Thursday, October 4, 2012

Urgent Hearing in HC


IN THE HIGH COURT OF SINDH AT KARACHI
(Constitutional Jurisdiction)

Constitution Petition # -D-                /2012


MUHAMMAD SALEEM             …………     PETITIONER

VERSUS

GOVERNMENT OF SINDH & others  ….. RESPONDENTS


APPLICATION UNDER RULE IX CHAPTER III-A
VOLUME –V OF THE SINDH HIGH COURT RULES
                   
                   On behalf of the petitioner, it is respectfully submitted that this Hon’ble Court may be pleased to treat this matter as urgent motion and hear the main petition on 0  .10.2012, as if immediate action is not taken, the respondent #. 3  will do more do anything which may be detrimental to the interest/rights of the petitioner and the respondent No. 3 transfers frequently the petitioner to many towns i.e. district Badin which causes the life of the petitioner miserable and disturbance to the petitioner due to that reason the petitioner will not perform his duty properly till disposal of this Constitution Petition. 
          The prayer is made most earnestly in the greater interest of Justice and equity.

Karachi.
Dated:   -10-2012.                          ADVOCVATE FOR THE PETITIONER




AFFIDAVIT
          I, MUHAMMAD SALEEM S/o Muhammad Hanif, Muslim, adult,  Presently posted as Secretary Union Council No. 7 Sharifabad  Liaqatabad  Town,, Karachi do hereby state on oath as under:-

1.                 That I am Petitioner in and deponent of this affidavit, as such am fully conversant with the facts of the matter deposed herein:

2.                 That the accompanying APPLICATION UNDER RULE IX, CHAPTER III-A, VOLUME –V OF THE SINDH HIGH COURT RULES has been drafted and filed under my express instructions and contents whereof are true and correct and the same along with contents of the memo of plaint may please be treated as part of this affidavit for the sake of brevity.

3.                 That I say that I have a good prima facie case, and balance of convenience lies in my favor and until and unless accompanying application is granted as prayed I will be seriously prejudiced and shall suffer irreparable loss.

4.                 That I say that whatever stated above is true and correct to the best of my knowledge and belief.
Karachi
Dated:     -10-2012.                                                       
Deponent ___________
CNIC #. ______________
Mobile No. ______________
  
Identified by me


Advocate

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