To

Subject:

The Principal,
Quaid-e-Azam Law,
College Nawabshah.
Request for admission in LL.B Part-III and issuance of examination
form of the same class.

Respected Sir,
It is humbly submitted in your that I had passed LL.B part-II
in your college and after passing of the same I could not get the
admission in LL.B part-III due to my transfer from Nawabshah to
Karachi I was remained unaware for the last date of admission in
said class, when I came to know that examinations forms are being
filled and have approached to the concerned office but the office
staff have refused with direction to make the application in your
honour and after grant of the same I may be admitted and
examination form shall be issued otherwise I may not able if my
application is not granted, due to bonafide reason above I may be
exempted and save my future.
Therefore, may kindly be allowed my request and to
save my future, I shall remain thankful to you for this act of
kindness.
Thanks.
Dated.

Yours obediently

Fayaz Hussain
son of Inayat Ali
Gopang.

Pir

Bux

S/O

Ameer

Bux

Mangsi,

Muslim, adult, r/o: Village Nabi Bux

Magsi,

Taluka

Sakrand,

District

Shaheed Benazir Abad.

------------------------ Appellant.

DEPARTMENTAL APPEAL
Being

aggrieved

and

dissatisfied

by

the

office

order

No.14(267)/Admn:/2011/-2841, dated 14.09.2011, issued by the Deputy

Director Food, Sukkur Region, Sukkur imposing penalty of Dismissal
from service upon the appellant and terminating his services from the
post of Food Supervisor, Shaheed Benazir Abad, the appellant prefers
this appeal with a prayer that the said order imposing penalty of
dismissal from service may be set-aside and the appellant may be

allowed to continue his services as Food Supervisor, Shaheed Benazir

Abad, on consideration of the submissions, mentioned herein below:-

1).

That appellant was serving / working as Food Supervisor in Food

department in District Shaheed Benazir Abad and was appointed in

September, 1993.
2).

That the appellant was posted as Center In-charge Wheat

Procurement Center Bandhi for purchasing the wheat on behalf of

Government for the crop of 2009-10.
3).

That as per Government policy, the appellant started purchasing

wheat from different growers at the Wheat Procurement Center aforesaid.

P/2

To
The Director Food,
Food Department,
Govt. of Sindh,
Sindh Secretariat Karachi.

Pir

Bux

S/O

Ameer

Bux

Mangsi,

Muslim, adult, r/o: Village Nabi Bux

Magsi,

Taluka

Sakrand,

District

Shaheed Benazir Abad.

------------------------ Appellant.

DEPARTMENTAL APPEAL
Being

aggrieved

and

dissatisfied

by

the

office

order

No.14(267)/Admn:/2011/-2841, dated 14.09.2011, issued by the Deputy

Director Food, Sukkur Region, Sukkur imposing penalty of Dismissal
from service upon the appellant and terminating his services from the

post of Food Supervisor, Shaheed Benazir Abad, the appellant prefers

this appeal with a prayer that the said order imposing penalty of
dismissal from service may be set-aside and the appellant may be
allowed to continue his services as Food Supervisor, Shaheed Benazir
Abad, on consideration of the submissions, mentioned herein below:-

1).

That appellant was serving / working as Food Supervisor in Food

department in District Shaheed Benazir Abad and was appointed in

September, 1993.
2).

That the appellant was posted as Center In-charge Wheat

Procurement Center Bandhi for purchasing the wheat on behalf of

Government for the crop of 2009-10.
3).

That as per Government policy, the appellant started purchasing

wheat from different growers at the Wheat Procurement Center aforesaid.

P/2

P/2
4).

That since there was no any arrangement at the aforesaid Wheat

Procurement Center for keeping the wheat in a safe custody on behalf of

the Government/Food Department.
5).

That the appellant purchased the wheat on behalf of Food

Department and approached District Food Controller, for getting the

same shifted to the godowns, as it was the work of the Contractor(s) to
shift the same, the application was moved by the appellant on
04.05.2010, duly received on 04.05.2010. Again the appellant moved
application to the District Food Controller, Shaheed Benazir Abad , for
getting the purchased wheat shifted to the Govt. Godowns from Wheat
Procurement Center aforesaid, where the appellant was appointed,
contending that the wheat was kept under open sky and there was every
apprehension of damage to the said wheat. The appellant again moved
application on 08.07.2010, duly received by the office of District Food

Controller, Shaheed Benazir Abad and being aggrieved by the attitude of

District Food Controller, Shaheed Benazir Abad, the appellant again
moved applications for the purpose aforesaid, which were duly received
on 17.05.2010, but to no avail.
6).

That the Khatedars were approaching the appellant for over and

again for getting the wheat shifted, resultantly the appellant asked them
for bearing the fare by themselves, as soon as the payment of shifting the
wheat is made to the contactors, that would be caused adjusted, as a
result of which the Khatedrs themselves shifted wheat to the Govt.
Godown and receipts were handed over to the appellant.
7).

That due to the shift of wheat on the part of the Khatedars

themselves, so much amount of them remained unpaid to them against

the contractors, which was being asked to the appellant to be paid, hence
some of the Khatedars refused to further shift the wheat or handover the
same to the appellant for the purpose of shifting because of their dues of
fare charges already sustained by them.
8).

That the appellant tried his level best to obtain the wheat from the

khatedars who are defaulter as yet, but complete result has not been
achieved.
P/3

9).

P/3
That it is also very strange that the contractors were paid whole

the amount of wheat shifting without obtaining the Clearance certificate

from the appellant, which create complication for the appellant being still
faced.
10).

That on the appellant was in his try to recoup the wheat from the

growers / khatedars, mean while a show cause notice was issued to the
appellant, for which he replied vide dated: 23.06.2011. It is also worth to
mention here that show cause notice dated 14.06.2011, the appellant
has been shown to be a defaulter of shortage of 1710 Jute bags and 01
P.P bags , but in the order of dismissal dated 14.09.2011, it has been

mentioned that there are 1478 Jute bag are remaining outstanding
against the appellant, which shows that appellant was busy in
completing his work of depositing the shortage wheat bags after
recouping the same from the growers / khatedars.
11).

That the appellant is availing his all efforts to make the wheat bags

completed to deposit the same before the Govt. Godwon after recouping
the same from the Growers / Khatedars.
12).

That the dismissal order dated: 14.09.2011, was received to the

appellant on 13.10.2011, hence the submissions are made as appellant

is not on fault to move the present appeal before your kind excellancy.
Therefore, in the light of the aforesaid submissions, I humbly
submit that order of dismissal from service bearing No. 14(267)/
Admin:/-2011/-2841, dated 14.09.2011, may be set aside and the
services of the appellant may be restored.

Appellant.

To

The Director Food,

Food Department,
Govt. of Sindh,
Sindh Secretariat Karachi.

Khair Muhammad S/O Bahadur Khan

Bhatti,

Muslim,

Muhammad
Sakrand,

adult,

Essa

District

r/o:

Village

Bhatti,

Taluka

Shaheed

Benazir

Abad.
------------------------ Appellant.

DEPARTMENTAL APPEAL
Being

aggrieved

and

dissatisfied

by

the

office

order

No.14(267)/Admn:/2011/-2840, dated 14.09.2011, issued by the Deputy

Director Food, Sukkur Region, Sukkur imposing penalty of Dismissal
from service upon the appellant and terminating his services from the
post of Food Supervisor, Shaheed Benazir Abad, the appellant prefers
this appeal with a prayer that the said order imposing penalty of
dismissal from service may be set-aside and the appellant may be
allowed to continue his services as Food Supervisor, Shaheed Benazir
Abad, on consideration of the submissions, mentioned herein below:1).

That appellant was serving / working as Food Supervisor in Food

department in District Shaheed Benazir Abad and was appointed in

September, 1993.
2).

That the appellant was posted as Center In-charge Wheat

Procurement Centers Shah Hussain, Mirza Shakh and Gupchani for

purchasing the wheat on behalf of Government for the crop of 2009-10.

3).

That as per Government policy, the appellant started purchasing

wheat from different growers at the Wheat Procurement Centers

aforesaid.
P/2

P/2
4).

That since there was no any arrangement at the aforesaid Wheat

Procurement Centers for keeping the wheat in a safe custody on behalf of

the Government / Food Department.
5).

That the appellant purchased the wheat on behalf of Food

Department and approached District Food Controller, for getting the

same shifted to the godowns, as it was the work of the Contractor to shift
the same, the application was moved by the appellant on 04.05.2010,
duly received on 04.05.2010. Again the appellant moved application to
the District Food Controller, Shaheed Benazir Abad , for getting the
purchased wheat shifted to the Govt. Godowns from Wheat Procurement
Centers aforesaid, where the appellant was appointed, contending that
the wheat was kept under open sky and there was every apprehension of
damage to the said wheat. The appellant again moved application on
08.07.2010, duly received by the office of District Food Controller,
Shaheed Benazir Abad and being aggrieved by the attitude of District
Food Controller, Shaheed Benazir Abad, the appellant again moved
application for the purpose aforesaid, which was duly received on
14.07.2010, but to no avail.
6).

That the Khatedars were approaching the appellant for over and

again for getting the wheat shifted , resultantly the appellant asked them
for bearing the fare by themselves, as soon as the payment of shifting the
wheat is made to the contactors, that would be caused adjusted, as a
result of which the Khatedrs themselves shifted wheat to the Govt.
Godown and receipts were handed over to the appellants.
7).

That due to the shift of wheat on the part of the Khatedars

themselves, so much amount of them remained unpaid to them against

the contractors, which was being asked to the appellant to be paid, hence

some of the Khatedars refused to further shift the wheat or handover the
same to the appellant for the purpose of shifting because of their dues of
fare charges already sustained by them.
8).

That the appellant tried his level best to obtain the wheat from the

khatedars who are defaulter as yet, but complete result has not been
achieved.
P/3

9).

P/3
That it is also very strange that the contractors were paid whole

the amount of wheat shifting without obtaining the Clearance certificate

from the appellant, which create complication for the appellant being still
faced.
10).

That on the appellant was in his try to recoup the wheat from the

growers / khatedars, mean while a show cause notice was issued to the
appellant, for which he replied vide dated: 23.06.2011. It is also worth to
mention here that 14.06.2011, the appellant has been shown to be a
default of shortage of 1528 Jute bags and 2102 P.P bags , but in the
order of dismissal dated 14.09.2011, it has been mentioned that there
are 816 Jute bag and 608 P.P Bags are remaining outstanding against
the appellant, which shows that appellant was busy in completing his
work of depositing the shortage wheat bags after recouping the same
from the growers / khatedars.
11).

That it is also worth mention here that the appellant further

deposited 47 Jute Bags and 115 P.P bags of wheat duly received at
Nawabshah Godowns.
12).

That the appellant is availing his all efforts to make the wheat bags

completed to deposit the same before the Govt. Godwon after recouping
the same from the Growers / Khatedars.

13).

That the dismissal order dated: 14.09.2011, was received to the

appellant on 13.10.2011, hence the submissions are made as appellant

is not on fault to move the present appeal before your kind excellancy.
Therefore, in the light of the aforesaid submissions, I humbly
submit that order of dismissal from service bearing No. 14(267)/
Admin:/-2011/-2840, dated 14.09.2011, may be set aside and the
services of the appellants may be restored.

Appellant.