the Petitioner is estopped by his own conduct to make
Petition before N.I.R.C after accepting his retirement order
and availing all benefits anciliary thereto as such he is not
entitled to any interim relief prayed for.
Wherefore, it is respectfully prayed that the interim

relief given to the Petitioner vide order dated 15.9.96 be recalled
and vacated and in these terms, Petitioner’s application under
Regulation 32 (2) of the N.I.R.C (P & F) 1973 be disposed off
and dismissed with costs.
Applicant/Respondent
Dated: 27.10.99
Agricultural Engineer
Multan Division, Multan.
Through: -
Zafar Iqbal Khan,
Advocate High Court,
Chamber No. 124 District Courts,
Multan.
IN THE COURT OF MR. IJAZ AHMAD CHADHAR,
ADDITIONAL DISTRICT JUDGE, LAHORE.
Muhammad Asad Vs. Mst. Humaira Naz

Dower Appeal
Muhammad Asad Vs. Mst. Humaira Naz & another.
Maintenance Appeal
Master Usama Vs. Muhammad Asad
Maintenance Appeal
1. The above captioned three appeals are fixed for summoning
the record at the learned Trial Court.
2. That applicant’s Counsel Mr. Zafar Iqbal Khan Advocate is
busy in the Lahore High Court, Multan Bench and as such is
unable to appear before this Hon’ble Court today.
Original Cause list of the High Court Multan Bench is
attached herewith.
Wherefore, it is respectfully prayed that hearing of
the above appeals may kindly be adjourned some other date.
Applicant/Appellant
Dated: 26.10.99
Muhammad Asad
Through: -
Zafar Iqbal Khan,
Multan.
In the Court of District Judge, Multan.
Syed Jaffer Hussain Shah S/o Syed Shabbeer Hussain Shah

Caste Syed Bukhari R/o Chah Gulab Shah Wala Tehsil Melsi
District Vehari.
Applicant/Judgment Debtor
Versus
Muhammad Saddiq Ahmad Khan S/o Sultan Ahmad Khan
Caste Dahar R/o Fareedabad Colony, Masoom Shah Road,
Multan City.
Respondent/Decree Holder.
Application Under Order20 Rule 11

and Section 151 C. P.C. and Under
Section 11 of the West Pakistan Relief
of indebtedness Ordinance (xv) 1960.
Respectfully Sheweth:-
1. That the Respondent/Decree Holder instituted a suit under Order
XXVII C.P.C against the applicant/Judgment Debtor for the
recovery of Rs. 500,000/- on the basis of a Pronote alleged to
have been executed on 10.3.93 by the applicant in favour of the
Respondent.
2. That the suit was filed in the Court of Learned District Judge
Multan which was entrusted to the Court of Mr. Safdar Hussain
Malik, the learned Additional District Judge, Multan for disposal
and the same was disposed of by him vide order and decree dated
23.10.98.
3. That Mr. Safdar Hussiam Malik the Learned Additional Session
Judge Multan, who passed the decree, has since been transferred
and probably is succeeded by Ch. Muhammad Saddiq Tabassum
the learned Additional Session Judge Multan. This application
may be entrusted for disposal to the learned successor Judge of
Mr. Safdar Hussain Malik
4. That the applicant/Defendant in the suit made an application for
leave to appear and defend the suit which was allowed subject to
furnishing Bank Guarantee in the sum of Rs. 500,000/- The
applicant, being a poor agriculturist failed to comply with the
order of the Court with the result that the suit of the Plaintiff was
decreed forthwith vide order and decree dated 23.10.98 of the
learned Trial Court.
5. That against the order and decree dated 23/10/98 passed by Malik
Safdar Hussain the learned Additional Session Judge Multan, the
applicant filed an appeal (R.F.A. No. 4/99) in the Lahore High
Court Multan Bench, Multan which was taken up as a notice case
on 14.10.99 by a Division Bench of the Hon’ble High Court for
final hearing. During the course of arguments, the applicant made
an offer that he is prepared to take oath on Holy Quran that the
Pronote is without consideration or if the Respondent make a
Statement on Holy Book that he had paid a sum of Rs. 500,000/-
to the applicant, his appeal be dismissed. The Respondent took
oath and appeal was dismissed accordingly vide order and decree
dated 14.10.99 passed by the Division Bench of the Hon’ble
High Court Multan Bench. Copy of the Order dated 14.10.99 is
attached herewith as Annex “A”.
6. That meanwhile, the Respondent/Decree Holder filed execution
of the decree in the Court of Mr. Safdar Hussain Malik the
learned Additional District Judge Multan by attachment and sale
of agricultural land of the applicant/Judgment Debtor. The land
being situtate in Tehsil Melsi therefore the execution application
was transferred by the learned Additional District Judge to the
Court of Learned Civil Judge First Class, Melsi who on 4.10.99
issued warrant of attachment of the agricultural land belonging to
the applicant/Judgment Debtor measuring 53 kanals 8 marlas
comprising of Khewat No. 29 situated in Mauza Assar, Tehsil
Melsi District Vehari. Copy of the order of attachement is
Annex “B”.
7. That the applicant now seeks for order regarding payment of
decretal amount of Rs. 500,000/- on the
GROUNDS
(i) That the applicant is an agriculturist who owns only 53 kanals

8 marlas of agricultural land and this is the only source of his
livelihood. He owns no other property or any other source of
income. If this property is sold in execution of decree, the
applicant and his family would be deprive of his livelihood.
(ii) That it may be mentioned here that decree holder has taken a
false oath on Holy Quran. The Pronote is without
consideration. There was no reason as to why he should give a
poor, old and illiterate land tiller a heavy amount of
Rs. 500,000/- The applicant has been defrauded but he leaves
this matter of false oath taken by the decree holder to God
who is almighty to take care of him. The applicant is actually
ruined by the decree and in addition to under section 11 of the
West Pakistan Relief of Indebtedness Ordinance 1960, is also
entitled to be allowed payment of decretal amount in
installments on humanitarian ground.
Wherefore, it is respectfully prayed that this Hon’ble Court
may be gracious enough to accept this application and the
applicant/judgment debtor be allowed to pay the decretal
amount in installments according to his six monthly
agricultural income of the produce of his land measuring 53
kanals 8 marlas. Meanwhile further execution proceedings be
held in abeyance. Affidavit is attached.
Applicant
Dated: 27.10.99
Syed Jaffer Hussain Shah
Through: -
Zafar Iqbal Khan,
Multan.
In the Court of Senior Civil Judge, Multan.
M/S Punjab Construction Co. Through Mirza Muhammad Aslam,

Mnaging Director, R/o Farooqabad Road, Jam-Ke, Shekhupura.
Plaintiff/Applicant
Versus
1. B. Z. University Multan Through Dr. Muhammad Ishaq Akhtar,
Vice Chancellor B. Z. University Mutlan.
2. Executive Engineer (University Engineer/Project Director B.Z.
University Multan).
Defendants
Suit No. 350 of 1995
SUIT FOR RECOVERY OF RS. 440,000/-
Application for entrustment of above

captioned case in the couurt of successor
Judge of Mr. Ali Naqvi Tanweer Previous
Civil Judge Multan
1. That the above captioned suit was filed by the Plaintiff in the
Court of Senior Civil Judge, Multan which case was entrusted to
the Court of Syed Ali Naqvi Tanweer Civil Judge, Multan.
2. That during the pendency of the suit, the defendants made an
application u/s 4 of the Arbitration Act which application was
dismissed vide order dated 25.3.96 passed by the said learned
Civil Judge.
3. That against this order, the defendants filed an appeal (F.A.O. No.
50/96) in the Lahore High Court, Multan Bench which appeal
was finally heard and decided on 30.9.99 by Syed Najm–Ul-
Hassan Kazmi Judge and the case was remanded with the
direction that the learned Trial Court should decide the
application U/s 34 of the Arbitration Act afresh within two
months and shall also decide the case within three months.
Certified of the copy of the order of High Court is attached
herewith.
4. That Syed Ali Naqvi Tanweer the learned Civil Judge, Mutlan
has since been transferred and the case is to be fixed before the
learned Successor Judge where the original file of the case is still
pending awaiting the decision of F.A.O.
Wherefore, it is respectfully prayed that an order be

made for entrustment of case No. 350 of 1995 to the
Successor Court of Syed Ali Naqvi Tanweer The then learned
Civil Judge, Multan.
Applicant
M/S Punjab Construction Co.
Through: -
Zafar Iqbal Khan,
Multan.
In the Court of District Judge, Multan.
Syed Jaffer Hussain Shah Vs. Muhammad Saddiq Ahmad Khan
Application Under Order 20 Rule 11

and Section 151 C. P.C. and Under
Section 11 of the West Pakistan Relief
of indebtedness Ordinance (xv) 1960.
Affidavit of: -
Syed Jaffer Hussain Shah S/o Syed Shabbeer Hussain
Shah Caste Syed Bukhari R/o Chah Gulab Shah Wala
Tehsil Melsi District Vehari.
_______________
I, the above named deponent do hereby
solemnly affirm and declare that the contents of
the above application are true and correct to the
best of my knowledge and belief and nothing has
been kept concealed thereto.
DEPONENT
Verification: -
Verified on oath at Multan, this 27th
day of October, 1999 that the contents of this
affidavit are true to the best of my knowledge and
belief.
DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
C.M. NO. ________/1999

In
CR. NO. 652 /1982
1. Muhammad Amjad Khan

2. Muhammad Shoab Khan sons of Muhammad
3. Muhammmad Mohsin Khan Asad Khan
4. Fakhr-un-Nisa Begum Caste Pathan
5. Qamar-un-Nisa Begum Daughters of Tareen R/o
6. Mehmooda Begum Qasba Gujrat
7. Zohra Begum Tehsil Kot
8. Mst. Allah Jiwai Widow of Addu District
Muzaffargarh.
Applicants/Revision Petitioners
Versus
Mst. Hayat Zeb-un-Nisa D/o Abdur-Razaq Khan Caste Pathan
Tareen R/o Mauza Khadar Tehsil Kot Addu District Muzaffargarh.
Respondent
Application U/s 151 C.P.C. for Restoration

of C.R. 652/1982 dismissed for non-
prosecution on 19.10.99 by his lordship
Mr. Justice Maulvi Anwar-ul-Haq.
1. That the above captioned C. R. No. 652/82 was fixed for hearing
on 19.10.99 before his lordship Mr. Justice Maulvi Anwar-ul-
Haq. When the matter was called on for hearing on the date, the
applicant/Revision Petitioners were absent and their Council
Mr. Pervaiz Akhtar, being died was also not present and as such
the Civil Revision was dismissed for non-prosecution.
2. That the applicant was seriously ill and was getting medical
treatment in Multan when he got a telephonic message from
Qasba Gujrat that case of Mst. Hayat Zeb-un-Nisa is fixed for
hearing on 19.10.99. The medical certificate is attached.
3. That the applicant, himself being bed ridden due to illness, sent
one Nazir Hussain Nandla, a Mureed of the applicant to Mr.
Zafar Iqbal Khan Advocate for conformation of the date of
hearing.
4. That Mr. Zafar Iqbal Khan Advocate told the said Nazir Hussain
that the case of Mst. Zeb-un-Nisa is fixed for 2.11.99 (F.C).
5. That on 2.11.99, at 9 a.m. the applicant approached his said

council in the Court of his lordship Mr. Justice Maulvi Anwar-ul-
Haq and enquired of him as to why my family received the notice
for 19.10.99 instead of 2.11.99. The Council, first appeared in the
case of Zeb-un-Nisa which was fixed for hearing in this Hon’ble
Court and the said case was adjourned for 12.11.99. Thereafter,
he went to the office of the High Court to enquire about the other
date i.e. 19.10.99 where he was told that another case of Hayat
Zeb-un-Nisa (Cr. 652/82) was fixed for 19.10.99 and not the case
of Zeb-un-Nisa ( FAO 13/74). He was furhter told that C.R. No.
652/82 was dismissed for non-prosecution on 19.10.99.
6. That the applicant had two cases in the Hihg Court: Title of both
the case are almost similar
(I) Mst. Hayat Zeb-un-Nisa Vs. Muhammad Asad (F.A.O. 13/74)
(ii) Muhammad Asad Vs. Mst. Hayat Zeb-un-Nisa (C.R. 652/82).
7. That unfortunately, when the applicant received a message on

telephone, he thougth of the case of F.A.O. 13/74 and could not
recall in the memory the other case Cr. 652/82 as the said case
was never fixed after 22.9.87. That is why he sent Nazir Hussain
to Mr. Zafar Iqbal Khan advocate who is Council in F.A.O. 13/74
only and not in the case C.R. 652/82.
8. That the absence of the Petitioner in Cr. 652/82 was due to

mistaken belief that the same is a case of F.A.O. 13/74 in which
date of hearing was fixed by the Hon’ble High Court as 2.11.99
as it was told to Nazir Hussain by the said Council. The absence
of the applicant was not due to any negligence on his part and
was not in any way intentional.
9. That the Petitioners/Applicants had been perusing the case since

1982 diligently and their valuable rights are involved in the case.
If their case is not restored and decided on merits, they will suffer
an irreparable loss.
Wherefore, it is respectfully prayed that this Hon’ble

Court may be gracious enough to accept this application and
to restore the case Cr. 652/82 and to decide the same on merits
after notice to the Respondent. Affidavit of the applicant and
of Nazir Hussain and of Mr. Zafar Iqbal Khan advocate is
attached herewith.
Applicants/Petitioners
Date: -3.11.99
Muhammad Amjad Khan and others
Through: -
Zafar Iqbal Khan,
Multan. C.C. No. 2216

MULTAN.
C.M. NO. ________/1999
In
C.M. NO. 1499-C /1999
In
CR. NO. 652 /1982
1. Muhammad Amjad Khan

2. Muhammad Shoab Khan sons of Muhammad
3. Muhammmad Mohsin Khan Asad Khan
4. Fakhr-un-Nisa Begum Caste Pathan
5. Qamar-un-Nisa Begum Daughters of Tareen R/o
6. Mehmooda Begum Qasba Gujrat
7. Zohra Begum Tehsil Kot
8. Mst. Allah Jiwai Widow of Addu District
Muzaffargarh.
Applicants/Revision Petitioners
Versus
Mst. Hayat Zeb-un-Nisa D/o Abdur-Razaq Khan Caste Pathan
Tareen R/o Mauza Khadar Tehsil Kot Addu District Muzaffargarh.
Respondent
Application U/s 151 C.P.C. for restoration

of C.M. No. 1499-C/99 in C.R. 652/1982,
dismissed for non-prosecution on 1.12.99
by his lordship Mr. Justice Maulvi
Anwar-ul-Haq J.
1. That the above captioned application No. 1499-C/99 for
restoration of C. R. No. 652/82 was fixed for hearing on 1.12.99
which was dismissed for non-prosecution.
2. That on perusal of weekly regular list, Mr. Zafar Iqbal Khan

Advocate Counsel for the applicant, inadvertently, mistook the
date fixed as 2.12.99 instead of 1.12.99 and entered the same date
in his case diary and accordingly attended the Court on the same
date at 8 a.m. When he did not find his case in the list pasted
outside the Courtroom, on enquiry the Steno of the Court
informed the counsel that C.M. 1499-C/99 was fixed for 1.12.99,
which was dismissed for non-prosecution. Photocopy of the case
diary 1.12.99 & 2.12.99 is attached herewith as Annexure “A” &
“A/1”.
3. That mistake in noting the case was inadvertent and in no way

intentional or malafide on the part of the applicant or his
Counsel. It was just a human error.
4. That the applicant’s valuable right is involved in the case and in

case his case is not decided on merits, he will suffer an
irreparable loss.
Wherefore, it is respectfully prayed that this application

be accepted and C.M. No. 1499-C/99 in C.R. No. 652/82 may
kindly be restored and be decided on merits. Affidavit is attached.
Applicants/Petitioners
Date: -2.12.99
Muhammad Amjad Khan and others
Through: -
Zafar Iqbal Khan,

MULTAN.
C.M. NO. ________/1999
In
C.M. NO. 1499-C /1999
In
CR. NO. 652 /1982
Muhammad Amjad Khan etc. Vs Mst. Hayat Zeb-un-Nisa
Affidavit of: -
Muhammad Amjad Khan S/o Muhammad Asad Khan
Caste Pathan Tareen, R/o Qasba Gujrat, Tehsil Kot
Addu District Muzaffargarh.
I do hereby solemnly affirm and declare on oath

that all the averments in the above captioned
application are correct to the best of my knowledge and
belief. Nothing is untrue nor any fact is kept secret.
Deponent
Verification: -
Verified on this 2nd day of December, 1999 that
the contents of the application are true to the best of my
knowledge and belief.
Deponent

MULTAN.
C.M. NO. ________/1999
In
C.M. NO. 1499-C /1999
In
CR. NO. 652 /1982
Affidavit of: -
Zafar Iqbal Khan Advocate, 124-District Courts,
Multan.

Deponent
Verification: -
Deponent

MULTAN.
C.M. NO. ________/1999
In
C.M. NO. 1499-C /1999
In
CR. NO. 652 /1982
Affidavit of: -
Muhammad Amjad Khan S/o Muhammad Asad Khan
Caste Pathan Tareen, R/o Qasba Gujrat, Tehsil Kot
Addu District Muzaffargarh.

Deponent
Verification: -
Deponent

MULTAN.
C.M. NO. ________/1999
In
CR. NO. 652 /1982
Affidavit of: -
Zafar Iqbal Khan Advocate, 124-District Courts, Multan.
1. That I do hereby solemnly affirm and declare on oath that

Mr. Muhammad Amjad Khan Tareen (the applicant) is
my spiritual leader (Peer Sahib).
2. That on 17.10.99, Mr. Muhammad Amjad Khan was
seriously ill and was residing in my house in Mauza
Nandla, Tehsil & District Multan.
3. That he received a telephonic message from his family
member from Qasba Gujrat that case Mst. Hayat Zeb-un-
Nisa was fixed for 19.10.99 without further explaination
as to whether it was a case F.A.O. 13/74 or C.R. 652/82.
4. That under the instructions of Mr. Muhammad Amjad
Khan, I went to his Council Mr. Zafar Iqbal Khan
advocate to inform him about the fixation of Mst. Hayat
Zeb-un-Nisa’s case, who in turn told me that the case was
actually fixed by the Hon’ble High Court for 2.11.99 and
that is why we failed to appear in the case of C.R. 652/82
on 19.10.99.
5. That the default of non-appearance was due to a mistaken
belief that case of Mst. Zeb-un-Nisa (F.A.O. 13/74) was
fixed and that too was for 2.11.99 and not for 19.10.99. It
was in no way intentional.
6. That contents of the affidavit are correct and true and
nothing has been kept concealed thereto.
Deponent
MULTAN.
C.M. NO. ________/1999
In
CR. NO. 652 /1982
Affidavit of: -
Mr. Zafar Iqbal Khan Advocate, 124-District Courts,
Multan, C.C.No. 2216.
1. I do hereby solemnly affirm and declare on oath that

one Nazir Hussain Nandla who is the spiritual follower
of Mr. Muhmmad Amjad Khan Tareen, the applicant,
came to me on 17.10.99 to inform me that the case of
Mst. Hayat Zeb-un-Nisa was said to be fixed for
19.10.99. I told him that the case of Hayat Zeb-uin-Nisa
was fixed by the Hon’ble High Cout for 2.11.99 and not
for 19.10.99. I further decalre on oath that in my
knowledge, only one case of Zeb-un-Nisa was pending
in the High Court and I had no knowledge about the
pendency of another similar titled case (C.R. 652/82)
that is why I gave him the correct date of the case
(F.A.O. 13/74).
2. That on 2.11.99, when Mr. Muhammad Amjad Khan
contacted me in the High Court, and on his further
inquiry as to why a notice was received by his family
for a date 19.10.99, I went to the office and came to
know that it was in fact another case of Zeb-un-Nisa
(C.R. 652/82) which was fixed for 19.10.99 and the
same was dismissed for non-prosecution on the date.
3. That I further declare that non-appearance of the
Petitioners in the case (C.R. 652/82) was due to
mistaken belief and it was in no way intentional.
4. That contents of the affidavit are correct and true and
nothing has been kept concealed thereto.
Deponent
IN THE COURT OF MR. IJAZ AHMAD CHADHAR,

In re:
Master Ausama Vs Mehar Asad
Appeal U/2 14, Family Courts Act.

Application for rejection of
Memorandum of appeal.
1. On 10.3.98, a suit for recovery of maintenance was filed by Mst.
Humaira Naz and Master Ausama minor against the respondent
in the Family Court at Lahore. The Suit, after contest, was
decreed by the Family Court on 5.7.99. The respondent/defendant
was directed to pay past maintenance to Mst. Humaira Naz,
plaintiff No. 1 at the rate of Rs. 10,000/- per month w.e.f.
September, 1995 to 6.12.98 plus 3 months for iddat period and
Rs. 1,500/- per month was fixed as past maintenance and Rs.
3,000/- per month with 10% annual increase till arising of any
legal disability as future maintenance to master Ausama plaintiff
No. 2/Appellant.
2. Aggrieved by this decision, Master Ausama, the appellant filed
the above captioned appeal u/s 14 of the W.P. Family Courts Act,
1964 claiming therein the rate of maintenance (past and future) as
Rs. 10,000/- per month instead of Rs. 1500/- past maintenance as
decreed in his favour from September, 1995 to July 1999 (47
months) which was worked out by the learned Trial Court as Rs.
70,500/- In appeal, the appellant claims past maintenance for 47
months at the rate of Rs. 10,000/- per month which works out to
be Rs. 470,000/- in addition to future maintenance at the same
rate and as such the subject matter of appeal shall be Rs.
470,000/- the relief claimed in appeal minus Rs. 70,500/- as
decreed i.e. Rs. 399,500/- the difference between the two
amounts.
3. That under section 7 (I), First Schedule, Art I of the Court Fees
Act (viii of 1870), Memo of appeal shall be liable to ad valorem
Court fee, and as such a Court fee of Rs. 15,000/- was to be fixed
on the memo of appeal which the appellant had not paid.
Wherefore it is respectfully prayed that the appellant be

directed to pay Court fee of Rs. 15,000/- within the time fixed
by this Hon’ble Court, and in case of appellant’s failure to pay
the required Court fee, his memo of appeal be rejected.
Appellant
Dated: - 13.11.99
Mehar Asad
Through: -
Zafar Iqbal Khan,
In the Punjab Labour Court No. 9, Multan.

Ahmad Hassan Ghazi Vs. Agricultural Engineer
Petition U/s 22-A(8) (g), I.R.O. 1969.

Application for vacation of interim Stay order.
Authorities referred to on behalf of the

Applicant/Agricultural Engineer.
1. PLJ 1980 Lah. 478 “No order under regulation 32 (2) could be
passed without enquiry or hearing held in
presence of bothr the parties and that too
only to the extent of staying the likelihood
of occurrence of unfair labour practice. If

the action of compulsory retirement has
already been taken, commission in such
case could not set aside orders of
management retiring the employee-
interim
relief could not be granted.
2. PLJ 1987 TRC. (Labour) 98.
“Petitioner was compulsory retired
from service on the basis of misconduct
on his part. He was charge-sheeted,
enquiry was held, found guilty, and after
show cause notice, he was retired from
service. His retirement, having no
connection with his trade union activities,
application based on allegation of unfair
labour practice under section 22-A (8) (g)
of the Ordinance is not maintainable.
3. 1991 PLC 338 “Petition for stay not maintainable on the
vague allegation of unfair labour practice
without specific details as to where, when
and how it was committed.
4. 87 PLC 547 “It can not be said that if the management
takes action against a worker who is found
guilty of misconduct, it acts in violation of
section 15 of the Ordinance”.
1. PLD 1976 Lah. 611 “Reinstatement cannot be ordered as interim
relief. It is only when the management
found guilty of unfair labour practice, then
and only then reinstatement may be
ordered as consequential relief”.
2. NLR 1984 Labour 23 “In absence of prima facie case, no order
of reinstatement can be passed”.
3. 1987 PLC 547 “In absence of prima facie case, no
order of reinstatement can be
passed”.
4. 1987 PLC 349 “Unless unfair labour practice is
established on the part of
management, no order for
reinstatement could be granted
as interim relief”.
5. 1984 PLC 1342,
6. NLR 1989 Labour 8,
7. 94 PLC 413 “Retired person is no more a worker
hence not competent to invoke
jurisdiction of N.I.R.C”.
In view of the above authorities, it is respectfully

prayed that interim relief ex-parte granted to the Petitioner, may
very kindly be vacated and Petitioner’s application under
regulation 32 (2) be dismissed with cost.
Applicant
Dated: -13.11.99
Agricultural Engineer,
Multan.
Through: -
Zafar Iqbal Khan,
To,
The Motor Taxation Authority,
Excise and Taxation Office,
Multan.
Mst. Haseen Begum Widow of Malik Ghulam Hussasin Caste Bosan

R/o Mauza Bosan Utar, Tehsil and District Mutlan.
Applicant
Versus
Sheikh Abdul Salam partener International Motors Chowk
Rasheedabad Khanewal Road, Multan.
Respondent
Cancellation of Transfer of Ownership

of Motor Car Toyota Corrlla Model 1986
Registration No. MNV 23.In the name of
Respondent.
Sir,
1. That Motor Car No. MNV 23 Toyota Corolla Model 1986 was
owned and possessed by Malik Ghulam Hussain (deceased) S/o
Malik Haji Manzoor Ahmad Khan Bosan R/o Mauza Bosan Multan.
2. That said Malik Ghulam Hussain Bosan died of heart attack on
21.3.98 and the applicant and her daughters being the legal heirs of
Ghulam Hussain became owner in possession of the said motor car.
3. That the said motor car, after the death of applicant’s husband, used
to be driven by our driver Khadim Hussain and sometimes the
applicant’s brother Malik Muhammad Arshad Iqbal.
4. That Malik Muhammad Arshad Iqbal used to visit the respondent at
his show room International Motors in connection with his side
business.
5. That the Registration Book of the motor car was stolen and when it
came tot the knowledge of applicant’s driver about the missing of
the registration book from dash board diggi of the motor car, the
Petitioner was forced to get a duplicate copy of the registration book
after making a report in P. S. Gulgasht Multan.
6. That sometimes, whereafter the duplicate registration book was also
stolen. When the applicant came to know of this second theft of the
registration book, she through her brother, Muhammad Arshad Iqbal
enquired from the registration authority E.T.O office, Multan from
where it transpired that the ownership of the motor car has been
transferred in the name of the respondent.
7. That the applicant being the owner in possession of the motor car,
has never authorised any body for transfer of the registration and it
has come to know that the said respondent in collusion with the staff
of the registration authority has managed deceitfully to transfer this
car in his own name.
8. That the applicant is owner in possession of the car. She has never
sold it to the respondent nor she signed any transfer letter for the
transfer of the ownership. The respondent has got the transfer of
ownership in his name deceitfully and fraudulently and as such he
has committed the offence of 467/468/471 and 420/406 P.P.C.
Photo state copy of the death certificate of Ghulam Hussain and
copy of original registration book is attached herewith.
Wherefore, it is respectfully prayed that transfer of ownership

of the above motor car in the name of the respondent may kindly be
cancelled and its ownership in the record may restored as it was
before the impugned transfer. And proper legal action be taken
against the respondent and the concerned official of the department
with whose collusion the offence has been committed.
Yours faithfully,
Mst. Haseen Begum
Through: -
Muhammad Arshad Iqbal
(real brother).
Basti Bosan Utar Tehsil & District Multan.
IN THE COURT OF CHAUDHARY MUHAMMAD AZAM

CIVIL JUDGE, IST CLASS, MULTAN.
Sheikh Muhammad Sadiq vs. Ghulam Muhammad etc.
Suit for Specific Performance

Application for adjournment of hearing.
1. The above captioned suit is pending before this Hon’ble Court and is
fixed for today.
2. That the Plaintiff’s Counsel Mr. Zafar Iqbal Khan Advocate is to leave
for Lahore to pursue 4 cases W.P. 99/97, W.P. 99/98, W.P. 99/99 and
W.P. 6900 of the year 1998 fixed for final hearing before the Hon’ble
Division Bench of Chief Justice Lahore High Court, Lahore and as such
the counsel cannot appear in the above captioned case, the hearing of
which may kindly be adjourned to some other day.
Humble Applicant
Sheikh Muhammad Sadiq
IN THE COURT OF CHAUDHARY MUHAMMAD AZAM

CIVIL JUDGE, IST CLASS, MULTAN.
Ghulam Sarwar Vs. Haji Muhammad etc.
Suit for Specific Performance

3. The above captioned suit is pending before this Hon’ble Court and is
fixed for today.
4. That the Plaintiff’s Counsel Mr. Zafar Iqbal Khan Advocate is to leave
for Lahore to pursue 4 cases W.P. 99/97, W.P. 99/98, W.P. 99/99 and
W.P. 6900 of the year 1998 fixed for final hearing before the Hon’ble
Division Bench of Chief Justice Lahore High Court, Lahore and as such
the counsel cannot appear in the above captioned case, the hearing of
which may kindly be adjourned to some other day.
Humble Applicant
Ghulam Sarwar
IN THE COURT OF DIRECTOR EXCISE & TAXATION, MULTAN.

Azhar Iqbal Khan vs. E.T.O. Multan.
Appeal Property Tax.

P.U. No. 615-E, Shah Rukn-e-Alam colony, Multan.
Written Arguments on behalf of Appellant.
Sir,
The following are the written arguments being submitted on
behalf of the appellant: -
Description of property: - House No. 615-E S.R.A. Multan is built

upon a 5 marla plot.
Its building consists of:
2 small rooms (10”X10”) without
bath rooms.
1 Bathak
1 Galery (6”X14”)
1 Kitchen
1 Bathroom in courtyard
Condition of the House: - Due to twice breakage of West Bank of the

nearby Nobahar Canal, its water flew into
the houses, remained there for 6 days at a
level of 2 feet causing great damage to the
whole building.
Sole Ownership: - This house is occupied by the owner for

his residence. No other property is owned
by the owner or any member of his family
in Pakistan.
Ascertainment of Urban immovable property tax Act, 1958

Annual value U/s 5-A: - section 5-A (as ammended vide Punjab
Finance act, 1998).
The annual value is to be determined on
the bases of valuation table notified by or
under the authority of the Government.
Copy of section 5-A attached.
Note: - While ascertaining the annual value of

house in question, only two small principle
living rooms shall be taken into
consideration exclusive of ancillaries as
Bathak, Kitchen, Bathroom, Gallery etc.
Valuation Table: - Yardstick of the department shows annual

value Rs. 35 to Rs. 60 per room per month.
Keeping in view the small size of the
rooms and their damaged condition, the
anunal value may be ascertained at Rs. 35
per room per month and for two rooms, it
comes to Rs. (35X2) =70
annual value 70X12 = 840
Rebate of 10% for Rs. 840-84 = 756

Repairs: -
Further deduction Section 3 (2) reads:

U/s 3 (2) proviso:- “Provided that where a building is
occupied for residential purpose by the
owner himself, the tax shall be levied at
the said rate on one half of the annual
value of such building if the owner or any
member of his family does not own any
other property in that rating area”.
As such the annual value comes to
Rs. 756 X1/2 = 378
Further deduction
U/s 3(4): - Under section 3 (4) as amended by the
Punjab Finance Ordinance (xxii of 1981)
which reads:
“in case of property of the annual value not
exceeding 12,000/- rupees, a deduction of
Rs. 270/- from the annual value shall be
allowed”.
After deduction
Net annual Value: - 378-270 deduction U/s 3 (4) =108
Exemption from Tax

Section 4(C) (II) (1): - Section 4 Clause (C) (II) (1) reads:
“The Tax shall not be leviable in respect of
the following properties: -
(a)
(b)
(c) (i)
(ii) One building occupied by an owner
for his residence, the annual value of
which
(i) does not exceed one thousand and
eighty rupees in the rating areas of a
Municipality of the First class.
Examples: - Property No. 799-E S.R.A. (5 marla)

annual value ascertained at Rs. 206/-
Property No. 774-E S.R.A. (5 marla)
Property No. 513-A S.R.A. (5 marla)
In view of the above legal as well as factual

position, it is respectfully prayed that appeal be accepted and
property No. 615-E S.R.A. Colony, Multan may kindly be
declared exempted from levy of Tax u/s 4 of the property tax
Act, 1958 as amended.
Azhar Iqbal Khan

Appellant
Through: -
Zafar Iqbal Khan
124-District Courts,
Multan.
Note: -
It is requested that these written arguments may be made part of
the appeal file.
Advocate.
In the Court of Ijaz Ahmad Butter Sahib Civil Judge/

Rent Controller Multan.
Javed Iqbal S/o Muhammad Anwar Caste Arian R/o H.No. 123 A/4
Lalazar Colony, Multan.
Versus
Naseera Begum W/o Hameed R/o H. No. 123 A/4 Lalazar Colony,
Multan.
Ejectment Application.
Application for Contempt of Court.
1. That the above captioned Ejectment Application is pending
before this Hon’ble Court in which next date of hearing is fixed
as 8.12.99.
2. That the petitioner is the owner of the premises and is residing in
the upper portion of the house while respondent is equipping the
lower portion of the house as tenant.
3. That at the time of tenancy, only one electricity meter was
installed on the for domestic purpose but later on the respondent
started the beauty parlour in the premises and without knowledge
of the petitioner, she got the electricity connection converted into
commercial which is much more costly than the connection for
domestic purpose and she compelled the petitioner to pay his
share of bill at commercial rates.
4. That the petitioner aggrieved only to pay the electricity bill at
domestic rates and not on commercial rates whereupon the
defendant disconnected the electricity line going to the upper
portion of the house.
5. That the petitioner submitted the application before this Hon’ble
Court seeking directions to the tenant to restore the supply line to
the petitioner and charge the bill at domestic rates.
6. That through order dated 18.6.99 the learned Court decided the
controversy on the way and ordered the restoration of supply line
to the petitioner and directed the petitioner to pay the bill on
domestic and the remaining bill would be paid by the respondent
at commercial basis. It was further directed that if such
arrangement is not accepted by the respondent she may get the
domestic electricity meter restored for use by the petitioner as
replacement of former electricity meter.
7. That instead of complying with the directions of the Court,
respondent discontinued making the payment of bills at all which
resulted in disconnection of the supply line and removal of the
meter as such she made the petitioner to suffer for her fault.
Although the petitioner was ready to pay his share of electricity
bill at domestic rate.
8. That when the petitioner asked the respondent in the presence of
Aftab Ahmad and Fida Hussain to comply with the order of the
Court, she refused to do so and in this way, she took the order of
the Court as waste paper. This conduct of respondent amounts to
contempt of Court and liable to be punished.
Wherefore, it is respectfully prayed that respondent be
directed to get the domestic electricity meter restored for use
of the petitioner as it was at the very out set of the tenancy.
It is further prayed that penal action under the contempt
of court act be taken for denying the directions of the court
contained through order dated 18.6.99.
Affidavit is attached.
Applicant
Javed Iqbal
Through: -
Malik Muhammad Hanif Arain,
Advocate Multan.
In the Court of Ijaz Ahmad Butter Sahib Civil Judge/

Rent Controller Multan.
Javed Iqbal S/o Vs. Naseera Begum
Ejectment Application.
Application for Contempt of Court.
AFFIDAVIT of:-
Javed Iqbal S/o Muhammad Anwar Caste Arian R/o
H.No. 123 A/4 Lalazar Colony, Multan.

solemnly affirm and declare that the contents of the
above application are true and correct to the best of my
knowledge and belief and nothing has been kept
concealed thereto.
DEPONENT
Verification: -
Verified on oath at Multan, this ____day
of December, 1999 that the contents of this affidavit
are true to the best of my knowledge and belief.
DEPONENT
IN THE LAHORE HIGH COURT LAHORE.
Muhammad Asad Vs. Mst. Humera Naz etc.

Writ Petition under Article 199
the Constitution of Islamic Republic of Pakistan.
Authorities referred to on behalf of the petitioner.
S.No. Citations Jist of Authorities.

1. PLD 1987 Kar 612 Art. 2 (A) Constitution of
at 614 (k) Pakistan 1973. Court is
empowered to construe and
enforce existing laws, with
such adaptations as are
necessary in the light of
Qur’an & Sunnah.
2. PLD 1976 Lah. Muhammadan Law-marked

930 at 933 (g) trend of suerior judiciary in
Pakistan to apply Islamic
Law and its principles where
statute law either silent or
to be interpreted or leaves
matter in Court’s discretion.
3. Family Courts Act Family Court shall have

Sec. 5 exclusive jurisdiction to entertain, hear and adjudicate
upon matters specified in schedule.
Schedule: (iii) Maintenance.
Sec. 20 Family court is invested with
powers of magistrate as
exercised in sec. 488 Cr.P.C.
Note: - Sec. 488 Cr.P.C.
admits only future
maintenance.
Note: - Section 5 of F.C. Act
is silent regarding past or
future maintenance. The
matter of maintenance is left
at Court’s discretion and in
view of the Art. 2 (A) of
Constitution, the Court is
not only empowered but duty
bound to apply Islamic law
i.e. sect. 278 Muhammadan
Law.
4. Sec. 278 Muhammadan If the husband neglects or

Law. refuses to maintain his wife
without any lawful cause,
the wife may sue him for
maintenance, but she is not
entitled to a decree for
past maintenance, unless
claim is based on a specific
agreement.
Note: - There was no

agreement of maintenance
between the spouse. There is
no neglect or refusal on the
part of the appellant to
maintain his wife and son as
per admissions of the
respondent in her statement
as P.W.
5. NLR 1991 SD 347 Maintenance to wife under

Islamic Law. There is no
scope for past maintenance
to wife.
6. PLD 2000 FSC I Muslim Family Laws Ord.

1961---Sec. 7 (3) (5) are
repugnant to injunctions of
Islam.
7. Sec. 313 A divorce in writing
Muhammadan law.Operates as an irrevocable
divorce and takes effect
immediately on its
execution.
Note: - Written Divorce deed
Dated12.2.98 was produced

along with written statement
in suit for maintenance.
Though not exhibited as the
same was admitted.
8. 1992 SCMR 1273 Muslim Family Law Ord.

S.7 read with Art. 2 (A) of
the Constitution. Divorce
becomes effective even in
the absence of notice to the
Chairman under sec. 7.
Ineffectiveness of divorce, in
the absence of a notice to

the Chairman, as
envisaged by sec. 7 was
against injunctions of Islam.
9. PLD 1988 Kar. Held same as above.

169 at 173
10. 1990 MLD W.P. Family Court Act,

344 at 345(e). 1964 sec. 5. Suit for
maintenance by a divorced
wife is not maintainable.
Note: - Written divorce

dated 12.2.98 being effective
immediately, suit for
recovery of maintenance
having been filed on 10.3.98
was not maintainable. The
Plaintiff however, at the most
entitled to maintenance for a
period of Iddat of 90 days
ending 12.5.98 and as such
she is entitled to
maintenance for two months
from 10.3.98 to 12.5.98.
11. PLD 1976 AJK Past Maintenance Under

9 at 10(d). Hanfi School of Law,
not being permissible and
available only from the
date of application or suit.
12. PLD 1958 (W.P) Lah Muhammadan Law.

596 (e). Past maintenance can not be
claimed from father unless
previously fixed by Court.
13. 1991 CLC 766 Muslim Family Law Ord.

Sect. 9-Past Maintenance
cannot be granted to minor,
but application of father for
custody of minor being
pending before guardian
judge, future maintenance till
decision of application could
be granted to minor.
Note: - Admittedly
application of the appellant
for custody of his minor son
is pending in the Court of
Guardian Judge, Lahore,
which is fixed for the
evidence of the parties.
14. 1994 MLD 574 Determination of rate of

maintenance payable by
father to his son without
determining monthly income
of father and without taking

into consideration evidence
on record is illegal and liable
to be set aside.
Note: - the learned trial
Court had left out of
consideration all the
documentary exhibit D1 to
D7 and Mark “D” and “E”
and Divorce deed as well as
oral evidence from where
monthly income of the
father
could be very correctly
determined.
15. Sect. 5 read with The columns of Nikah Nama

rule 10 Muslim Family is to be filled in by the Nikah
Laws Ordinance 1961. Registrar with responsibility.

Rule 10(1) The Nikah
Registrar shall fill in form II
in quadruplicate, in the
Register, the persons whose
signatures are required in the
Form, shall then sign and

the Nikah Registrar shall
then affix his register and
seal thereto and keep the
original intact in the
Register.
(2) The duplicate and
triplicate of the Nika Nama
filled in as aforesaid shall be
supplied to the bride and
bridegroom respectively on
payment of 50 paisas each
and the quadruplicate shall
be forwarded to the Union
Council.
Note: - In view of the above

rule, correctness of entries of
Nikah Nama was to be
proved by the Nikah
Registrar who is supposed to
have filled in the forms of

Nikah.
In this case, Nikah
Registrar was not produced
as a witness as such the best
evidence was withheld, the
presumption would go
against
the plaintiff who claims benefit
out of Nikah Nama.

16. Sect. 289 Proper Dower.
Muhammadan Law. If the amount of dower is not
fixed, only the wife is

entitled to proper dower.
17. PLD 1992 SC. Mere failure to exhibit a
822 at 823 (C). document formally would
not make any difference and
if it was necessary for just
decision of the case, it
should be read in evidence.
PETITIONER
Dated: -__________
(MUHAMMAD ASAD)
Through: -
ZAFAR IQBAL KHAN
Multan.

MULTAN.
W.P. No.______________/2000
Riaz Hussain S/o Haji Ghulam Hussain Caste Thaheem R/o Mauza
Nai Wala, Tehsil & District Multan.
Petitioner
Versus
1. Manager Agricultural Development Bank of Pakistan, Branch
Abdali Road, Nawan Sheher Multan.
2. Mobile Credit Officer Agricultural Development Bank of
Pakistan, Branch Abdali Road, Nawan Sheher Multan.
Respondents

Of The Constitution of Islamic
Republic of Pakistan, 1973.
1. That names and addresses of the parties have correctly been
given in the Heading of the petition for the effective services of
summons.
2. That petitioner is an agriculturist. He applied for loan from the

Respondent Bank for the purchase of Tractor, seed and fertilizers.
3. That petitioner’s application was accepted by the respondent on

30.12.1997 and he sanctioned a loan of about Rs. 450,000/- in
favour of the petitioner for the purchase of Tractor, seed and
fertilizers etc. (Note: The correct loan amount figures will be
given by the respondent Bank).
4. That for the security of loan, petitioner mortgaged his agricultural

land with the respondent Bank.
5. That it may be mentioned here that Tractor so purchased was

registered in the name of the respondent Bank although the actual
possession of the tractor was handed over to the petitioner.
6. That the conditions for repayment of loan were that after the
concession/lapse of complete first year, the loan was to be paid in
six monthly installments of Rs. 28,000/- each i.e. by the end of
June and by the end of December of every year. The whole
period for repayment of complete loan is 8 years from the date
the same was sanctioned/obtained.
7. That the petitioner’s first installment was due by the end of

December 1998 and further after every six months.
8. That the petitioner paid installments rather before dates and much
more amount than the due installments. The detail of which is
given below: -
Installments paid Date of payment Amount paid 1st

Installment 30.12.1997 59,700/-
2nd installment 08.01.1999 139,000/-
3rd Installment 09.01.1999 4,250/-
4th Installment 11.06.1999 176,600/-
5th Installment 12.06.1999 3,650/-
Total amount paid 383,200/-
Photocopies of receipts are attached as Annexes “A, A/1, A/2,
A/3 & A/4”.
9. That as per conditions of the loan, the petitioner was bound to

pay six monthly installments @ 28,000/- per installment from
December 1998 to December 1999 (three in all) which comes to
Rs. 84,000/- and as such in view of the above paid amount the
petitioner has already paid Rs. 299,200/- more than it was due.
10.That the respondent Bank insists for payment of one installment

of December 1999 without taking into consideration that the
same has already been paid well before due date.
11.That unfortunately, virus disease spread in the area of petitioner

and cotton crop of the petitioner was partly damaged and
whatever was left it was sold on a very low rate due to wrong
policy of the Govt. as the Govt. before the cotton crops has
imported heavy quantity of cotton from the foreign country and
as such there was left no demand for the cotton of this country
with the result that the petitioner and the other cotton growers
suffered a great loss rendering them penniless. And as such the
petitioner failed to pay the two installments for the year 1999
although if the amount already paid is considered then the over
payment might be adjusted towards the two installments for the
year 1999 and as such the petitioner could not be harassed for
non-payment of the two installments for the year 1999 which in
fact had already been paid before time.
12.That now the respondents have started harassing the petitioner for
making recovery of the two installments through coercive
measures. The respondents are bent upon to arrest the petitioner
in case the one alleged installment is not paid forthwith. The
petitioner requested the respondents for rendition of accounts, but
genuine demand of the petitioner has not been acceded to by the
respondents. Even they are not issuing any demand notice to the
petitioner.
13.That in view of the over payment made by June 1999, the

petitioner could not be held defaulter as the amount already paid
fully covers the amount of one installment December 1999.
However, petitioner undertakes to make payment of the said one
installment in June and December 2000 in addition to the usual
six monthly installments.
14.That the harassment and coercive actions being taken by the

respondents against the petitioner are illegal and unwarranted by
law. The period for repayment of loan is 8 years extended upto
the year 2006 and the coercive measures adopted by the
respondents for the recovery of outstanding amount of loan is
totally illegal and unwarranted by law and they have no right and
authority to take coercive measures without adopting the course
of law.
15. That the petitioner’s valuable land which is much more than
sufficient to cover the entire loan amount is already mortgaged
with the respondent Bank as security of loan. The tractor
purchased with the loan amount is also registered in the name of
respondent Bank and further petitioner has already been vigilant
in payment of installments rather more than it was due. In the
circumstances it is cruel on the part of the respondents to take
coercive measures and extreme step for recovery of outstanding
loan by arresting and detaining the petitioner in jail. Such
threatening steps of the respondents for the recovery of loan are
without lawful authority in the circumstances. 1995 MLD P 12
is authority on the point.
16.That the petitioner requested the respondents so many times not

to take any coercive measures and not to harass the petitioner and
his other family members by creating mental torture so threats of
putting him in jail but they are adamant to do so.
17.That the petitioner is now left with no alternate and efficacious

remedy in law except to invoke the extra ordinary jurisdiction of
this Hon’ble Court.
Wherefore, it is respectfully prayed that this

Hon’ble Court may very graciously be pleased to accept
the Writ Petition and direct the respondents not to take
any coercive measures for the realization of loan
amount till the months of June 2000 and December
2000.
It is further prayed that any other appropriate
relief which this Hon’ble Court deems fit may also
kindly be granted.
Affidavit is attached herewith.
Petitioner
Through: -
Zafar Iqbal Khan
Multan.
C.C. No. 2216
MULTAN.
W.P. No.______________/2000
Riaz Hussain Vs Manager A.D.B.P. etc.
AFFIDAVIT of: -
Riaz Hussain S/o Haji Ghulam Hussain Caste Thaheem
R/o Mauza Nai Wala, Tehsil & District Multan.

the above Writ Petition are true and correct to the
DEPONENT
Verification: -
Verified on oath at Multan, this 23rd day of
February 2000 that the contents of this affidavit are
true to the best of my knowledge and belief.
DEPONENT

MULTAN.
C. M. No. ___________/2000
In
W.P. No.____________/2000
APPLICATION FOR DISPENSING WITH THE

FILING OF CERTIFIED COPIES OF ANNEXURES.
=========================================
Respectfully Sheweth:-
That certified copies of Annexures “A, A/1 to A/4” are
not available. However, uncertified/photo state copies of the
same have been annexed with the Petition, which are true
copies of original documents. The original documents can be
produced if required in Court.
It is, therefore, respectfully prayed that this Hon’ble

court may please dispense with the filing of aforesaid copies
of documents.
PETITIONER
Dated: 23.02.2000 Riaz Hussain
Through: -
Zafar Iqbal Khan
Multan.
C.C. No. 2216

MULTAN.
C. M. No. ___________/2000
In
W.P. No.____________/2000
Dispensation Application
Affidavit of: -
Riaz Hussain S/o Haji Ghulam Hussain Caste Thaheem
R/o Mauza Nai Wala, Tehsil & District Multan.
_______________

the above application are true and correct to the
DEPONENT
Verification: -
Verified on oath at Multan, this 23rd day of
February 2000 that the contents of this affidavit are
true to the best of my knowledge and belief.
DEPONENT

MULTAN.
C. M. No. ___________/2000
In
W.P. No.____________/2000
Stay Application
1. That the above titled petition has been filed in this Hon’ble
Court.
2. That the contents of the accompanying petition may kindly be
read as integral part of this petition.
3. That the petitioner is not defaulter. This petition is based on
good grounds, which is likely to succeed.
4. That in case the respondent is not restrained from adopting
coercive measures for the recovery of undue installments, the
petitioner shall suffer irreparable loss.
5. That the threat of the respondents of arresting the petitioner
and putting him in jail is illegal and without lawful authority.
6. That balance of convenience lies in favour of the petitioner.
Wherefore, it is respectfully prayed that pending final
decision of the Writ Petition, the respondents may kindly be
restrained from arresting the petitioner and adopting
coercive measures for the recovery of alleged unpaid one
installment for December 1999.
Applicant
Through: -
Zafar Iqbal Khan
Multan.
C.C. No. 2216
MULTAN.
W.P. No.______________/2000
Mulazim Hussain S/o Haji Ghulam Hussain Caste Thaheem R/o

Mauza Nai Wala, Tehsil & District Multan.
Petitioner
Versus
1. Manager Agricultural Development Bank of Pakistan, Branch
Abdali Road, Nawan Sheher Multan.
2. Mobile Credit Officer Agricultural Development Bank of
Pakistan, Branch Abdali Road, Nawan Sheher Multan.
Respondents

Of The Constitution of Islamic
Republic of Pakistan, 1973.
Date: 23.02.2000
Through: -
Zafar Iqbal Khan
Multan.
C.C. No. 2216
MULTAN.
W.P. No.______________/2000
INDEX
S. No. NAME OF DOCUMENTS ANNEXURES PAGES
1 Urgent Form
2 Stamp Paper worth Rs. 500/-
3 Writ Petition.
4 Affidavit
5 Receipt dated 30.12.1997 A
6 Receipt dated 08.01.1999 A/1
10 Sanction Letter. B
11 Dispensation Application.
12 Affidavit.
13 Application u/s 151 C.P.C.
14 Affidavit
15 Vakalatnama
PETITIONER
Through: -
Zafar Iqbal Khan
Multan.
C.C. No. 2216
Before Member Board of Revenue, Lahore, Camp at Multan.
In re: Saleem Ahmad etc. Vs. Mst. Ruqaya Begum and others.
R.O.R. No. 2019/96
Application for adjournment of Hearing
Respected Sir,
1. That the above captioned Revision Petition is fixed for today.
2. That Mr. Zafar Iqbal Khan Advocate Counsel for respondents
No. 1 to 5 is busy today in a notice case titled Muhammad
Asad Khan Vs. Mst. Hayat Zeb-un-Nisa before the Hon’ble
High Court, Multan Bench and on 24.2.2000 he is also busy in
connection with two Writ Petition titled as Mulazim Hussain
Vs. A.D.B.P. & Riaz Hussain Vs. A.D.B.P.
Wherefore, it is respectfully prayed

that hearing of the abvoe R.O.R. may be
adjourned to some other day.
Applicants
Date: 23.02.2000
Mst. Ruqaya Begum etc.
(Respondents No. 1 to 5)
Through: -
Zafar Iqbal Khan
Multan.
C.C. No. 2216
In the Court of Mr. Muhammad Akram Rana, Civil Judge,
Multan.
Punjab Construction Company Vs. B.Z. University etc.
Suit for Recovery

Application under orders 14, 5 C.P.C.
Written Reply on behalf of Plaintiff/respondent.
1. That Para No. 1 of the application is correct.
2. That Para No. 2 of the application is correct.
3. That Para No. 3 of the application being misconceived is
incorrect. Issues No. 1, 2 & 3 had already been framed
covering all the said three preliminary objections taken in the
written statement and as such there is no need to frame further
issues.
Application is misconceived, the same is made
with malafide intention to delay the disposal of the suit
which is to be decided within a limited period as
directed by the Hon’ble High Court. Application be
dismissed with cost.
Plaintiff/Respondent
Dated: 24.02.2000
Through: -
Zafar Iqbal Khan
Multan.
C.C. No. 2216
IN THE COURT OF MR. IJAZ AHMAD CHADDHAR,
(1) Muhammad Asad Vs. Humera Naz,

(2) Muhammad Asad Vs. Humera Naz etc.
(3) Master Usama Vs. Muhammad Asad
Family Appeals
1. That the above-captioned 3 appeals were fixed for 18.3.2000
which date happened to be Eid Holiday.
2. That today dated 20.3.2000, being the next opening day, the
appeals are supposed to be taken up for hearing.
3. That Mr. Zafar Iqbal Khan advocate, Multan, Council for
Muhammad Asad appellant is pre-occupied in a notice case
FAO 13/1974 before the Hon’ble High Court, Multan Bench
Multan and as such is unable to appear before this Hon’ble
Court today. Original Notice of the High Court is attached
herewith.
Wherefore, it is respectfully prayed that in the
interest of justice, the hearing of the above 3 appeals
may kindly be adjourned for some other date.
Appellants
Dated: 20.3.2000
Through: -
Zafar Iqbal Khan
Multan.
C.C. No. 2216
My dear Shazia, I am much worried to know from you mother
that your married life is still unsatisfactory. I think that I see your
difficulty and it is this that you have developed a habit of negative
attitude---an attitude of doubt and not good expectations. I advise
you to keep your heart free from hate, your mind from worry, live
simply, expect little, give much. Fill your life with love. Scatter
sunshine, forget self and think of others. Do as you would be done
by. Learn believing develop your habit of expecting the best, not the
worst. Change your habit of belief and not disbelief. Learn to expect
and not to doubt.
When you trust in Allah, He guides your mind, so that you do

not want things that are not good for you or that are inharmonious
with Allah’s will.
When you expect the best, you release a magic force in your
mind, which by law of attraction tends to bring the best to you. But
if you expect the worst, you release from your mind the power of
repulsion which tends to force the best from you expecting the best
means that you put your whole heart into what you want to
accomplish. People are defeated in life not because of lack of ability
but for lack of whole heartedness. Life cannot deny itself to the
person who gives life his all. Do not be hold out. Go all out. Do this
and life will not hold out on you. It is what is in your heart, either
good or bad, strong or weak, that finally comes to you.
As to your married life, it is not very happy. The reason is that

you are really quite severe to your husband. Your such negative
attitude represents a serious fault. I think your husband would have a
difficult time if you checked him that closely all the time. In fact,
you would so dominate him, but your marital life would be
unsatisfactory.
Love cannot live under domination. I must say you have a

very fine way of pressing your lips together which indicates a
domineering attitude. The average male does not like to be
dominated.
By grace of Allah, you have got a charming personality, but
due to your negative thinking, you wear hard lines on your face. You
must have a little softness, a little tenderness. Your dress, it needs
not be expensive, but it should be well tailored and well worn. You
may also add a little sweet smelling perfume. But, the really
important thing is to get a new attitude that will change the lines on
your face and give you that indefinable quality and charm known as
spiritual joy. This will make you release charm & loveliness in you.
There is an old saying that “God runs a beauty parlour”. I explain it,
you might have seen in college girls, who were very pretty. But
when you met her after 20 years or so, their beauty is faded. On the
other hand, other girls came to college who were very plain, but
when they returned thirty years later, they are beautiful women.
What made the difference. The latter had the beauty of an inner
spiritual life written on their faces. This is –“God runs a beauty
parlour”. Face is the index of mind. If your thinking is positive, your
face will reveal charm, if you think in negative, your face will show
negative lines.
I hope you shall be intelligent enough to understand this point,

which is a hard reality.
With best wishes.

Your loving father.

Zafar Iqbal

Hochgeladen von

Dokumentinformationen

Originalbeschreibung:

Copyright

Verfügbare Formate

Dieses Dokument teilen

Dokument teilen oder einbetten

Freigabeoptionen

Stufen Sie dieses Dokument als nützlich ein?

Sind diese Inhalte unangemessen?

Copyright:

Verfügbare Formate

Zafar Iqbal

Hochgeladen von

Copyright:

Verfügbare Formate

IN THE LABOUR COURT NO. 9, MULTAN.

Petition U/s 22-A (8) (g) of the I.R.O 1969.

This application for vacation of

Wherefore, it is respectfully prayed that the interim

Muhammad Asad Vs. Mst. Humaira Naz

Syed Jaffer Hussain Shah S/o Syed Shabbeer Hussain Shah

Application Under Order20 Rule 11

(i) That the applicant is an agriculturist who owns only 53 kanals

M/S Punjab Construction Co. Through Mirza Muhammad Aslam,

Application for entrustment of above

Wherefore, it is respectfully prayed that an order be

M/S Punjab Construction Co.

Syed Jaffer Hussain Shah Vs. Muhammad Saddiq Ahmad Khan

Application Under Order 20 Rule 11

C.M. NO. ________/1999

1. Muhammad Amjad Khan

Application U/s 151 C.P.C. for Restoration

5. That on 2.11.99, at 9 a.m. the applicant approached his said

7. That unfortunately, when the applicant received a message on

8. That the absence of the Petitioner in Cr. 652/82 was due to

9. That the Petitioners/Applicants had been perusing the case since

Wherefore, it is respectfully prayed that this Hon’ble

Muhammad Amjad Khan and others

IN THE LAHORE HIGH COURT, MULTAN BENCH,

1. Muhammad Amjad Khan

Application U/s 151 C.P.C. for restoration

2. That on perusal of weekly regular list, Mr. Zafar Iqbal Khan

3. That mistake in noting the case was inadvertent and in no way

4. That the applicant’s valuable right is involved in the case and in

Wherefore, it is respectfully prayed that this application

Muhammad Amjad Khan and others

IN THE LAHORE HIGH COURT, MULTAN BENCH,

Muhammad Amjad Khan etc. Vs Mst. Hayat Zeb-un-Nisa

I do hereby solemnly affirm and declare on oath

IN THE LAHORE HIGH COURT, MULTAN BENCH,

Muhammad Amjad Khan etc. Vs Mst. Hayat Zeb-un-Nisa

I do hereby solemnly affirm and declare on oath

IN THE LAHORE HIGH COURT, MULTAN BENCH,

Muhammad Amjad Khan etc. Vs Mst. Hayat Zeb-un-Nisa

I do hereby solemnly affirm and declare on oath

IN THE LAHORE HIGH COURT, MULTAN BENCH,

Muhammad Amjad Khan etc. Vs Mst. Hayat Zeb-un-Nisa

1. That I do hereby solemnly affirm and declare on oath that

Muhammad Amjad Khan etc. Vs Mst. Hayat Zeb-un-Nisa

1. I do hereby solemnly affirm and declare on oath that

IN THE COURT OF MR. IJAZ AHMAD CHADHAR,

Appeal U/2 14, Family Courts Act.

Wherefore it is respectfully prayed that the appellant be

In the Punjab Labour Court No. 9, Multan.

Petition U/s 22-A(8) (g), I.R.O. 1969.

Authorities referred to on behalf of the

of occurrence of unfair labour practice. If

In view of the above authorities, it is respectfully

Mst. Haseen Begum Widow of Malik Ghulam Hussasin Caste Bosan

Cancellation of Transfer of Ownership

Wherefore, it is respectfully prayed that transfer of ownership

Mst. Haseen Begum

IN THE COURT OF CHAUDHARY MUHAMMAD AZAM

Suit for Specific Performance

Sheikh Muhammad Sadiq

IN THE COURT OF CHAUDHARY MUHAMMAD AZAM

Suit for Specific Performance

IN THE COURT OF DIRECTOR EXCISE & TAXATION, MULTAN.