Tayyaba
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IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No._____________/2001 Tayyaba Sultana daughter of Muhammad Yaseen, caste Qureshi, R/o 325/326 Satellite Town, Bahawalpur. Petitioner VERSUS 1. Government of Punjab through Secretary Health Division, Punjab Secretariat, Lahore. 2. Health Department through Director General, Punjab Secretariat, Lahore. Respondents
Writ Petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973.
Respectfully Sheweth: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the National Guard Act, 1973 was assented by the Parliament for the purposes of initial Military Training. So many forces were established under this act from the general public. This act was implemented upon the educational institutions. A corps was established in the male institutions, it was called as “National Cadet Corps” and in the female institutions as “Women Guards”.
3. That it was very much clear in the act u/s 29 (c) that the person who will complete the training successfully at the time of admission in any institution the student will be given benefit of 10% of the marks obtained the said examination. This section was further amended in 1975 and concession of 20 marks instead of 10% marks was allowed to a student who has completed the training under this act, at the time of admission in any institution. The real spirit of this act was to create a loyal sense among the youth to defend their country. 4. That the right of this concession is guaranteed by the legislation and till now the act is not abrogated and every institution which is supposed for general education, professional education or advance studies, giving benefit of this legislation to every student/candidate at the time of admission. The petitioner has completed his training in N.C.C. during his studies and certificate in this regard is Annex “A” and the copy of F.Sc. Certificate is Annex “A/1”. 5. That the petitioner submitted his admission form for the admission of professional course of M.B.B.S/B.D.S. and an entry test was held on 22.10.2001 under the supervision and control of respondents. The result of entry test was issued on 4.11.2001 in which the merit ranking of the petitioner is 3858. Copy is annexed as Annex “B”. 6. That the petitioner remained taken aback when it came to their knowledge that 20 marks for the training of N.C.C. were not included, while preparing the merit list. On the other hand in the whole Punjab, for every professional course, as well, at the time of admission 20 marks for N.C.C. training were included for the consideration of merit. The abstract of admission part from the prospects of Medial Colleges, University of Engineering and Technology and B.Z.U. Multan are enclosed herewith as Annexes “C, D & E”. 7. That there must be infirmity for the purpose of admission in whole the Punjab, because the future of thousands of students is
annexed with this practice of authorities. There must not be any type of discrimination and right of every individual shall be safeguarded as required under the constitution through articles 2(A), 4 and 25. 8. That the respondents have prepared the merit ranking without giving the benefit of 20 marks for N.C.C. Training and going to publish the same within days. At this stage, the petitioner are left with no other alternate, efficacious, adequate or speedy remedy except to invoke the constitutional jurisdiction of this Hon’ble Court for the redressal of their grievance. Keeping in view the above-mentioned facts, it is respectfully prayed that the respondents may please be directed to prepare the merit ranking of petitioner after giving benefit of 20 marks for N.C.C. Training. Any other writ, order, direction or relief which this Hon’ble Court deems fit, may please be extended in the favour of petitioner to meet the ends of justice. Humble Petitioner, Dated: ___________ (TAYYABA SULTANA)
Through: Hamad 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
CERTIFICATE: Certified as per instructions of the client, that this is the first petition on the subject matter. No such petition has earlier been filed before this Hon’ble Court. Advocate
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No. ______________/2001
Tayyaba Sultana
Vs
Govt. of Punjab etc.
AFFIDAVIT of: Tayyaba Sultana daughter of Muhammad Yaseen, caste Qureshi, R/o 325/326 Satellite Town, Bahawalpur.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above petition 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 January 2001 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
In re: C.M. No. _____________/2001 In W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
APPLICATION FOR DISPENSING WITH THE FILING OF CERTIFIED COPIES OF ANNEXURES. =========================================
Respectfully Sheweth:That certified copies of Annexures “A to E” are not available. However, uncertified/photo state copies of the same have been annexed with the petition, which are true copies of original documents. It is, therefore, respectfully prayed that this Hon’ble court may please dispense with the filing of aforesaid copies of documents. PETITIONER Dated: __________ (TAYYABA SULTANA) Through: Hamad 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.
In re: C.M. No. _____________/2001 In W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
DISPENSATION APPLICATION
AFFIDAVIT of: Tayyaba Sultana daughter of Muhammad Yaseen, caste Qureshi, R/o 325/326 Satellite Town, Bahawalpur.
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 _____ day of January 2001 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
INDEX S. No. NAME OF DOCUMENTS
ANNEXES PAGES
1 Urgent Form
__
2 Stamp Paper worth Rs. 500/-
__
3 Writ Petition.
1-5
4 Affidavit
7
5 Copies of N.C.C. Certificates & F.Sc. 6 Copies of Ranking (result). 7 Copy of Prospectus.
A & A/1
9-11
B
13
C,D & E
15-63
8 Dispensation Application.
65
9 Affidavit.
67
10 Application U/s 151 C.P.C.
69-71
11 Affidavit.
73
12 Vakalatnama
75 PETITIONER
Dated: ____________ Through: Hamad 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.
In re: C.M. No. _____________/2001 In W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
Application under section 151 C.P.C. for the grant of Stay Orders.
The applicant respectfully submits as under: 1. That the contents of the main petition may please be treated as integral part of this petition. 2. That the respondents are going to publish the merit lists without giving the benefit of 20 marks to the petitioner. 3. That the benefit of 20 marks is given by statute and through an administrative order, this benefit is can not be revoked. 4. That the matter is very much sensitive and which is directly connected with the future and career of the petitioner. 5. That the balance of convenience lies in favour of the applicant. 6. That the act and conduct of will cause irreparable loss to the petitioner/applicant. 7. That in these circumstances, it is a prima facie arguable case.
It is, therefore, respectfully prayed that the respondents may please be directed to prepare the merit list after giving benefit of 20 marks to petitioner, subject to final decision of the main petition. Any other relief, which this Hon’ble Court deems fit, may please be extended in favour of the petitioner/applicant. Humble Applicant Dated: __________ (TAYYABA SULTANA)
Through: Hamad 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.
In re: C.M. No. _____________/2001 In W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
STAY APPLICATION.
AFFIDAVIT of: Tayyaba Sultana daughter of Muhammad Yaseen, caste Qureshi, R/o 325/326 Satellite Town, Bahawalpur.
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 _____ day of January 2001 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT
W.P. No._____________/2001 Tayyaba Sultana daughter of Muhammad Yaseen, caste Qureshi, R/o 325/326 Satellite Town, Bahawalpur. Petitioner VERSUS 1. Government of Punjab through Secretary Health Division, Punjab Secretariat, Lahore. 2. Health Department through Director General, Punjab Secretariat, Lahore. Respondents
Writ Petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973.
Respectfully Sheweth: 1. That the names and addresses of the parties have correctly been given for the purpose of their summons and citations. 2. That the National Guard Act, 1973 was assented by the Parliament for the purposes of initial Military Training. So many forces were established under this act from the general public. This act was implemented upon the educational institutions. A corps was established in the male institutions, it was called as “National Cadet Corps” and in the female institutions as “Women Guards”.
3. That it was very much clear in the act u/s 29 (c) that the person who will complete the training successfully at the time of admission in any institution the student will be given benefit of 10% of the marks obtained the said examination. This section was further amended in 1975 and concession of 20 marks instead of 10% marks was allowed to a student who has completed the training under this act, at the time of admission in any institution. The real spirit of this act was to create a loyal sense among the youth to defend their country. 4. That the right of this concession is guaranteed by the legislation and till now the act is not abrogated and every institution which is supposed for general education, professional education or advance studies, giving benefit of this legislation to every student/candidate at the time of admission. The petitioner has completed his training in N.C.C. during his studies and certificate in this regard is Annex “A” and the copy of F.Sc. Certificate is Annex “A/1”. 5. That the petitioner submitted his admission form for the admission of professional course of M.B.B.S/B.D.S. and an entry test was held on 22.10.2001 under the supervision and control of respondents. The result of entry test was issued on 4.11.2001 in which the merit ranking of the petitioner is 3858. Copy is annexed as Annex “B”. 6. That the petitioner remained taken aback when it came to their knowledge that 20 marks for the training of N.C.C. were not included, while preparing the merit list. On the other hand in the whole Punjab, for every professional course, as well, at the time of admission 20 marks for N.C.C. training were included for the consideration of merit. The abstract of admission part from the prospects of Medial Colleges, University of Engineering and Technology and B.Z.U. Multan are enclosed herewith as Annexes “C, D & E”. 7. That there must be infirmity for the purpose of admission in whole the Punjab, because the future of thousands of students is
annexed with this practice of authorities. There must not be any type of discrimination and right of every individual shall be safeguarded as required under the constitution through articles 2(A), 4 and 25. 8. That the respondents have prepared the merit ranking without giving the benefit of 20 marks for N.C.C. Training and going to publish the same within days. At this stage, the petitioner are left with no other alternate, efficacious, adequate or speedy remedy except to invoke the constitutional jurisdiction of this Hon’ble Court for the redressal of their grievance. Keeping in view the above-mentioned facts, it is respectfully prayed that the respondents may please be directed to prepare the merit ranking of petitioner after giving benefit of 20 marks for N.C.C. Training. Any other writ, order, direction or relief which this Hon’ble Court deems fit, may please be extended in the favour of petitioner to meet the ends of justice. Humble Petitioner, Dated: ___________ (TAYYABA SULTANA)
Through: Hamad 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
CERTIFICATE: Certified as per instructions of the client, that this is the first petition on the subject matter. No such petition has earlier been filed before this Hon’ble Court. Advocate
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No. ______________/2001
Tayyaba Sultana
Vs
Govt. of Punjab etc.
AFFIDAVIT of: Tayyaba Sultana daughter of Muhammad Yaseen, caste Qureshi, R/o 325/326 Satellite Town, Bahawalpur.
I, the above named deponent do hereby solemnly affirm and declare that the contents of the above petition 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 January 2001 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
In re: C.M. No. _____________/2001 In W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
APPLICATION FOR DISPENSING WITH THE FILING OF CERTIFIED COPIES OF ANNEXURES. =========================================
Respectfully Sheweth:That certified copies of Annexures “A to E” are not available. However, uncertified/photo state copies of the same have been annexed with the petition, which are true copies of original documents. It is, therefore, respectfully prayed that this Hon’ble court may please dispense with the filing of aforesaid copies of documents. PETITIONER Dated: __________ (TAYYABA SULTANA) Through: Hamad 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.
In re: C.M. No. _____________/2001 In W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
DISPENSATION APPLICATION
AFFIDAVIT of: Tayyaba Sultana daughter of Muhammad Yaseen, caste Qureshi, R/o 325/326 Satellite Town, Bahawalpur.
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 _____ day of January 2001 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH, MULTAN.
W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
INDEX S. No. NAME OF DOCUMENTS
ANNEXES PAGES
1 Urgent Form
__
2 Stamp Paper worth Rs. 500/-
__
3 Writ Petition.
1-5
4 Affidavit
7
5 Copies of N.C.C. Certificates & F.Sc. 6 Copies of Ranking (result). 7 Copy of Prospectus.
A & A/1
9-11
B
13
C,D & E
15-63
8 Dispensation Application.
65
9 Affidavit.
67
10 Application U/s 151 C.P.C.
69-71
11 Affidavit.
73
12 Vakalatnama
75 PETITIONER
Dated: ____________ Through: Hamad 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.
In re: C.M. No. _____________/2001 In W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
Application under section 151 C.P.C. for the grant of Stay Orders.
The applicant respectfully submits as under: 1. That the contents of the main petition may please be treated as integral part of this petition. 2. That the respondents are going to publish the merit lists without giving the benefit of 20 marks to the petitioner. 3. That the benefit of 20 marks is given by statute and through an administrative order, this benefit is can not be revoked. 4. That the matter is very much sensitive and which is directly connected with the future and career of the petitioner. 5. That the balance of convenience lies in favour of the applicant. 6. That the act and conduct of will cause irreparable loss to the petitioner/applicant. 7. That in these circumstances, it is a prima facie arguable case.
It is, therefore, respectfully prayed that the respondents may please be directed to prepare the merit list after giving benefit of 20 marks to petitioner, subject to final decision of the main petition. Any other relief, which this Hon’ble Court deems fit, may please be extended in favour of the petitioner/applicant. Humble Applicant Dated: __________ (TAYYABA SULTANA)
Through: Hamad 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.
In re: C.M. No. _____________/2001 In W.P. No.____________/2001 Tayyaba Sultana
Vs
Govt. of Punjab etc.
STAY APPLICATION.
AFFIDAVIT of: Tayyaba Sultana daughter of Muhammad Yaseen, caste Qureshi, R/o 325/326 Satellite Town, Bahawalpur.
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 _____ day of January 2001 that the contents of this affidavit are true & correct to the best of my knowledge and belief. DEPONENT
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