IN THE COURT OF MIAN MUHAMMAD RIAZ KHURRAM,

CIVIL JUDGE, MULTAN.

Syed Mahmood-ul-Hassan VS. Mahboob Alam etc.

Petition U/s 3 & 4 of the Contempt of Court Act.

WRITTEN REPLY

Respectfully Sheweth: -

PRELIMINARY OBJECTIONS: -

1. That the petition is not legally maintainable and is liable to be

dismissed as no lis is pending before this court.

2. That the petition is not legally maintainable and is liable to be

dismissed as the respondents were not party in the main suit.

3. That the necessary ingredients in respect of Sec-3 & 4 of

Contempt of Court Act are not present, so the petition is not
maintainable and liable to be dismissed.

4. That the petitioner along-with others has preferred an appeal

against the order dated 26.9.2002; and is estopped by their
words and conduct to file this petition.

5. That this petition as per claim of petitioner is not legally

maintainable and is liable to be dismissed.

ON MERITS: -

1. That para No. 1 of this petition is correct upto this extent only
that the suit was filed by the petitioner with Qaswar Abbas
 and Aftab Ahmad. This Hon’ble Court was pleased to
summon the defendants; and written statement was filed on
their behalf. On 26.9.02, this Hon’ble Court recorded the
statement of the counsel for defendants; and was pleased to
pass an order on the same day. This order is very much part &
parcel of that file. Remaining para is incorrect. The order
dated 26.9.02 is mis-quoted and mis-stated in this para, which
amounts to contempt of court as well.

2. That the contents of para No. 2 are correct upto the extent that
an application for temporary injunction was filed along-with
the main suit; and the petitioner was not a contestant on the
target date i.e. 31.8.02, but neither any order was suspended
by this Hon’ble Court nor the nomination papers were
accepted on the direction of this Hon’ble Court. The
remaining para is not correct is totally self-explanatory.

3. That the contents of para No. 3 are correct upto the extent of
particulars of respondent No. 1, the remaining para is self-
explanatory. After the dismissal of the suit from Hon’ble
Court, the fate of the petitioners and others was totally
dependant upon the elected body of P.C.G.A.

4. That the contents of para No. 4 are correct upto the extent of
engagement of counsel, the remaining para is self-
explanatory.

5. That the contents of para No. 5 are incorrect. The respondents

in this petition were not a party in the main suit. The
respondents neither violated nor disobeyed any order of this
Hon’ble Court.

6. That the contents of para No. 6 are incorrect. The respondents

being the law-abiding citizens even could not think in such a
way which may amounts to contempt of court.
 It is therefore, respectfully prayed that the
petition in hand has no force and is liable to be
dismissed with costs.

Any other relief, which this Hon’ble Court

deems fit & proper may kindly be granted to the
respondents in the interest of justice.

Humble Respondents,

Dated: ___________

Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176
IN THE COURT OF MIAN MUHAMMAD RIAZ KHURRAM,
CIVIL JUDGE, MULTAN.

Syed Mahmood-ul-Hassan VS. Mahboob Alam etc.

Petition U/s 3 & 4 of the Contempt of Court Act.

WRITTEN REPLY

AFFIDAVIT of: -
Mahboob Alam, Additional Secretary, P.C.G.A.
Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-titled written reply 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 December 2002 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief. Nothing has been kept
concealed thereto.

DEPONENT