To The Deputy Inspector General of Police Punjab Highway Patrol, Lahore.

Subject: APPEAL AGAINST THE ORDER NO 2175-80/PA-SSP-PHP DATED 17-03-12 OF THE SENIOR SUPERINTENDENT OF POLICE PUNJAB HIGHWAY PATROL LAHORE, WHEREBY HE AWARDED THE MAJOR PUNISHMENT OF DISMISSAL FROM SERVICE TO THE APPELANT. PRAYER TO SET ASIDE THE IMPUGNED PUNISHMENT ORDER W.E FROM PASSING THE IMPUGNED ORDER WITH ALL BACK BENEFITS. My Respected Sir, With excellent respects, utmost regards reverences and deepest venerations. I beg to submit the following few line for favour of your good selfs sympathetic/gracious consideration.
1.

That the appellant was recruited as Constable in Punjab Highway Patrol 2004. After his induction, the appellant performed his official duties with full dedication/devotion, while utilizing all his physical as well as intellectual abilities and never gave a chance of complaint to his seniors. The service of appellant was ever appreciated by departmental high ups. He was also awarded many commendation certificates. During the service the appellant passed the departmental Examination of List A and B. The appellant also passed M.A Political Science exams in 2008.

2.

That the appellant was served with the show cause notice no. 3772/PA-SSP-PHP dated 05-08-11 containing the following allegations that: While he was posted at PHP 48/3.R on receipt of information that a berretta pistol has been lost by the officials of PHP post 48/3.R Dist. Okara and a local made berretta pistol has been kept in its place in kot by the delinquents. A committee comprising of Mr. Nafasat Ali

Khan DSP PHP Kasur, and Miss. Azra Parveen Dsp PHP Okara was constituted to conduct a detailed inquiry into the matter find out facts and fix responsibility
3.

The appellant submitted his written reply to the show cause notice in which he pleaded himself innocent. He was summoned in the orderly room. The appellant successfully explained his position before the punishing authority during his personal hearing in orderly room, but it was perhaps the hard luck of the appellant that the punishing authority did not consider the submissions of the appellant in a positive way, rather passed the impugned punishment order in a hasty manner. Hence submitting this appeal.

4.

That the impugned order is liable to be set aside on the following grounds.

GROUNDS:
1. That the impugned punishment order is against law and facts of the

case.
2. That the appellant is absolutely innocent in to the matter. 3.

That while passing impugned order the punishing authority failed to appreciate the real situation of the matter. Detailed submission of the appellant in this regard are as under

a. During posting of the appellant at PHP post 48/3.r District Okara

performed his duties devotedly and no complaint from any corner was received against the appellant to his seniors.
b. That the appellant is innocent in the matter on the following grounds. c. My duration as an incharge PHP 48/3.R since 19-02-09 to 22-05-10

and during my inchargeship neither displacement of pistol berretta H60169Z happened nor the muharrir constables reported its

displacement in daily diary and even so much so I have never been reported about its displacement. During the same era high officials inspected the post formally and informally approximately 90 times. And they reported OK about arms and performance in their ammunition and my inspections and

displacement/replacement/deficiency of the above mentioned pistol berreta have never been reported(Copies of inspection reports are attached are as appendix A)
4. Armour Amir Abbas 2178/c have been repeatedly visited the post who

never reported displacement/replacement/deficiency. With reference to DD 04 Dated 22-05-10 Israr Hussain Si took over the charge as incharge PHP 48/3.R and same day muharrir reported in the daily diary that every thing including arms and ammunition in its perfect state(copies attached as appendix B). All these references bear out that during my inchargeship displacement/replacement/deficiency of pistol berretta have never been reported and happened.
5. Sir, I have never been issued pistol berretta H60169Z, inquiry

committee verified it after scrolling out record, daily diaries and arms register. Direct custodians are muharrir constables they posses keys of kot as well and they never mentioned its displacement in daily diary. Whenever I visited the kot along with officers, visiting authorities found arms in there perfect conditions. During the same time arms expert also checked arms stock and reported OK as I have not completed the arms expert course and I am not an arms expert so about replacement of pistol did not came to my notice. That the written as well as oral explanation of the appellant has not been considered sympathetically.

6.

Sir, the FIR No. 14/11 against me was registered in PS Cantt Okara dated 11-01-11 in which I was allegated that I didnt inform about displacement/replacement/deficiency of pistol berretta during Sep 2009. I want to put forward in my defence the following proofs arguments.

DD 31 dated 04-09-09 Farhan Nazir 2310/c was issued pistol berretta H60169Z along with Qaisar Abbas on motor cycle as reported in daily diary by Muharrir Iftikhar Hussain 2293/c for patrolling duty.

DD 30 dated 13-09-09 Dilshad Ali Si issued pistol berretta H60169Z and departed on patrolling by Muharrir Iftikhar Hussain 2293/c

DD 23 dated 16-09-09 Armourer Amir Abbas visted the post for checking the arms as reported in daily diary

DD 26 dated 16-09-09 Tariq Mehmood 2135/c armed with pistol berretta H60169Z and departed on patrolling by Muharrir Iftiikhar Hussain 2293/c.

DD 32 dated 17-09-09 Head constable Shahid Iqbal was departed on patrolling by Muharrir Iftikhar Hussain 2293/c with berretta pistol H60169Z.

At 3.20 PM on 19-09-09 formal inspection of post was carried out by Zia Malik Assistant Director PMU Home Department and he didnt report of about pistol any berretta displacement/replacement/deficiency

H60169Z and on the same day post was visited by DSP/PHP Okara Ali Ahmad Mirza who also declared every thing all right.

In Sep 2009 as trainee ASI I had have to go for C course to DPO office Okara even then I performed my duties in best way entrusted for. DD 10 and 66 06-06-09 with permission of DSP/PHP Okara timing of patrolling was changed from 10 PM to 10.30 & 11 PM and all the personnel was directed to get ready and bound to move with out haulting the vehicle in front of post even for a minute so that changing the timing of shift could not be assessed by culprits because of sudden patrolling orders DD 34 dated 19-09-09 was reported by Fazal Ur Rehman Muharrir and I am not at fault. With reference to order no 9500-55c-ii by the office

of respected provincial police officer Punjab dated 29-10-07 in paragraph 2 it was very clearly mentioned that responsibility of

pistol berretta is upon muharir/Kot muharrir( copy of order attached as appendix C) Sir, according to above mentioned arguments it is evident that the issuance of pistol berretta H60169Z in Sep 2009 was being by Muharrir Iftikhar Hussain 2293/c and if the allegation of taking oath would have been true than these departures appear on the scene instantly and the personnel who was being issued this pistol negate its issuance than only Muahrrir Iftikhar Hussain 2293/c can explain the very issue.
7. After the appointment of Israr Hussain Si on 22-05-10 post

was formally inspected on 24-05-10 by DSP/PHP Nankana Sahib MR. Muhammad Afzal by order no. 1318/R-Dsp-Php/NNK in which Nadeem Anwar ASI was performing admin duties and in there presence Dsp Nankana himself inspected the arms and uptill that day no report of displacement/replacement/deficiency was mentioned during informal inspection of the post stay at the post 4/5 hours and evaluate all and sundry and personally check kot/mall khana/ store( copies attached).
8.

That the officers conducted surprise visit formal and informal inspection of PHP post 48/3.R District Okara on the dates mentioned against each and recorded there views/comments but they did not point out regarding displacement/replacement/deficiency of official weapon berretta H60169Z attached as appendix D.

S. No 1. 2.

Name of officer visited PHP 48/3.R Okara Mr. Ali Ahmad Dsp/php Okara

Date of visit 02-09-09

Mr Shahzada Khurram Assistant Director OPS 06-09-09 Home department Lahore

3. 4. 5. 6. 7. 8.

Mr. Ali Ahmad Dsp/php Okara Mr. Ali Ahmad Dsp/php Okara Mr. Ali Ahmad Dsp/php Okara Mr. Ali Ahmad Dsp/php Okara Assistant Director Mr. Zia Malik PMU Mr. Ali Ahmad Dsp/php Okara

07-09-09 10-09-09 11-09-09 06-09-09 19-09-09 19-09-09

9. 10. 11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21. 22. 23. 24. 25. 26. 27. 28. 29. 30. 31. 32. 33. 34. 35. 36. 37.

Mr. Ali Ahmad Dsp/php Okara Mr. Kamran Akhtar Dsp/Php Kasur Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Assistant Director Mr. Zia Malik PMU Mr. Ali Ahmad Dsp/Php Okara Malik Nasim Ul Haq SSP/PHP Lahore Mr. Ali Ahmad Dsp/Php Okara Mr. Abdul Wahid Dsp/Php Kasur Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Zia Malik Assistan Director PMU Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Zia Malik Assisstant director PMU Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr Zia Malik Assistant Director PMU Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Ali Ahmad Dsp/Php Okara Mr. Zia Malik Assistant Director PMU DSP/HQR Lahore

29-09-09 30-09-09 01-10-09 03-10-09 09-10-09 07-10-09 22-10-09 22-10-09 26-10-09 27-10-09 03-11-09 07-11-09 08-11-09 14-11-09 21-11-09 25-11-09 27-11-09 02-12-09 09-12-09 12-12-09 05-01-10 14-01-10 16-01-10 04-02-10 12-02-10 18-02-10 22-02-10 27-02-10

Mr. Muhammad Ashraf Awan DSP/T&T HQR 04-03-10 Lahore

38.

Azra Parveen Dsp/Php Okara

07-03-10

39. 40. 41. 42. 43. 44. 45. 46. 47. 48. 49. 50. 51. 52. 53. 54. 55. 56. 57. 58.

Mr. Zia Malik Assistant Director PMU Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Hummaira Tabassum Dsp/Php Kasur Azra Parveen Dsp/Php Okara Mr. Zia Malik Assistant Director PMU Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Malik Nasim Ul Haq SSP/PHP Lahore Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Azra Parveen Dsp/Php Okara Mr. Zia Malik Assistant Director PMU Mr. Shahid Minhas DSP/Hqr Lahore Azra Parveen Dsp/Php Okara

13-03-10 10-03-10 17-03-10 24-03-10 25-03-10 02-04-10 10-04-10 08-04-10 10-04-10 14-04-10 21-04-10 24-04-10 26-04-10 26-04-10 03-05-10 13-05-10 17-05-10 20-05-10 21-05-10 23-05-10

The reports of above officers indicate that displacement/replacement/deficiency of pistol berretta H60169Z was not happened during my inchargeship.

According to the preliminary inquiry the so called oath about displacement of pistol berretta H60169Z was carried out on 18-09-09 which is totally baseless allegation neither I have took such oath nor gave because such incidence never came in to my knowledge for if such

incidence would have been happened then instantly according to the SOP of arms and ammunitions No. 9031-38/T&T issued by Add. IG / PHP according to which In case of any lost/displacement/misplacement of arm muharrir instantly reported in Daily Diary and inform telephonically to District DSP and that DSP immediately visited the particular post and will filed the informative report in daily diary and informed regional SSP about all realities who will sent a special report to Headquarter Lahore The above mentioned procedure was not implicated any where in daily diary during the era of my inchargeship which proves that blame on me is totally baseless. 9. That Show cause notice issued on the base of inquiry in which inquiry officer clearly declared that he failed to point out the specific date of displacement/replacement/deficiency of pistol berretta H60169Z. Hence the inquiry has no value in the eyes of law. That while passing the impugned order the competent authority didnt keep in mind the above solid facts of the case of the appellant rather based on the surmises and conjectures which is not warranted in law/justice/. That the appellant is the sole bread winner of his family comprising of school going children and advance aged parents. He had no other source of bread earning except the present service. The impugned order has cut down the only source of income the appellant due to which he and his innocent family members are facing quite financial problem extending to the state of starvation in these price hike days for no fault on there part. The appellant is also entitled for his re-instatement in service on these humanitarian/compassionate grounds.

In view of the above submissions, it is humbly prayed that the instant appeal may kindly be accepted, the impugned order be set aside and appellant may be restored in service with all back benefits w.e.f passing the impugned order to meet the ends of the justice.

The appellant will be highly thankful and shall pray from almighty Allah for your good selfs happy/long life for this act of kindness. All relevant documents are attached for kind perusal.

Yours Obedient Servant.

Ex ASI Munsaf Ali 49/SL S/O Abdul Rasheed R/O Chak # 18/4.L PS Cantt Okara Mobile # 0300-7954404