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Text of petition


Grounds:
(i) Breach of trusts and Exploitation are forbidden by the Constitution; See Article 1-8; 10-14, 18, 24-25, 40, 22, 232 and obstructs justice and subverts the Constitution

(ii) Not acknowledging or replying to letters is illegal per Section 24A General Clauses Act and the Constitution Art. 2A,3 (See p., 578, Vol. 6, Muarriffe Quran); it also has promoted bad governance and is most detrimental to the welfare and future and credibility of Pakistan;

(iii) Quota Systems, are discriminatory, dehumanizing and promote corruption and disrespect for law and abhorrence of merit, these have been held to be illegal in Pakistan by the High Court and the SCP; such Quotas stir dissatisfaction, encourage networking and networking and abuse of merit .. these work against pursuit of excellence. QUOTAs for JUDGES violate in letter and essence and spirit, the Beijing Statement of the Principles of the Independence of the Judiciary; The Latimer House Guidelines for the Commonwealth, The Bangalore Principals of Judicial; Conduct and are not compatible with the teachings of the Holy Prophet and exception to these offends the Oath under Art 194, 178 of the Constitution.

(iv) Granting extra marks to Farah because she is daughter of a Judge is disgraceful, is invidious, capricious, against just expectations of Rajpoot; invidious, it demeans Islam, goes against the principles of Ethics, violates values in Code of Judicial Conduct; Professional Ethics of the Legal Profession and principles of international law including the Shaira; it goes against the grain of independence of Judiciary and supremacy of law and in Pakistan it has encouraged Law off Rulers rather than Rule of Law; and we have become objects of ridicule and are now the laughing stock of the world as large.

(v) The Affixation of Rs. 3 Revenue stamps on Each Page is, unreasonable, wasteful, a corrupt practice with no redeeming feature, specious, it operates against Access to Justice; is discriminatory and it is illicit for the State for it is providing no service in return. It has been declared to be unconstitutional by the Lahore High Court in 2004. It amounts to Unjust Enrichment and sounds in chicanery rather than Chancery. It encourages over charging by lawyers' clerks and thus it obstructs due course of justice. It demeans public confidence in our institutions.

(vi) Pakistan is sliding downhill and going backwards as a result of the above-mentioned.
Therefore:

It is humbly prayed that the Court read this Petition although truth is bitter and its realization is better; and please liberally construe the contents of this Writ engrossed in an Emergency situation.

a) The Court kindly declare the rights and responsibilities of the Parties and issue Preliminary and Perpetual Declaratory Judgements (See Section 42 etc. of Specific Relief Act) (Declarations) and grant appropriate Protective Orders and Injunctive Relief by issuing TRO, Preliminary and Permanent injunctions; Petitioner and those similarly situated are suffering irreparable harm and all equities eight in their favour.

b) The Court Order that Respondent Miss Farah Dogar's marks to restored/reduced to their original state, number and condition and order her to vacate her seat a the Medical College; and the State respondents be ordered to register FIR against hose corrupt individuals including Respondents who aided and abetted Farah in this Holy Grail for discrimination, disgrace and ongoing, energies Exploitation and Breach of Trusts (Art 2A, Amanats being khayanatted).

c) The Court forbid Mister Babar Awan to stop using the title “DOCTOR” and to apologize to the public at large; and the State be directed to ensure that all his Unjust Enrichment since he started using Doctoral Title be taxed and restored to National Treasury. The Government of Pakistan be directed to discover and recover any nonpayment of taxes by means of discovery and Polygraph test which are creditable and available in Pakistan.

d) Affixing of Rs. 3 Revenue Stamps be declared as Unconstitutional, the court also has pendent, ancillary, corollary, incidental jurisdiction to that effect. A Preliminary Injunction enter forthwith re Rajpoot and his lawyers Geoffrey and Khitran; Cost of Revenue stamps on this Petition be refunded immediately;

e) All QUOTAS in favour of Judges and Government/State employees/officials be declared to be Unconstitutional; these be ordered discontinued and forbidden for all times, purposes and abolished thoroughly. This will send good signals and restore our credibility, that we are willing to learn from the past and mend our ways and are back on the track of The Right Path, Sarate Mustasqueem.

f) Other, different and additional relief be granted and INDEMNITY and PUNITIVE costs be awarded due to on going misconduct and disgraceful machinations of the Respondents.

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Members of the academic and legal fraternity are requested to peruse the legal petition lodged against awarding additional marks to Ms Farah Dogar, the decision of the Islamabad High Court and both the articles of Ansar Abbasi. Their valued opinions will be published in The News and Daily Jang, broadcast on Geo TV, as well as printed on the websites of The News and Daily Jang.

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