 |
| Writ Petition for Sui Gas Supply |
In the name of ALLAH, the most beneficent, the most
merciful
Format of Writ Petition for Sui Gas supply
BEFORE THE
HONOURABLE
W.P
No. ________/15
1.
Farhan Yaseen son of Mehmood Alam R/O _________
2.
Kamran Ali son of Ishtiaq Ali
Bhatti R/O _________
3.
Ahsan Ali Malik Gujar son of Adeel
Akhtar R/O _________
Petitioners
Versus
1.
Federation of
2.
Sui Northern Gas
Pipelines, Limited, through its General Manager (
3.
Managing Director,
Sui Northern Pipelines, Limited.,
Respondents
WRIT
PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF ISLAMIC
The petitioners
most respectfully submit as under:
1.
That the petitioners
are respectable citizens of
2.
That the people
of the rural areas of Rawalpindi such as Kalri, Chak Beli Khan, Dhoke Abdullah,
Terbella Colony, Panjgran, Dawri and their adjoining abadis falling in constituencies
PP-5 and PP-6 have been facing hardships due to lack of gas facility in their
areas, therefore in the year 2013 a delegation of respectable of both the constituencies
met _____, Adviser to the then Prime Minister of Pakistan for resolution of their
issues. Mr. _____took them to the then Honourable Deputy Prime Minister of
3.
That in pursuance
of the directive of the Honourable Prime Minister, the Cabinet Division has
released the aforesaid amount i.e Rs. 90 millions for execution of work at the
site Rs. 19 millions were released in favour of PWD for civil works whereas Rs.
71 million were credited to the Sui Gas pipelines Limited (SNGPL) for provision
of gas facility to the rural areas of District Rawalpindi.
4.
That in pursuance
of announcement of the then Honourable Prime Minister of
|
S. No. |
Scheme |
Cost |
|
1. |
Provision
of Gas-Chak Beli Khan, |
40
Millions |
|
2. |
Provision
Gas-Village Karli U/C Kalya, Tehsil and District |
3
Millions |
|
3. |
Provision
Gas-Village Dhoke Abdullah, Terbella Colony & Adjoining Abadis, Dhamial,
Tehsil and District |
8
Million |
|
4. |
Provision
of Stadium U/C Dhamial Rawalpindi |
8
Millions |
|
5. |
Provision
Gas-Pajgraran Dawri & Adjoining Abadis, Tehsil Rawalpindi |
20
Millions |
|
6. |
Completion
of Press Club, |
1
Million |
|
7. |
Rehabilitation
of |
10
Million |
|
|
Total
Costs |
90
Millions |
5.
That thereafter
PWD started carrying out work and executed the schemes according to plan but
the respondent No. 2 and 3 did not do the needful and withheld the amount of
Rs. 71 Million released for provision of gas facility to rural areas of
Rawalpindi and thus the people of these areas are still suffering difficulties and
hardship due to non-provision of gas facility.
6.
That promotion of
social and economic well being of the people and provision of basic facility of
life to the citizens is the responsibly of the Government under article 38 of the constitution. The then prime Minister
of Pakistan at the initiative of the then Honourable Deputy Prime Minister of
Pakistan, _________and the then Advisor the, _________had approved the schemes and
allocated and released the amount for provision of gas facilities to the
aforesaid rural areas of Rawalpindi and respondents were under obligations to
implement the schemes and carry out the work at the site for providing gas
facility to the peoples of these areas but respondent No. 2 and 3 have
miserably failed to perform their duties and execute the work at the spot. The
respondents are unnecessarily and malafidely hampering the schemes approved for
welfare and betterment of the peoples . The peoples of rural areas of
7.
That after
delaying by the respondents for non
providing of gas facility to the above mentioned areas, others resident of above mentioned rural areas, namely ______________filed
a Writ Petition bearing No. ___/2013 titled as “__________ versus Federation of Pakistan etc” before the this
Honourable Court. The report/ comments
on behalf of respondents were submitted in which they admitted that the scheme
was approved and funded of rural areas of
8.
That now it has
passed more than one year from
9.
That as per scheme an amount of 8 Millions was released for the rural area of petitioner No.
1 and 3 and an amount of 3 Millions was released for the rural area of petitioner
No. 2 but as mentioned above there has not been made any effort for providing
of gas facility especially in the area of petitioners.
10.
That the
petitioners are apprehending that inordinate and unreasonable delay caused by
the respondents in execution of development schemes may have lapsed of funds. Therefore,
an urgency is involved in the matter for disposal of the same on urgent basis.
11.
That inaction on
the part of respondents in providing gas facility to the peoples in violative
of Article 25 and 38 of the constitution, hence this writ petition having there
being no other efficacious and adequate remedy.
PRAYER
It is, therefore, respectfully prayed that the instant writ
petition may graciously be allowed, writ of mandamus be issued and the
respondents be directed to provide the facility of Gas to the rural area of
petitioners in accordance with the schemes approved by the Government of
Pakistan as narrated above, in the interest of justice.
Any other
relief which this Honourable Court may deem fit and proper, may also be awarded
to the petitioners.
Petitioners
Through
Counsel
Advocate
High Court
CC No. 2000001
CERTIFICATE
As per instructions received,
it is certified that this is the first writ petition on the subject matter,
being moved in this honourable court.
Counsel