IN THE COURT OF DISTRICT
JUDGE / DIRECTOR HUMAN RIGHTS GHOTKI
Misc:
App: No. 2015
Muhammad
Mithal S/o Abdul Rehman Panhwar
By
profession an Advocate,
Resident
of Village Abdul Rehman Panhwar near Ice Factory,
(Jalbani
law chamber, lawyer’s street)
Taluka
Miprur Mathelo District Ghotki ……………………………Applicant
V E R S U S
1 Chief Executive Engineer
Highway Division Ghotki
2. SDO
Roads, Mirpur Mathelo
3. Circle Officer,
Anti-corruption
Establishment Circle, Ghotki
4.
Deputy Commissioner
District Ghotki @ MiprurMathelo ……………………….
Respondents
APPLICATION TO CONSTRUCT THREE (03) DRAINAGE
SYSTEM /WATER COURSE BRIDGES BETWEEN THE UNDER CONSTRUCTED METALED ROAD
I the undersigned
applicant state as under,
1.
That I am the law abiding citizen
of Pakistan and residing @ above address within this Honorable Court's
jurisdiction.
2.
That about 03 years ago (in the
year 2012) the contract of metaled road with 03 drainage system /water course
bridges from by-pass Mirpur Mathelo to Belo Mirpur/village Abdullah Marnass via
Village Abdul Rasool Khoso & Village Abdul Rehman Panhwar about 1.5 km was
approved and tendered by the Sindh Government through the respondent no.1, as
the information acknowledged from the office of respondent no.1.
3.
That the construction of road was
started without construction of 03drainage system /watercourse bridges by the
petty contractor.
4.
That the villagers reached to respondent
no.01 and requested for construction of 03 drainage system / watercourse
bridges between the under constructed road but the respondent no.1 also given
hopes but no any action taken till to date.
5.
That the solid bricks were bought
by the contractor on site and after few days later the solid bricks lifted by
some unknown persons as the construction of
03 drainage system / water course bridges may delay and interrupted.
6.
After that Mr. Ubedullah soomro
presently DSP Admin @ SSP office and other villagers have been move the many applications
to construct the 03 water course/drainage system bridges in under constructed
road to respondent no.1 to 4 as on dated 27.04.2013, 29.05.2013, 24.06.2014, 05.08.2014,
29.08.2014, 15.12.2014 & 13.01.2015, But till to date there is no response
to construct the said bridges for drainage the land and crossing of rain both
side to road.
7.
That during construction of
metaled road in the monsoon season, it was rained about 2 weak continuously.
Due to filling of mud in the under constructed road about 05 feet’s from land
and non-construction of 03 drainage/watercourse bridges, the rainy water was
stopped because there is no another way to cross the filled mud between the
under constructed road.
8.
That due stop of mud / road, the
rainy water comes into our houses and residential buildings & boundaries
walls were cracked and damaged. Due to raining and non-construction of said bridges,
the houses and lands are filled with rainy water. The flow of water is from the
East side of road to West and the road is West side of my & villagers
houses and lands.
9.
That the crop of about 2000 acres
destroyed due to the reason of stoppage of rainy water and non-construction of 03
drainage/watercourse bridges between the under constructed metaled road. Having
the loss of hundred thousand to farmers of land and also landlords.
10.
That the said road is crossing
from my house to village Abdullah marnas along with my house building, my house
is also on the right bank of under
constructed road.
11.
That the contractor is a
political influences person whose name don’t tell us by the respondent no.1.
The road is constructed by another petty contractor, who has no proper
machinery, engineers and workers to construct the road as per Tender and Government’s
rules and regulations.
12.
That we are in
very trouble because there is no crossing of water for drainage the irrigated
lands and monsoon rain between whole roads which is still under construction.
13.
That the
applicant lastly contacted to respondent no.01 as on dated 04.03.2015 for the
construction of road with 03 bridges between the roads but the respondent no.01
absolutely refused to construct the road and 03 bridges.
14.
That the
applicant has no other alternate remedy available except to appear before this Honorable
Court and pray for the justice.
15.
That the applicant
therefore prays for the judgment, decree and directions to concerned
authorities as under,
A.
This Honorable Court may be
pleased issue directions/orders to respondent no.1 & 2 to construct the 03
drainage system / water course bridges for crossing the rain water and also to
irrigate the agriculture lands between the under constructed metaled road and
also to complete the whole work within time.
B.
To issue the directions to respondent
no.3 & 4 to enquiry the matter & take the legal action against this
corruption and interruption in work.
C.
To issue the direction to
respondent no. o1 & 02 to cancel the license of contractor for this
corruption and negligence.
D. To
award the other costs of the applicant for this case.
E. Any
other relief which this Honorable Court may deems fit and proper under the circumstances
of this application.
Dated: APPLICANT & ADVOCATE IN PERSON
Documents
Filed
2.
P.S Copies of Applications to respondents
IN THE COURT OF
DISTRICT JUDGE / DIRECTOR HUMAN RIGHTS GHOTKI
Misc:
App: No. 2015
Muhammad
Mithal Panhwar ………………………… Applicant
V E R S U S
Chief
Executive Engineer
Highway
Division Ghotki & others ……………………… Respondents
A F F I D A V I
T
I, Muhammad Mithal Panhwar s/o Abdul
Rehman by – caste Panhwar, by
profession an Advocate, Resident of Village Abdul Rehman Panhwar, (Jalbani law
chamber, lawyer’s street), near Ice Factory bypass, Taluka Miprur Mathelo
District Ghotki do hereby state on oath as under,
1.
That I am deponent in this
affidavit and also applicant, hence well conversant with the facts of the case.
2.
That the proposed respondents
named in the application having influential persons and have committed to do
not complete the construction of metaled road with 03 drainage / water course
bridges between the under constructed metal road within time.
3.
That I am stated on oath that for
the sake of brevity the contents of the application may kindly be treated as
part of this affidavit.
4.
That whatever is stated above is
true and correct to the best of my knowledge and belief.
Verified and
signed by me at Ghotki as on dated _____ day of March 2015
D E P O N E N T
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