Nasir (1533 & 1535)

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

C.M. No. 1533/02 In W.P. No. 5883/02 Nasir Mahmood

Vs.

Govt. of Pakistan.

Application under Order 6, Rule 17 and Section 151 C.P.C. Written Reply.

Respectfully Sheweth: Preliminary Objection: 1.

That the applicant has no cause of action to file this application at this stage.

2.

That the applicant has no locus standi to file this application.

3.

That this application is after-thought. First of all the applicant claimed the policy of respondents No. 1 & 2, but later on when a written reply for the main petition was filed by the respondent No. 1, then by changing the plea, the applicant filed this application, which is liable to be dismissed.

4.

That the amendment may not be allowed to fill the lacunas of case.

ON MERITS: 1.

That para No. 1 along-with grounds is not admitted to be correct. The amendment required by the applicant is an exercise to fill in the lacunas at belated stage.

10 a. That the Annex “J” mentioned in this para is quite ambiguous. The annexure referred has no identification, valid signature and reference to context, in respect of issuing authority. It is also clear that, when, and for what purpose the Annex “J” was issued and how this annexure is relevant for the main petition. 10 b. That this para is also ambiguous in the main petition no respondent No. 4 is mentioned. 10 c. That the para referred is not correct, it is an exercise to fill in the lacunas at belated stage. It is therefore, prayed that this application may please be dismissed with cost. Any other relief, which this Hon’ble Court deems fit and proper, may graciously be awarded to the respondent. Dated: __________ Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959

Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

C.M. No. 1535/02 In W.P. No. 5883/02 Nasir Mahmood

Vs.

Govt. of Pakistan.

Application under Order 1, Rule 10 and Section 151 C.P.C. Written Reply.

Respectfully Sheweth: Preliminary Objection: 1. That the application is pre-mature at this stage and liable to be dismissed. ON MERITS: 1. That para No. 1 is formal and needs no reply. 2. That this para of application is not correct. The instructions placed on file as Annex “J” does not transpire the authority who issued these instructions, so until and unless the authority, who issued the instructions is not unveiled, no one can be inducted as a necessary party. 3. That para No. 3 is incorrect, however, concerned with the merits of main case, cannot be commented at this stage.

It is therefore, prayed that this application may please be dismissed with cost. Any other relief, which this Hon’ble Court deems fit and proper, may graciously be awarded to the respondent. Dated: __________ Through: Hammad Afzal Bajwa, Advocate High Court, 28-District Courts, Multan. C.C. No. 20959

Sheikh Muhammad Faheem, Advocate High Court, 28-District Courts, Multan. C.C. No. 20176

IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.

C.M. No. 1535/02 In W.P. No. 5883/02 Nasir Mahmood

Vs.

Govt. of Pakistan.

Application under Order 1, Rule 10 and Section 151 C.P.C. Written Reply. AFFIDAVIT of: Rehan Suleman S/o E. Suleman, R/o 359, Shah Rukn-e-Alam Colony, Multan. I, the above named deponent do hereby solemnly affirm and declare that the contents of the above-titled written reply 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 September 2002 that the contents of this affidavit are true & correct to the best of my knowledge and belief. Nothing has been kept concealed thereto. DEPONENT