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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