IN THE HONOURABLE HIGH COURT OF SINDH AT KARACHI (CONSTITUTIONAL JURISDICTION)
Constitution Petition No. D-852 of 2019
1. Naeem Sadiq, Son of Mohammad Sadiq Malik, Muslim, Adult, Resident of F-15/2, 4th Gizri street, Phase IV, DHA, Karachi
2. Mirza Asad Hasan Kizilbash, Son of Mirza Aftab-I-Alam Kizilbash, Muslim, Adult, Resident of 14-K, 9th Gizri Street, Phase IV, DHA, Karachi
3. Ayesha Sasha Abdul Monem, Wife of Abdul Monem AlAdawy, Muslim, Adult, Resident of 4/A, 10th South Street, Phase II, DHA, Karachi
4. Rumana Mukhtar Husain, Wife of Mukhtar Husain, Muslim, Adult, Resident of 76/2, 12th Street, Off Khayaban e Badar, Phase VI, DHA, Karachi
5. Romana Khan, Daughter of M. Nasrullah Khan, Muslim, Adult, Resident of 10/1, 9th Zamzama Street, Phase V, DHA, Karachi
6. Karamat Ali, Son of (Late) Amanat Ali, Muslim, Adult, Resident/office at 143-A, Sector X-5, Gulshan-e-Maymar, Karachi
7. Pakistan Institute of Labour Education & Research, Registered as an Association under Section 42, Companies Ordinance, 1984, Through its authorized person, Having its registered office at PILER Centre, ST-001, Sector X, Sub-Sector V, Gulshan-e-Maymar, Karachi……………………………………………………………………….Petitioners
Versus
1. Federation of Pakistan Through Director, Directorate of Projects, Industries and Labor Welfare, Islamabad Capital Territory Administration, 2nd Floor, ICT Agriculture Complex, Mauve Area, G-11/4, Islamabad
2. Clifton Board Cantonment, Through Cantonment Executive Officer A body corporate established under the Cantonment Act, 1924, Having its office at Cantonment Board Clifton, Khayaban-e-Rahat, Phase VI, DHA Karachi
3. Province of Sindh Through the Secretary, Department of Labor and Human Resources, Government of Sindh, Having its office at Block No 86, Sindh Secretariat IV-B, Court Road, Karachi
4. Sindh Minimum Wages Board, Through its Chairman, Constituted under the Sindh Minimum Wages Act, 2015, Having its office at Block No 86, Sindh Secretariat IV-B, Court Road, Karachi…………………………………………..…………….Respondents
CONSTITUTION PETITION UNDER ARTICLE 199 OF THE CONSTITUTION OF THE ISLAMIC REPUBLIC OF PAKISTAN, 1973
It is most respectfully and most humbly submitted on behalf of the above-named Petitioners as under:
1. That the subject matter of this present Petition is the unconstitutional and illegal denial of
the basic minimum wage to the janitorial staff employed by the Clifton Cantonment
Board [herein after referred to as the ‘CBC’] i.e. Respondent No. 2. Through the present
Petition, the Petitioners seek, inter alia, the enforcement of the Minimum Wages for the
CBC janitorial staff on the basis of the Minimum Wages Ordinance, 1961 [herein after
referred to as the ‘Ordinance’] or the Sindh Minimum Wages Act, 2015, by the
Respondents such that the minimum wage is paid to the janitorial staff of Respondent
No.2. The Petitioners seek the enforcement of fundamental rights as guaranteed under the
Constitution, 1973.
2. That the Petitioners are concerned citizens of Pakistan and known activists who are
involved in various struggles for the enforcement of legal and human rights of the People
of Pakistan. In their individual capacities as well as through informal and formal forums,
organizations and activists’ groups, they work for the causes which uphold human rights,
social justice and righteousness and regularly fight for the fundamental rights of the
underprivileged and the marginalized individuals of our society, particularly laborers and
workers. The Petitioner No. 1 is a public-spirited individual who has extensively written
and worked on the rights to information and equality. The Petitioner No.2 is also a public-
spirited individual who has served as the General Secretary and as Vice President of the
Defence Society Residents Association (DSRA). He has represented residents' rights
numerous times before the Standing Committees of Defence in both the National
Assembly and the Senate of Pakistan. He also serves as the Honorary General Secretary
& Founding Member of Association of Defence Residents (ADR), which is a body
representing all the major resident associations of DHA. He is also a key member of the
initiative “Baraber Kay Shehri”. The Petitioner No. 3 is an environmental activist who
works on issues of waste management and has founded “The Green Gang Pakistan” to
further the efforts to spread awareness against environmental pollution and waste
management. The Petitioner No. 4 and No.5 are also public-spirited individuals who have
long been engaged in activism regarding various struggles for the people of Pakistan. The
Petitioner No. 6 in his personal capacity as well as in his capacity as the Executive
Director of Pakistan Institute of Labor Education and Research (PILER) i.e. the Petitioner
No.7 has always fought for the rights of labourers' and workers including, but not limited
to, the victims of, inter alia, 2012 Baldia Factory Fire tragedy and had filed CP No.3318
of 2012 [‘PILER and Others Versus Federation of Pakistan and Others’] and CP No.295
of 2013 [‘PILER and Others Versus SBCA and Others’] before this Honourable Court in
relation to the above tragedy.
A copy of the Certificate of Incorporation and Board Resolution of Petitioner No.7 (PILER) is annexed and marked as Annex ‘A’ & ‘A-1’.
3. That the Clifton Board Cantonment (hereinafter ‘CBC’) was established under the
Cantonments Act, 1924, which places the authority of Cantonments under the “Central Government” i.e. the federal government. CBC was brought into existence through the
Notification bearing SRO No. 207(1)/ (83), dated: 27-2-1983 in order to provide
municipal cover to 8 DHA phases together with 13 Katchi Abadis located in the periphery
and Blocks 8-9 of Clifton. An area of over 51.327 square kilometers with swelling
population of 0.5 million is presently under the purview of the CBC. CBC shares its
territory with Karachi Cantonment on its North and West, Karachi Metropolitan
Corporation (KMC) to the East and the Arabian Sea to the South. The CBC is statutorily
bound to provide essential services as to cleanliness and sanitation within its jurisdiction.
This includes, but is not limited to, watering streets and other public places and cleaning
streets, public places and drains abating nuisances and removing noxious vegetation.
Since, the CBC is governed by the Cantonment Act, 1924, the CBC is bound to fulfill
obligations regarding cleanliness and sanitation within the land under its purview. The
Cantonment Act, 1924, explicitly envisages the hiring of services staff, including but not
limited to, janitorial staff. Moreover, Section 36-A of the Cantonment Act,1924,
stipulates that all direct and indirect employees of the Cantonment will be deemed public
servants/employees.
4. That for the abovementioned duties and/or purposes, CBC obtains services of janitorial
staff which are in contractual employment with the third party contractors but work for
the benefit of and perform their duties and provide janitorial services for CBC, and wear
uniforms bearing the name ‘CBC’. Accordingly, the janitorial staff has no direct contract
with the CBC. This is a deliberate attempt of CBC to engage the services of the third
party contractor for the provision of janitorial staff so that firstly, CBC does not have to
directly pay remuneration to the janitorial staff, and secondly, to exonerate itself from the
responsibility of ensuring that minimum wage as envisaged under the Minimum Wages
Ordinance, 1961, is paid to the janitorial staff on the principle of consistency. By
engaging the services of the third party contractors to provide janitorial staff, CBC
attempts to place the entire responsibility on the third party contractor for remuneration.
However, there are three important aspects that must be considered. Firstly, the
staff/employees which provide services as “Contract workers” are classified as workmen
under the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968,
accordingly, they are entitled to the benefit of minimum wage for unskilled workers at Rs. 15,000/- per month, under the Federal Government Notification No. ADLW-
2(3)/ICT/2016-657 dated: 2ndAugust 2017, issued under the Minimum Wages Ordinance,
1961, on the principle of consistency. Secondly, CBC cannot exonerate itself from the
responsibility of ensuring that minimum wage is paid to the janitorial staff hired through
third party contractors as the definition of “employer” under the Minimum Wages
Ordinance, 1961, covers employers who employ directly or through another person (i.e.
third party contractors) on the principle of consistency. Thirdly, without prejudice to the
aforementioned, given the definition of “employer” in Minimum Wages Ordinance, 1961,
and in Sindh Minimum Wages Act, 2015, even if CBC janitorial staff could be considered
private employees of the contractor, CBC would still be responsible to ensure that they
are paid the provincial minimum wage, which is set at Rs. 16,200/- as per Notification
No. L-11-13-3/2016 dated: 1st July 2018 in accordance with Sindh Minimum Wages Act,
2015.
A copy of Federal Government Notification No. ADLW-2(3)/ICT/2016-657 dated: 2ndAugust 2017,anda copy of Sindh Government Notification No. L-11-13-3/2016 dated: 1st July 2018,annexed and marked as Annex ‘B’ and ‘B-1’.
5. That the janitorial staff is working for CBC at a dismal remuneration of Rs. 10,400/- per
month, without a contract, and without any employment benefits. The present wage is far
below the basic minimum wage of at Rs. 15,000/- per month for unskilled workers set by
the Federal Government Notification No. ADLW-2(3)/ICT/2016-657 dated: 2ndAugust
2017. The said janitorial staff is made to work 10 hours a day from 6:00 am to 4:00 pm,
six days a week. However, CBC fails to pay minimum wage to its janitorial staff, fails to
provide such janitorial staff with a contract, fails to pay overtime, fails to provide any
employment benefits or job security and further fails to ensure monthly wages are paid
on time, with weeks of delays in monthly payments.
A copy of testimonies collected from workers annexed and marked as Annex ‘C’ to ‘C- 2’.
6. That as stated above, CBC irresponsibly hires janitorial staff as contractual labor and fails
to ensure that any contract is executed between CBC and the janitorial staff. It is important
to mention here that the employment of the janitorial staff is not regularized even after
years of employment. Through this malafide omission CBC denies minimum wage, housing allowance, health insurance, pension, paid holidays, sick leave or bonus as
required under law. It is as a result of such cruel and discriminatory practices that ten
percent (10%) of wage earners in Pakistan are living below the poverty line, according to
international studies. It is important to submit that it is a settled principle, as held by the
Honourable Supreme Court of Pakistan, that regardless of whether they are public or
private; all contractual employees must be given minimum wage and employment
benefits. That is, they must be regularized or deemed to have been regularized. However,
as the facts herein will show, CBC fails to ensure that minimum wage is paid to the said
janitorial staff. Moreover, the struggle for a living wage remains a distant goal when
workers are struggling to obtain their rightful basic minimum wage.
A copy of the fact sheet produced by international wage monitor and supporting reports and articles is annexed and marked as Annex ‘D’ to ‘D-7’.
7. That the Petitioners and others have previously approached the Cantonment Executive
Officer in a Letter dated: 14th June 2017, requesting information under the Sindh
Transparency & Right to Information Act, 2016 and Article 19A of the Constitution of
the Islamic Republic of Pakistan, as to the contracts executed for janitorial staff in the
past three years, and numbers of so-called “gutter men” employed by CBC. He was
approached with the same again vide Letter dated: 10th July 2017. The Cantonment
Executive Officer for CBC was approached again vide Letter dated: 18th August 2017,
which urged that the janitorial staff be regularized as CBC employees, be given all lawful
employment benefits such as social security, pension and health insurance, and that
Occupational Health and Safety standards be maintained for all. The Petitioners and
Others have also written to the Director General of Military Lands and Cantonments,
Ministry of Defense vide letter dated: 2nd August 2018, again to avail no response. It is
important to mention here that unfortunately none of these letters availed any response
whatsoever.
A copy of the letters dated: 14th June 2017, 10th July 2017, 18th August 2017, and 2nd August 2018 is annexed and marked as Annex ‘E’ to ‘E-3’.
8. That the Petitioners and others have also written to the Federal Ombudsman’s office vide
Letter dated: 4th August 2017, in order to appeal against inaction of the Cantonment Executive Officer. However, the Federal Ombudsman’s Office replied vide Letter dated:
7th August 2017,stating that it could not take cognizance of the matter as the matter related
to a defense institution.
A copy of the Letter dated: 4th August 2017, and the Response dated: 7thAugust 2017,annexed and marked as Annex ‘F’ and ‘F-1’.
9. That as far as the regularization, provision of back benefits, pension, old age benefits, and
occupational health and safety rights of the CBC janitorial staff is concerned, the
Petitioners reserve the right to pursue the same through separate Petitions.
10. That it is most respectfully and most humbly submitted that being aggrieved by the
abovementioned illegal and malafide acts of the Respondents, being unconstitutional and
without jurisdiction, the Petitioners have no alternate or efficacious remedy except to
invoke the Constitutional jurisdiction of this Court on the, inter alia, facts and grounds
stated herein.
GROUNDS
A. That the Petitioners have filed this present petition for the enforcement of the fundamental
and constitutional right of the janitorial staff of the Respondent No. 2 to a minimum wage,
which petition is in the nature of Public Interest Litigation. The locus standi of the
Petitioners is based on the following reasons. Firstly, as explained in Para 2 of the Present
Petition, the Petitioners are public spirited individuals struggling for the rights of
disempowered groups and individuals in society. Secondly, as explained in Para 7 and 8
of this present petition, the Petitioners have been pursuing the issue of the right to
minimum wages of the janitorial staff of the Respondent No. 2, without any response or
remedy from the Respondent No. 2. Thirdly, the janitorial staff of the Respondent No. 2
are a suppressed and disempowered group and although they have expressed their
concerns of being denied the minimum wages to the Petitioners, they have also expressed
their fears of being terminated in case of agitation of such a demand. In short, only the Petitioners are in a position to agitate their demands for a minimum wage in such
circumstances. Therefore, the Petitioners have locus standi to file this petition.
B. That as explained in greater detail in the grounds herein below, the object and purpose of
this present petition is the enforcement of the fundamental right to a minimum wage to
the janitorial staff of Respondent No. 2. Such a right is based on the following ground (as
elaborated below). Firstly, regardless of whether Minimum Wages Ordinance, 1961,
West Pakistan Minimum Wages for Unskilled Workers Ordinance, 1969, or the Sindh
Minimum Wages Act, 2015, applies, the janitorial staff of the Respondent No. 2 comes
within the ambit of workers or employees as defined under these laws. Secondly, in view
of the settled law, as laid down by the Honorable Supreme Court, the janitorial staff of
the Respondent No. 2 cannot be denied of the minimum wage either on the ground that
they are employed through contractors or that they are only temporary employees.
Thirdly, on the principle of consistency and equality, as guaranteed under Article 25,
Constitution, 1973, it is now settled law that even if none of the aforementioned labor
laws apply, the janitorial staff of the Respondent No. 2 is still entitled to minimum wages
on the basis of Article 25, Constitution, 1973. Fourthly, one of the foundational basis of
the application of the aforementioned principle of consistency and equality is that its non-
application will lead to the violation of the fundamental right to life (Article 9), right to
equality before the law (Article 4) and right to dignity (Article 14) are and would be
irreparably violated. In short, this is the Petitioners case in this present petition.
C. That Section 36-A of the Cantonment Act, 1924, says that every officer or servant,
permanent or temporary, shall be deemed to be a public servant/public employee. In
various pronouncements of the Honourable Supreme Court of Pakistan, it has been held
that based on the principle of consistency of rule of law, and Article 25 of the Constitution
of Pakistan, it is mandatory to ensure there is no discrimination in entitlement to and
provision of minimum wages to all persons deemed to be public employees, and that they
be provided the minimum wage regardless of whether they are permanent or contractual
employees, and regardless of whether the minimum wages laws apply or not. Therefore,
it is the right of all direct and indirect employees of the CBC to be given the federal
minimum wage. Especially the janitorial staff, who are one of the most disadvantaged groups and must not be discriminated against. Therefore, this non-payment of minimum
wage by Respondent No. 2 malafide and illegal. This is a violation Article 25 of the
Constitution, which guarantees equality.
D. That as per Article 9 of the Constitution of Pakistan, every citizen has a right to life which
includes the right to livelihood and the right to livelihood is intrinsically linked with the
right to minimum wage. Therefore, it is the right of all CBC employees to be given
minimum wage. The omission on the part of Respondents No.1,2, and 3 is malafide,
illegal and in violation of Articles 9 of the Constitution, which guarantee the right to life.
Further, this non-payment of minimum wage is a violation of Article 4 of the Constitution,
which guarantees that each person shall be dealt with in accordance with the law.
E. That as per Article 9 and 25 of the Constitution of Pakistan, all public employees must be
paid at least the minimum wage. As a settled principle of law, that every unskilled worker
or laborer must be paid minimum wage, regardless of whether they are private or public
employees. This omission on the part of the Respondents No. 1, 2, 3 and 4 is malafide,
illegal and in violation of Article 9 and 25 of the Constitution of Pakistan. It is further a
violation of human dignity and therefore a violation of Article 14 of the Constitution.
Furthermore, it is a violation of Article 4 of the Constitution which guarantees that
everyone be treated in accordance will the law.
F. That without prejudice to the above, it is submitted that an establishment qualifies as an
industry if it falls within the definition from either the standpoint of the employee or the
employer or both. It further held that labor legislation is beneficial legislation which “has
to be construed liberally and beneficially”. Therefore, the non-payment of minimum wage
by Respondent No. 2 is malafide and illegal, in violation of Article 9 and 25 of the
Constitution of Pakistan as the benefits of labor legislation are not being given to the CBC
janitorial staff. It is further a violation of human dignity and therefore a violation of
Article 14 of the Constitution. Further still, it is a violation of Article 4 of the Constitution
which guarantees that everyone be treated in accordance will the law.
G. That regardless of whether an employment is contractual or permanent, the CBC janitorial
staff are deemed public employees and therefore, the Respondent No. 2 is responsible to
provide their rightful minimum wages and employment benefits. Further, as held by the
Honourable Supreme Court that all contractual labor is eligible for regularization and for
accompanying benefits including but not limited to increments, pensions and bonuses,
and that they would be entitled to back benefits from the date of their initial employment.
Therefore, the present non-payment of minimum wage, non-payment of benefits and non-
regularization of contractual employees, by Respondent No. 2 is malafide, illegal and in
violation of Article 9 and 25 of the Constitution of Pakistan. It is further a violation of
human dignity and therefore a violation of Article 14 of the Constitution. Further still, it
is a violation of Article 4 of the Constitution which guarantees that everyone be treated
in accordance will the law.
H. That without prejudice to the above, even if the CBC janitorial staff are private employees
of the contractor, they have a right to the payment of minimum wage as per provincial
law. Under Section 4 of the Sindh Minimum Wages Act, 2015, the Sindh Minimum
Wages Board recommends the minimum wage to the Government of Sindh, which
publishes the same as the minimum wage which must be met by all employers in the
province of Sindh. This notification was published as Notification No. L-11-13-3/2016
dated: 1st July 2018 and stipulates that the minimum wage for the whole of the Province
of Sindh is set at a monthly rate of Rs. 16,200/-, until updated. Under Section 9(3) of the
Sindh Minimum Wages Act, 2015, any employer who fails to pay minimum wages in
contravention of this Act is liable for imprisonment for a sentence which may extend to
six months and/or for the payment of a fine. Therefore, the non-payment of minimum
wage is a cruel omission, specifically on part of Respondent No. 2 and generally on part
of the Respondents 1 to 4 and is in violation of the human dignity of the CBC janitorial
staff. Therefore, this is in violation of Articles 9 and 14 of the Constitution, which
guarantee the right to life and human dignity. Further, this is a violation of Article 4 of
the Constitution, which guarantees that each person shall be dealt with in accordance with
law.
I. That without prejudice, if the CBC janitorial staff are to be deemed as private employees,
under Section 7(2) of the Sindh Minimum Wages Act, 2015 then the Minimum Wages
Board has the responsibility to enquire and review the disbursement of minimum wages,
and under Section 10 it is obligated to constitute and maintain an avenue of appeal which
would hear and decide all claims arising out of non-payment, or delay in the payment of
wages to workers. However, by not enquiring and taking note, the Respondent No. 3 has
failed to take note of the cruel denial of minimum wages in the present case. The
Respondent No. 3 has illegally and malafidely violated its own office through a flagrant
disregard for its responsibilities and has failed to ensure that Respondent No. 2 complies
with the minimum wage. As a consequence of this, CBC janitorial staff are forced to live
a stifled life. This is further in violation of Articles 9 and 14 of the Constitution, which
guarantee the right to life and human dignity. Further, this is a violation of Article 4 of
the Constitution, which guarantees that each person shall be dealt with in accordance with
law.
J. That under Article 18, the Constitution of Pakistan, 1973, guarantees that every person
shall be allowed to enter into a lawful profession. This inextricably includes the right to
lawful remuneration. This right stands completely violated by Respondents No. 1 to 4
who have illegally and malafidely caused the CBC janitorial staff to not access a bare
minimum remuneration for the work that they carry out. This is a violation of the right to
be dealt with in accordance with law as per Article 4 of the Constitution of 1973. This
directly affects sustenance and is also a flagrant violation of Articles 9 and 14 of the
Constitution of 1973, which guarantee life and human dignity.
K. That moreover Article 24 of the Constitution of Pakistan, 1973, clearly provides that no
person shall be deprived of his property save in accordance with law. Through the denial
of the basic bare minimum, that is, the minimum wages, the said janitorial staff is being
deprived by Respondent No. 1 of their rightful proprietary claim over their minimum
wages. That this is a further an illegal and malafide denial on part of Respondents No. 1
to 4 of the right to be dealt with in accordance with law. Therefore, it is a clear violation
of Article 4 of the Constitution of 1973.
L. That moreover, Respondent No. 1 is in violation of the basic principle of law wherein no
contract, oral or written, can be made in contravention of the law of the land. Therefore,
if the law grants minimum wages, no contract or agreement can be made in contravention
of the said minimum wage. The Respondents No. 1, 3& 4 have failed to take cognizance
of the matter and have failed to make a forum of appeal available as they were required
to do so under the law and have therefore, engaged in the grossest violation of Article 4
of the Constitution of 1973 wherein everyone has a right to be dealt with in accordance
with law.
M. That it is most respectfully and humbly submitted that the Petitioners seek the indulgence
of this Honourable Court to raise further grounds at the time of the hearing of this Petition.
P R A Y E R
It is, therefore, most respectfully and most humbly prayed that this Honourable Court may graciously pass judgment, and orders, in the following terms:
(a) Declare that the omission of the Respondents No.2 to ensure that payment to the CBC
janitorial staff of minimum wage of Rs. 15,000/- as stipulated under the Federal
Government Notification No. ADLW-2(3)/ICT/2016-657 dated: 2ndAugust 2017 [Annex
‘B’], or the Sindh Minimum Wage of Rs. 16,200/- as stipulated by the Notification No.
L-II-13-3/2016 [Annex ‘B-1’] under the Sindh Minimum Wages Act, 2015, on the
principle of consistency, is illegal, malafide, and violative of the fundamental rights of
the janitorial staff;
(b) Declare that the Federal Minimum Wage of Rs. 15000/- as stipulated by Federal
Government Notification No. ADLW-2(3)/ICT/2016-657 dated: 2ndAugust 2017 [Annex
‘B’] or the Sindh Minimum Wage of Rs. 16,200/- as stipulated by the Notification No.
L-II-13-3/2016 [Annex ‘B-1’] under the Sindh Minimum Wages Act, 2015, on the
principle of consistency, will apply to the CBC janitorial staff;
(c) Declare that the CBC janitorial staff have a right to, and entitled to be paid all wages
from the date of their initial employment as per the minimum wage effective on such
dates as prevalent from time to time;
(d) Direct Respondent No. 2 to pay all wages to the CBC janitorial staff in terms of the
minimum wages as prevalent from time to time including all wages due from the date of
their initial employment;
(e) Permanently restrain the Respondent No. 2 from denying the minimum wages to the CBC
janitorial staff during the period of employment with Respondent No. 2;
(f) Direct the Respondent No. 2 to individually and Respondent No. 1, 2, 3 and 4 to jointly
submit Compliance Reports regarding the payment of minimum wages to the CBC
janitorial staff (including all wages which have been due since their initial employment)
on a monthly basis to the Honourable Hight Court of Sindh, for a period as determined
by this Court;
(g) Permanently restrain the Respondents, or any person acting on their behalf, from taking
an adverse and/or coercive action against the janitorial staff working for Respondent
No.2, including but not limited to, termination of services of the janitorial staff on the
purported basis of non-payment of minimum wages, including all dues of the minimum
wages from the date of their initial employment;
(h) Grant such further, additional or alternative relief, as this Honourable Court may deem fit
and proper.
PETITIONER NO.1
PETITIONER NO.2
PETITIONER NO.3
PETITIONER NO.4
PETITIONER NO.5
PETITIONER NO.6
PETITIONER NO.7
ADVOCATE FOR THE PETITIONERS
Karachi;
Dated: ______, 2019
DOCUMENTS FILED: As shown in the Petition
DOCUMENTS RELIED UPON: The abovementioned documents e.t.c.
ADDRESS OF PETITIONER: As per in title of the petition ADDRESS OF PETITIONER COUNSEL: Faisal Siddiqi Advocate 14-C, 4th floor, 21st Street Khayaban-e-Sehr, Phase V, DHA, Karachi. DRAWN BY ME
ADVOCATE