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| Writ Petition Format (Water Connection) |
In the name of ALLAH, the most beneficent, the most
merciful
BEFORE THE
W.
P No._________/2021
Nabeel
Ahmed Khan Raja son of Raja Ahmed Gujar Chaudhary resident of House No.
787854, Street No. 454544, Mohallah Chah Chan Gawalmandi, Rawalpindi
.
…Petitioner
Versus
1.
Commissioner,
2.
Water and
Sanitation Agency (WASA), WASA
Headquarter, Liaquat Bagh,
3.
Respondents
WRIT PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF ISLAMIC
Respectfully Sheweth;-
1.
That the
addresses of the parties are evidently given for the efficacious purpose for
the deliverance of summons/ notices/ orders, issued / passed by this Honorable court.
2.
That the
petitioner is invoking the jurisdiction of this Honourable Court under article 199
of the constitution of Islamic Republic of Pakistan 1973 and seeking a writ in
the nature of mandamus.
3.
That as per
settled law, the petitioner in order to seek a writ of mandamus, fulfilled the
pre-requisite before invoking the jurisdiction of High Court under article 199
of the constitution of Islamic Republic of Pakistan 1973 by approaching the
respondents through written correspondence and by appearing before them in
person but the legitimate request of the petitioner is not solicited.
4.
That there is a
legal right exists of the petitioner which is explicitly shown. That by seeking
a writ in the nature of mandamus to explicitly show that there exist a legal
right in such a person to insist upon a clear duty being performed by some
public officer in respect of that right. Moreover, that a demand for performance
of such duty ought to have been made and the same had been met with refusal by
the public officer / authority in relation to the right being asserted. There
were no equally expeditious, in expensive and efficacious remedy is available
to the petitioner.
Brief Facts:
1.
That the brief
facts of the case are that the petitioner is a law abiding citizen, applied for
the water connection before respondent No. 2 vide Diary No. 200003 dated
2.
That according to
the rules of respondent No.2, the required time for providing the new water
connection is 10 to 15 days. That after expiry of said period, the
petitioner approached the respondents but one pretext or the other, the
respondents peculiarly respondent No.2 is delaying without giving any rhyme and
reason.
3.
That the
petitioner is having a water connection in one of his adjacent property No. House
No. 45487871, Street No. 34, Gawalmandi,
4.
That the petitioner is entitled for the fundamental
rations and services being a citizen of
Pakistan as laid down in Article 24(3)(e)(ii) of Constitution of Pakistan which
reads as under:-
“Providing housing and public
facilities and services such as roads, water supply, sewerage, and gas
and electric power to all or any specified class or citizen; or”
5.
That the
petitioner is deprived of the basic necessity and services by the respondent
No. 2 which is extensively illegitimate and against the basic median, moral
principles and natural justice. Moreover, the respondent No.2 failed to give any
strapping, lawful or unyielding rationale for not providing the water
connection for the residential premises which tantamounts to stern indiscretion
and misdeeds on the part of respondent No.2.
6.
That it is the
right of petitioner for enforcing his rights to life and quality before law.
This Honourable Court can issue Writ in the interest of justice and public
interest. Furthermore, this Honourable Court can issue authoritative direction to
the Government Officials / authority in an effort to preserve the rights of a citizen
of a country. These rights may be individual right and they may ensure that the
government system is running appropriately.
PRAYER:
In the facts and circumstances,
stated above, the petitioner prays that a direction in the form of writ of
mandamus be issued to the respondents to install water connection at Property
No. AB-56557 situated in Gawalmandi,
Any other relief which this Honourable Court
deems fit and proper may also be awarded to the petitioner.
Petitioner
Counsel
CERTIFICATE:-
As per information received, it is
certified that this is the first Writ Petition on the subject matter
being moved before this Honourable Court.
Counsel
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