IN THE COURT OF MALIK AHMAD BAKHSH BHAPA, JUDGE

BANKING COURT NO-I, MULTAN.

In re:
Wazeer Ahmad Vs. Small Business Finance
Corporation Vehari etc.

Suit for Declaration

Application for Grant of Permission

to defend the titled Suit.

Respectfully Sheweth:-

1. That the above titled suit is pending adjudication before this

Hon’ble Court and is fixed for today.
2. That the summons issued by this Hon’ble Court were received by
the Respondents on 7.7.99, as such application for leave to defend
is well within time.
3. That the plaintiff has filed the suit without any cogent and
convincing reasons, moreover as filed the titled suit only with the
object to usurp the loan amount obtained from the Respondents. As
such the suit is based on malafide and ulterior motive because
there are Rs. /- outstanding against the plaintiff till the
month of , 1999.
4. That the valuable rights of the Respondents are involved in the
matter in hand and in case, this application is declined, the
Respondents would undoubtedly confront with more hardships and
inconvenience besides legal complications would also arise and the
dictum of Hon’ble Superior Courts that “every person should not
be condemned unheard” would be violated.
5. That balance of convenience too leans in favour of the
Respondents, because Small Business Finance Corporation has a
good prima-facie and arguable case and there are bright chances of
success. An affidavit is attached.
It is therefore most respectfully prayed that this
application may kindly be accepted and the Respondent
may graciously be permitted to defend the suit on
Respondents’ behalf.

Humble Respondent.

Through: -
Through:-
SAEED HASSAN HASHMI MANAGER (SBFC)
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
IN THE COURT OF MALIK AHMAD BAKHSH BHAPA, JUDGE
BANKING COURT NO-I, MULTAN.

In re:
Wazeer Ahmad Vs. Small Business Finance
Corporation Vehari etc.

Suit for Declaration

Application for Grant of Permission

to defend the titled Suit.

AFFIDAVIT of: -
Mushtaq Sarwar District Manager Small Business
Finance Corporation, Vehari.

I, the above named deponent do hereby solemnly

affirm and declare that the contents of the
accompanying application for leave to defend the
suit are true and correct to the best of my
knowledge and belief.

Deponent.

Verification: -
Verified on oath at Multan, this_____
day of July, 1999 that the contents of this affidavit
are true to the best of my knowledge and belief.

Deponent
IN THE COURT OF MALIK AHMAD BAKHSH BHAPA, JUDGE
BANKING COURT NO-I, MULTAN.

In re:
Wazeer Ahmad Vs. Small Business Finance
Corporation Vehari etc.

Suit for Declaration

Memo of Appearance

Respectfully Sheweth:-
1. That the above titled suit is pending adjudication before this
Hon’ble Court and is fixed for today.

2. That the above titled suit of the undersigned has been

engaged as a counsel to defend the suit. The power of
Attorney still has not been received; the same will be
produced as soon as received.

Under the above circumstances, the memo of appearance

may kindly be accepted.

Through:-

SAEED HASSAN HASHMI

Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
Legal Advisor S.B.F.C.
 IN THE COURT OF CHAUDHARY MUHAMMAD KHALIL,
JUDGE BANKING COURT NO-II, MULTAN.

In re:
M/s Union Straw Paper Industries (Pvt) Limited and another.
Versus
National Bank of Pakistan and others.

Suit for Recovery of

Rs. 25062073/-as damages.
_____________________________

Application seeking Permission for leave to

defend the Suit on behalf of defendant No. 1 & 2

Respectfully Sheweth:-
1. That the above titled suit is pending adjudication before this
Hon’ble Court and is fixed for 21.09.99.

2. That the summons issued by this Hon’ble Court were received by

the defendants No. 1 & 2 on 11.08.99, as such application for leave
to defend is being filed within the stipulated period.

3. That the brief facts giving rise to the instant application are that the
National Bank of Pakistan brought a suit for recovery of loan of
Rs. 9527954/- against the M/s Union Straw Papers (Pvt) Limited
through Ch. Muhammad Saleem, the Managing Director and
Ch. Ali Ahmad Tariq, the Director. The above-referred suit was
brought before the Court on 08.10.97 and the suit is pending
adjudication and is fixed for 21.09.99 for recording of ex-parte
evidence of the Plaintiff Bank.

4. That M/s Union Straw Paper Industries (defendants in that suit)

 made an application for leave to defend.

5. That admittedly M/s Union Straw Paper Industries were chronic

defaulters of the loan therefore, while keeping in view their
conduct, their application for leave to defend was dismissed for the
reasons mentioned in the order dated 02.09.98.

6. That thereafter M/s Union Straw Paper Industries on account of

their malafide and ulterior motives, obviously with the object to
save their skin from the recovery process of loan, brought the titled
suit for the recovery of damages against the defendant Bank
(defendant No. 1 & 2) alleging therein that the process of
rescheduling was delayed and that the sanction order of
rescheduling was delayed under the greed of commission by the
Bank Authorities which caused serious loss in business and project
of the Plaintiffs. Moreover, the Plaintiff has also sustained mental
shock causing the loss of his health on account of damage of his
business and project, entitling him to recover the damages through
the titled suit.

7. That the Plaintiffs filed an application for leave to defend in the

recovery suit of the present defendant No. 1 & 2 on 26.03.98
which is completely silent regarding any loss or damage of their
business, project and health. As such the present suit is based on
malafide and ulterior motive and is afterthought and no actual
damage was sustained to the Plaintiffs.

8. That the excuse and pretext extended by the Plaintiff is concocted

story with a view to obviate recovery of loan under threat through
the suit for damages which is quiet unjust, unfair and is clear cut
departure from “Agreement” arrived at by the parties to the case
with regard to the loan referred to above.

9. That the suit is not maintainable in the eye of law and that the
Plaintiffs have no cause of action or locus standi for bringing the
 instant suit.

10.That the suit is result of malafide and ulterior motives. Moreover,

the Plaintiffs are estoped by their words and conduct to bring the
titled suit.

11.That the Plaintiffs have filed the titled suit without any cogent and
convincing reasons. They intend to ususrp the loan amount
obtained by them. The valuable rights of the applicant are involved
in the matter which require necessary probe for the purpose of
determination their rights in the matter so as to bring on record the
relevant agreement, papers, factual position and description of loan
in a shape of evidence. It shall only be possible in case if the
applicants are given an opportunity of being heard. The titled suit
is also badly time barred.
Under the above circumstances and submissions, it
is most respectfully prayed that this application
may kindly be allowed and that the applicants/
defendants No. 1 & 2 may kindly be afforded an
opportunity to defend the titled suit, in the supreme
interest of justice.
An affidavit is attached.
Humble applicants

1. Defendant No. 1
Through: - Zonal Chief

2. Defendant No. 2
Through: - Manager
National Bank of Pakistan
Dera Adda Branch, Multan.
Through:-
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
 IN THE COURT OF CHAUDHARY MUHAMMAD KHALIL,
JUDGE BANKING COURT NO-II, MULTAN.

In re:
M/s Union Straw Paper Industries (Pvt) Limited and another.
Versus
National Bank of Pakistan and others.

Suit for Recovery of

Rs. 25062073/-as damages.
_____________________________

Application seeking Permission for leave to

defend the Suit on behalf of defendant No. 1 & 2

AFFIDAVIT

I, the deponent, Rao Zulfiqar Ali Khan, being the

Manager National Bank of Pakistan, Dera Adda
Branch, Multan do hereby solemnly affirm and
declare that the contents of the accompanying
application for leave to defend the suit are true and
correct to the best of my knowledge and belief.

Deponent

Verification: -
Verified on oath at Multan, this_____
day of August, 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.

IN RE:
W.P. No.4884/1999

Sahahid Javaid Versus Small Business Finance

Corporation Vehari, etc.

PARAWISE COMMENTS ON
BEHALF OF THE RESPONDENTS.

Respectfully Sheweth: -
1. That Para No. 1 of the Writ Petition is not known to the replying
Respondent.

2. That Para No. 2 of the Writ Petition is correct.

3. That Para No. 3 of the Writ Petition is correct to the extent that
the Petitioner obtained Rs. 100,000/- from the Respondent but
loan amount was disbursed in 1994, rest of the Para is incorrect.
The Petitioner himself winded up the said business without prior
permission of Respondents and has misappropriated the loan
amount.

4. That Para No. 4 of the Writ Petition is incorrect. The Petitioner

himself illegally winded up the business. Moreover, he did not
pay back the installments in time. As such the Petitioner has
violated the financial assistance agreement (on mark-up basis)
and there are Rs. 50,232/- outstanding against the Petitioner till
the month of June, 1999. Copy of the statement of account is
Annexure “A”.
5. That Para No. 5 of the Writ Petition is correct to the extent the
loan was given to YOUTH unemployed persons for their benefit
and the rest of the Para is incorrect because the contract signed
by the parties is made with his own free will and without any
outside interference and is binding upon the parties and at the
time of contract/agreement, the Petitioner himself agreed to pay
installments with mark-up. Copy of the Agreement is
Annexure “B”.

6. That about Para No. 6 of the Writ Petition, it is humbly

submitted that on the Judgment of the Federal Shariat Court,
appeal is pending before the Hon’ble Supreme Court of
Pakistan, as such under Article 203-D (2) of the Constitution of
Islamic Republic of Pakistan, this Writ Petition merits its
dismissal on the solitary scope. Even otherwise the matter in
dispute is contractual in nature as the same is mandated out of an
agreement executed between the parties on their own free will
and without any outside interference. As such the jurisdiction of
this Hon’ble Court under Article 199 of the Constitution would
not be attracted. However, it is in the jurisdiction of Hon’ble
Federal Shariat Court under the Constitution of Islamic Republic
of Pakistan to decide whether any law is repugnant against the
injunction of Islam and how it can be presumed that introduction
of Shariat has amended the Constitution of Pakistan.

7. That about Para No. 7 of the Petition, it is submitted that

Financial assistance advanced to the Petitioner was without any
security, in shape of mortgage of any property, but simply on the
basis of personal guarantee and according to the Small Business
Finance Corporation Act 1972, the only remedy available to the
Respondent is to recover the outstanding amount of financial
assistance/loan as arrears of land revenue.

8. That Para No. 8 of the Writ Petition is incorrect and is not

admitted as such. Details are given in the foregoing paragraph.
9. That Para No. 9 of the Writ Petition is incorrect and is not
admitted as such. Moreover, the Petitioner did not pay back the
installments in time. As such he himself violated the contract
signed between the parties and is liable to pay the loan amount
in lump sum.

10.That about Para No. 10 of the Writ Petition, it is submitted that

the Petitioner is not entitled to invoke the Constitutional
Jurisdiction of this Hon’ble Court under Article 199 of the
Islamic Republic of Pakistan, the Petitioner has remedy to
invoke the Jurisdiction of Banking Court.

Prayer: -
Prayer clause of the Petitioner under reply is
unwarranted by law and facts of the case, as such is
absolutely incorrect, under the above circumstances and
terms, it is most respectfully prayed that this Petition may
very graciously be dismissed with costs.

Dated: __________
Humble Respondent

Through: -
Manager,
Small Business Finance
Corporation, Vehari.
Through: -

Saeed Hassan Hashmi

Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
Legal Advisor S.B.F.C.
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

IN RE:
W.P. No.4884/1999

Sahahid Javaid Versus Small Business Finance

Corporation Vehari, etc.

Petition under section 151 of C.P.C

for dispensing with the certified
copies of Annexures.

Respectfully Sheweth: -
1. That the Respondent is filing the photo state copies of the
Annexures “A & B” with the Writ Petition as the certified copies
of the same are not readily available with the Respondent. The
same shall be submitted as and when this August Court directs.

2. It is, therefore, most respectfully prayed that the Petitioner may

kindly be allowed to file photo state copies of the Annexures
with the Petition.

Respondent

Through: -
Manager,
Small Business Finance
Corporation, Vehari.
Through:-

Saeed Hassan Hashmi

Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
Legal Advisor S.B.F.C.
 IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

IN RE:
W.P. No.4884/1999

Sahahid Javaid Versus Small Business Finance

Corporation Vehari, etc.

AFFIDAVIT of:-
Manager Small Business Finance Corporation,
Vehari.

I, the above named deponent do hereby solemnly

affirm and declare that the contents of the above
Writ Petition are true and correct to the best of my
knowledge and belief and nothing has been kept
concealed thereto.

DEPONENT

Manager,
Small Business Finance
Corporation, Vehari.
Verification: -
Verified on oath at Multan, this_____
day of September, 1999 that the contents of this
affidavit are true to the best of my knowledge and
belief.

DEPONENT

Manager,
Small Business Finance
Corporation, Vehari.
IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN.

Sui Northern Gas Pipelines Limited, Gas House, 21-Kashmir Road,

Lahore through General Manager (Legal) Lahore, having its
Distribution Office at 7-A Piran Ghaib Road, Multan.
PLAINTIFF

VERSUS

Abdul Hameed S/o Haji Abdul Aziz, Nan Farosh, Shop No. 1485/8,
Chowk Lakkar Mandi, Multan.
DEFENDANT

SUIT FOR RECOVERY OF RS. 44,341/-

Respectfully Sheweth: -
1. That the Plaintiff is a Public Limited Company duly incorporated
under the Companies Act, 1913 (Now Companies Ordinance
1984) having its registered office at Gas House, 21-Kashmir
Road Lahore and Regional office situated at Piran Ghaib Road,
Multan.

2. That Mr. Shahid Hamid, who is General Manager (Legal) of the

Plaintiff Company and has signed and verified this plaint, is duly
competent and authorised to do so through General Power of
Attorney, executed in his favour by the Board of Directors of the
Plaintiff Company. He is fully conversant with the facts of this
 suit and is competent to institute this plaint. Copy of power of
attorney is annexed with the plaint.
3. That the defendant entered into an agreement with the Plaintiff
Company for the supply of Gas to its premises namely Abdul
Hameed S/o Haji Abdul Aziz, Nan Farosh, Shop No. 1485/8,
Chowk Lakkar Mandi, Multan.
4. That the supply of the Gas was commissioned on 22.3.96 to the
defendant’s premises vide Consumer No. 11240029250.
5. That the defendant failed to make the payment of monthly gas
bills with effect from April 1998 issued to him and as such an
amount of Rs. 73,341/- was outstanding and payable by the
defendant to the Plaintiff Company on 28.4.98 when the gas
supply was disconnected due to non-payment of outstanding gas
bills. The defendant made the payment of Rs. 24,000/- on
different occasions and the same has been duly deducted from the
outstanding amount, detail of which has been given in the detail
of outstanding arrears, annexed with the plaint.
6. That the defendant had also deposited the amount of security of
Rs. 5,000/-, which has been adjusted against the outstanding
amount of Rs. 73,341/- and the balance of Rs. 44,341/- is still
outstanding and payable by the defendant.

7. That a number of times, the defendant was reminded verbally,

through letters and through notices to pay the outstanding amount
but he is adamant. Hence, this suit.

8. That the cause of action in favour of the Plaintiff and against the
defendant accrued at the time of commencement of original
agreement for the supply of gas when the gas was commissioned
and thereafter when the supply of gas was disconnected on
28.4.98 and was advised to pay the outstanding gas bill but the
defendant failed to clear the same and finally a week ago when
the defendant refused to make payment of the total outstanding
amount of Rs. 44,341/-.
9. That the cause of action arose within the limits of Tehsil &
District Multan as the defendant resides in Multan; therefore, this
Court has jurisdiction to adjudicate upon this suit.

10. That the value of the suit for the purpose of Court fee and
jurisdiction is fixed as Rs. 53,440/- for which, Court fee of Rs.
4010/- is fixed under this law.

Under the above circumstances, it is respectfully prayed that a

decree for Rs. 53,440/- along with interest/mark-up, as stipulated in
Clause 15 (i) of the Gas Supply Contract, from the date of default till
the realisation of decretal amount, may kindly be passed in favour of
the Plaintiff and against the defendant with costs.
Any other relief, of which, the Plaintiff is found entitled, may
also be granted, in the supreme interest of justice.

HUMBLE PLAINTIFF

Through: -
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.

Verification: -
Verified on oath at Multan this _____
day of ________ 2001 that para No. 1
to 6 are correct to the best of my
knowledge and remaining paras are
true to the best of my information.

PLAINTIFF
IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN.

Sui Northern Gas Pipelines Limited, Gas House, 21-Kashmir Road,

Lahore through General Manager (Legal) Lahore, having its
Distribution Office at 7-A Piran Ghaib Road, Multan.
PLAINTIFF

VERSUS

Muhammad Rafiq S/o Muhammad Ishaque, R/o H. No. 1263

Mohallah Bagh Vehra, outside Dehli-gate, Multan.
DEFENDANT

SUIT FOR RECOVERY OF RS. 104,232.76

Respectfully Sheweth: -
1. That the Plaintiff is a Public Limited Company duly incorporated
under the Companies Act, 1913 (Now Companies Ordinance
1984) having its registered office at Gas House, 21-Kashmir
Road Lahore and Regional office situated at Piran Ghaib Road,
Multan.

2. That Mr. Shahid Hamid, who is General Manager (Legal) of the

Plaintiff Company and has signed and verified this plaint, is duly
competent and authorised to do so through General Power of
Attorney, executed in his favour by the Board of Directors of the
 Plaintiff Company. He is fully conversant with the facts of this
suit and is competent to institute this plaint.

3. That the defendant entered into an agreement with the Plaintiff

Company for the supply of Gas to its premises namely
Muhammad Rafiq S/o Muhammad Ishaque, R/o H. No. 1263
Mohallah Bagh Vehra, outside Dehli-gate, Multan.

4. That the supply of the Gas was commissioned on 27-09-94 to the

defendant’s premises vide Consumer No. 11210026407.

5. That the defendant failed to make the payment of monthly gas

bills with effect from July 1996 issued to him and as such an
amount of Rs. 108,232.76 was outstanding and payable by the
defendant to the Plaintiff Company on 29.07.97 when the gas
supply was disconnected due to non-payment of outstanding gas
bill.

6. That the defendant had deposited the amount of security of Rs.

4,000/- which has been adjusted against the outstanding amount
of Rs. 108,232.76, and the balance of Rs. 104,232.76 is still
outstanding and payable by the defendant.

7. That a number of times, the defendant was reminded verbally,

through letters and through notices to pay the outstanding amount
but he is adamant. Hence, this suit.

8. That the cause of action in favour of the Plaintiff and against the
defendant accrued at the time of commencement of original
agreement for the supply of gas when the gas was commissioned
and thereafter when the supply of gas was disconnected on
29.07.97 and was advised to pay the outstanding gas bill but the
defendant failed to clear the same and finally a week ago when
the defendant refused to make payment of the outstanding
amount of Rs. 104,232.76.
9. That the cause of action arose within the limits of Tehsil &
District Multan as the defendant resides in Multan; therefore, this
Court has jurisdiction to adjudicate upon this suit.

10.That the value of the suit for the purpose of Court fee and
jurisdiction is fixed as Rs. 104,232.76 for which Court fee of
Rs.__________ has been paid according to law.

Under the above circumstances, it is respectfully prayed

that a decree for Rs. 104,232.76 along with interest/mark-up,
as stipulated in Clause 15 (i) of the Gas Supply Contract, from
the date of default till the realisation of decretal amount, may
kindly be passed in favour of the Plaintiff and against the
defendant with costs.
Any other relief, of which, the Plaintiff is found
entitled, may also be granted, in the supreme interest of
justice.

HUMBLE PLAINTIFF

Through: -
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.

Verification: -
Verified on oath at Multan this _____
day of ________ 2000 that para No. 1
to 6 are correct to the best of my
knowledge and remaining paras are
true to the best of my information.
 PLAINTIFF

IN THE COURT OF SPECIAL JUDGE FOR THE SUPPRESSION

OF TERRORIST ACTIVITIES (SPECIAL COURTS) ACT, 1975,
MULTAN DIVISION, MULTAN.

Ghulam Mustafa son of Karam Khan, Caste Kharal R/o Mauza

Kharal Khakhani, Tehsil Mailsi, Distrit Vehari.
Accused/Petitioner
Versus
The State
Respondent

POST ARREST BAIL APPLICATION

UNDER SECTION 497 CR.P.C. IN
CASE F.I.R. NO. 90/97 DATED 16.4.97,
OFFENCE UNDER SECTIONS 302/324,
148/149/109 P.P.C. REGISTERED AT
POLICE STATION CITY MAILSI,
DISTRICT VEHARI.

NOTE: - This is the first bail application on behalf of the

Petitioner/accused.

Respctfully Sheweth: -
1. That brief facts giving rise to the instant bail Petition are that
Abdul Razzaq, lodged a report in Police Station City Mailsi on
16.4.1997 Under Sections 302/324/148/149/109 P.P.C wherein he
 alleged that Naveed, Mukhtar, Adil, Muhammad Muneer and
Muhammad Hussain along with three unknown persons fired
upon Mushtaq Ahmad as well as at the Jeep carrying other
victims which resulted in the death of Mushtaq Ahmad, Noor
Muhammad and Muhammad Arif. Hence, this case against the
accused/Petitioner.

2. That the accused/Petitioner was arrested on 4.7.97 and since then

he is behind the bar.

3. That the accused/Petitioner is innocent and prays for his bail to

this Hon’ble Court, inter alia on the following

GROUNDS

(i) That the instant case against the accused/Petitioner is

absolutely false, result of malafide ulterior motive and
that of enmity.

(ii) That identification parade was delayed by 25 days

deliberately for the purpose to get identification of the
accused before lodging him in the jail and also prior to
his date arrest shown in the papers/record, even then
complainant and other so called eye witnesses of the
occurrence, failed to identify the accused/petitioner in
the jail premises whereas the evidence of other
witnesses statedly identifying the accused/petitioner in
the jail premises during the so-called identification
parade carries no weight in the eyes of law with regard
to the factum of identification of the accused, therefore
it is absolutely padding in the record and is fabrication
of evidence.

(iii) That the statement of one of the co-accused connecting

the accused/petitioner in the referred particular
circumstance carries no weight under the law of
 evidence. Whereas in the case in hand, there is no
evidence on record against the accused/petitioner for
connecting him with the commission of crime and that
reliance on the solitary statement of co-accused is
highly insufficient because of lacking of the principle
and criteria of “quality and quantity” in the evidence in
this matter.

(iv) That significant aspect of the case is that the

accused/petitioner is not named in the F.I.R. and has not
been identified as well. He was also unknown to the
eye-witnesses of the occurrence who denied his
identification at the time of occurrence and during the
course of identification parade. This particular
circumstance requires further enquiry into the guilt of
the accused/petitioner, which entitles him to the
concession of bail under section 497-sub section (2) of
the Cr.P.C.

(v) That the accused/petitioner also prays his bail on

statutory ground as more than two years have passed
since his confinement and arrest as well.

(vi) That the case of the accused/petitioner is at par with the

case of his co-accused namely Muhammad Isamil who
has been granted the concession of bail vide order dated
21.7.98, passed by the Hon’ble High Court. Moreover,
nature of role ascribed to the said accused is also
identical in its nature to that of the role attributed to the
present accused/petitioner. As such in pursuance to the
rule of consistency, the petitioner is also entitled for the
grant of bail.

(vii) That the accused/petitioner is previously non-convict

and is law-abiding citizen of Pakistan.
 (viii) That there is no apprehension on the part of the
accused/petitioner to tamper with the prosecution
evidence.
(ix) That the Petitioner is ready to furnish a sound surety
bond to the entire satisfaction of this Hon’ble Court.

PRAYER: -
In the light of the above cricumstances, it is most
respectfully prayed that this petition may kindly be accepted
and the accused/petitioner may kindly be enlarged on bail, in
the supreme interest of justice.

Humble Petitioner

Through:-

1. Saeed Hassan Hashmi

Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.

2. Ashfaq Ahmad Khan,

Advocate High Court,
261-District Courts, Multan.
To,
The Director Law,
A.D.B.P.,
Head Office I-Faisal Avenue,
Islamabad.

Subject: - Enlistment as Panel Advocate for A.D.B.P. Vehari & Multan.

Dear Sir,
With reference to your letter No. LD (lit) 4 (43)/99/821 dated
2.12.99, it is humbly submitted that I have been practicing as an advocate
of High Court as well as Lower Courts since 1994. I have sufficient
experience regarding Banking matters and High Court cases. I ensure that
I would conduct the court cases on behalf of A.D.B.P. very diligently and
with the best of my efforts, it is therefore, most respectfully requested that
the name of undersigned may kindly be included on the Panel of
Advocates of A.D.B.P. Vehari & Multan by relaxing the rules and by also
treating the case of undersigned as a special case.
I shall be highly obliged.

Yours sincerely,

Dated: 24.02.2000
SAEED HASSAN HASHMI,
Advocate High Court,
40-Aziz Block, District Courts,
Multan.
Ph # 061-521253, 0300-639296
Vehari: 0693-696196
To,
The Chief Engineer,
PARCO (Mehmood Kot)
District Muzaffargarh.

Subject: - Application for the post of Technologist/Boiler Foreman.

Respected Sir,
I beg leave to state that I have come to know through some reliable
sources that some posts of Technologist/Boiler Foreman are lying vacant
under your kind control. I offer my services for one of them. My complete
Bio-data is as under: -

1. Name: IQBAL HUSSAIN

2. Father’s Name: FAIZ BUKHSH
3. Date of birth: 7.4.69
4. Qualification: Three years Diploma of Associate
Engineer in Chemical Technology.
5. Experience: (i) One year in Saigal Margarine as a
Process Operator.
(ii) Three years and eight months in
Bela Chemical Industries as a
Process/Control Room operator.
(iii) Then I joined the R.D.C. as a Sub-
Engineer. Though this organization
I got the six month Training in
Pakistan Steel Karachi.
(iv) Then I got one years experience in
Peoples Republic of China as a
Boiler Operator.
 (v) I have passed the First/Second
Class Boiler attendant in Karachi.

Still I am working in Sandak Project as a Sub-Engineer.

Contact Address: Iqbal Hussain C/o Malik Riaz Hussain
Seat No. 50 Aziz Block District Courts
Multan.
Permanent Address: Mouza Mochi Panoohan, Tehsil Jalalpur
Pirwala District Multan.

I shall be very thankful to you and if you kindly give me a

chance I shall work to the entire satisfaction of my superiors.
Thanks

Yours Faithfully,

Dated: ________
Iqbal Hussain