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IN THE SUPREME COURT OF (Ori1!inalJ urisdiction)

loRe:

Constitutional Original Petition No. /2007

Chief Justice of Pakistan (on forced leave), Mr. JusticeIftikhar MuhammadChaudhry, Chief JusticeHouse, Islamabad. ...Petitioner VERSUS

The President of Paldstan, The ReferringAuthority, Presidency, Islamabad. AND OTHERS Respondents

AFFIDAVIT bF Lt. Gen. (Retd.) Hamid Javaid son of Ch. Muhammad Ashraft Chief of Staff to the

I. I, Lt Gen(R) Hamid Javaid son of Ch Muhammad Ashraf, presently working as Chief of Staff to the President of Pakistan, do hereby solemnly state on oath as under:- II I y.lasappointed as Chief of Staff to the President on I November 2002, and have continued to work in that position todate. I ) ,t..

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.4 As Chief of Staff to the President, my responsibilities include coordination of all activities related to the President'soffice work.

That I have read the affidavit filed by Mr. Justice Iftikhar Muhammad Chaudhry, Chief Justice of Pakistan (on forced leave) ("CJP") and all adverse allegations made therein unless specifically admitted herein below are herebydenied.

I say that as per official record, Mr. Justice Iftikhar Muhammad Chaudhry, Chief Justice of Pakistan (on forced leave) ("CJP") made ten fonnal cans on the Presidentof Pakistan.The CJP himself desired all these meetings. The details of the meetings between the Presidentof Pakistanand Mr. Justice Iftikhar Muhammad Chaudhry both as Judge of the Supreme Court and CJP are given below: -

~ ~ ~!!dl!e of SS:F-

07-10-2004 Army House 07-05-2005 ~ Camp Offi

As-'-" CJP 04-10-2005 Army House 16-12-2005 Camp Office 1.7-12-2005 Aiwan-e-Sadr 19~05-2006 Camp Office 01-06-2006 Army House 04-10-2006 Army House 13-02-2007 Aiwan-e-Sadr 09-03-2007 Camp Office

2.4.3. 3 '3 l !'4

Th.a.tbes.ides the above formal meetings the CJP and the Presidentinteracted frequently on a number of state and!social functions at the Aiwan-e-Sadr, Camp Office and GHQ.

The: Federal Government received 8! number of complaints againstthe CJP.

The Federal GoverJ1mentprepared a draft Reference against the CJP for filing the same before the Supreme Judicial Council ("SJC").

Deulils of the draft Referenceand the Code ofCohduct for Jrudgeswere brought to the notice of the President by 1the Prime Minister on 7 March 2007 in my pres(~nce.

8. The next day on 8 March 2007, the President's Secr<~tariatreceived a summary containing advice of the Prime Minister to the President to make a Reference against CJP to the SJC under Article 209 of t;f1eConstitution.

The Prime Minister advised that the CJP be "restrained" and also that the most senior available Judge of the Supreme Court of Pakistan be ~ppornt~~ as Acting Chief Justice of Pakistan under Article 180 of the: Constitution, as it would not be in the public intere:)t, nor in consonancewith the norms of judicial propriety, that the CJP continues to perform functions of his high judicial office while the SJC was condulctingan inquiry into allegations against him for misconduct.

10. On 8 ~...rarch2007 the CJP rang the Military Secretary to the Pre:sident("MS"), requesting an urgent meeting with

5.6.7.9.'~!' I ;~, 4 ~ 4

tllie President. The President was due to leave for Karachi on 9 March, to participate in the Pakistan Navy exercise "l\.man 2007". The MS explained this position to CJP but as the CJP insisted on thc: meeting, the MS stated that he would do his best to fe-adjust the schedule. Later, after having re-adjl,1stedthe schedule the MS told the Deputy Military Secretary (OMS) to iluorm the staff of the CJP ac(;ordingly. The OMS later confirmed to the MS that this had been done. The appointment was accordingly set for 11:30 a.m. on 9 M'4i"ch2007.

Jl. The CJP arrived at the President'sCamp Office at 1135 a.ml. on 9 March2007. The C.JP did not come to Army House to meet the President, as stated by him in his affidavit. The meeting took place in the President's Secretariat's Camp Office, I{awalpindi, in which the Pre:)identand his staff hold office.

12. The CJP had a one on one meeting with the President startingat 1 I :45 a.m., with only tile MS present.The ADC was not present in this meeting as stated in ~e CJP's affidavit. There is only one photographerand one TV cam(:ramanstationed at the Camp Office to cover the routilnecalls/meetings of the President.It is incorrect that a number of TV cameramenand photograpnerswere usheI-edin, as stated in the CJP's affidavit. The CJP first brief(:dthe Presidentin detail for about20 minutes on the following events:-

a. SAARC Law Conference. b. SAARC Chief JusticesConference. c. GoldenJubilee ceremonyof the SupremeCourt of Pakistan. , 6 6

ChairmanCBR and to persuadehim to convey a favourable impression in this respectto the Presidency.The Chairman CBR infonned me that when he enteredthe Chamberof the CJP the latter was on telephone.After completing' the phone call he informed the Chairman CBR that he was speaking to the MS and had requestedan appointmenton 9 March 2007 for a call on the President.The CJP impressedupon the ChairmanCBR that as his appointmentfor a call on the President was likely, it was imperative that the Chairman CBR conveyed his clarifications.to the Presidentimmediately. The CJP said that this was necessaryas it was somewhatembarrassing to explain one's own case in a detailed manner.The ChairmanCBR promisedto convey CIP's clarifications to the Presidency,which he did to the cas the same day.[See: Affidavit by Abdullah Yousaf, Chairman CBR]

b. CJP also telephoned Major General Mian Nadeem Ijaz Ahmad, DC: MI on 8 MarcJ1-2007 at night to seek his a:, istance and support regarding complaint filed against him by Mr. Justice Jehanzeb Rahim of the Peshawar High Court. He informed the DG MI that he had sought an appointment for a call on the President which had beer confirmed to take place on 9 March 2007 at ll30 lu"Sand that it would be appreciated if D: J MI could also be present in the Camp Office to s~pport the CJP. [See: Affidavit ofDG Mil.

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0' f I I (ii) From the" foregoing it is clear that 1he issue of complaint filed by a servillg Judge of the Peshawar High Court against the CJP was not raised by the " President but by the CJP which apparently was the

primary purpose of his call on the President. J

14. After the CJP had concluded his foregoing points, the President observed that in his last meeting with the CJP at i\iwal1-e-Sadr Qn 13 FebruarY,j2007, tl1e CJP had, requested the President to ask the intelligence a~encies to .., assist tl1e CJP in suppressin,i'ithe media reports which were tarnishing his image. The President also told tl1e CJP tllat he was informed that tl1e DO MI and DO IB had also been called individually several times by tl1e CJP at his residence for similar assistance. The DO ISI, was also called at his residence once for tl1esame purpose.

IS. Based on the CJP's own request, the intelligence agencies caLrriedout a discreet fact finding probe.

16. The President informed.. the CJP tJlathe has had the best of reilatiotJswith the CJP and he held him in high esteem and he was, therefore, pained to learn about the findings of tile ~, intelligence agencies.

17. Thereafter, the President drew his attention to the main points of the Reference received by him.

18. The affidavit of tl1e CJP conveys an impression as if the President did not have any consolidated document but only a few pieces of p~pers based on the letter written by Mr. N~eem Bokhari. This statement is incorrect as the Reference from the Prime Minister along with advice to the Presidenl was received on 8 March 2007 and tile President had jotted down points after reading it. The 8.

."'" President's notes consisted of points related to the Reference and not points based on Naeem Hokhari's letter, as statedin the affidavit of CJP.

19. The President mentioned these points to the CJP. Notwithstanding his personal cordial relations with the CJP,the Presidentwas bound by the advice received from \ ?;Jt' the Prime Minister and hadno discretionin the matter.

20.' The CJP denied having approachedany body for any undue favour in the Governmentin connection with the career of his son. However, when reminded that he had approachedboth the Presidentand the Prime Minister, as w~:ll, for this purpose,the CJP readily acceptedthe same but stated that he had done the same considering the Pn~sidentas his elderbrother.

21. The CJP mentioned that he had always extended cooperation to the Government .and would remain cooperative in future as well. He said that he did not acceptmost of the other pointsand insisted that he would like:to know the ,details.The Preside~t,thereafter, told the CJP that the details could be discussedin the presenceof the intelligence heads.who had also been asked by the -. CJP himselfto find out the details.The CJPhad extremely good relations with the intelligenceheads. most of whom he met frequently. He. therefore. wanted to meet them. The Prime Minister joined the meeting at that stage. Thereafter. .at 1300 hours. the deponent and the intelligenceheads. joined the meeting.

22. Dets,ils of the Reference and the salients of the intelligenceprobe initiated at the requestof the CJP were threreafterdiscussed. The initial information received by the ]?ederalGovernment through the intelligence probe 9

'..11.. I and other sources proved correct on subsequent verification tllld counter-check. Details are as follows:

(A) Allotment of Plot in Karachi

(a) Judges of the Superior Judiciary were not eligible for allotment of plots in Federal Government Employees Housing Scheme, Phase-II, Karachi, launched in February 1999, which waS meant for Federal Government Employees with minimum of 10 years regular Federal Government Service on 1 January 1999. The expression "Federal Government Employee" was clearly defined to include only civil servants as defined un

(b) In violation of the said eligibility criteria, CJP. t !'.. who was not even a Judge of the Supreme Court on I January 1999, applied and obtained a plot ill tile said scheme. [See: (i) Application of CJP for allotnlent of plot and (ii) Proof of

Allotment} --10 -.

(c) It may be stated that in his Gapacityas a judge he had alreadybeen al1otted a plot in Islamabad.

(B)

(a) The CJP submitted numerous claims and received cash worth hundred of thousandsof I{upees~or reimbursement of petrol for car No. ' CIA-9 on .the basis of receipts, purportedly issued by a Shell Pump (Abdu,lah & Sons) at Sumungly Road, . All the receipts are bogus. The pump, at all material times, only sold diesel. It

(b) CarNo. CIA-9, a HondaAccord was actually in uSenot 'at Quetta but at Islamabadas a family car for theCJP.

~ (c) The CJP's son Dr. Arsalan Iftikhar, a governmentservant was in the meantime using another Honda Accord car No. CIA-2 at Lahore. Petrol for this vehicle was also being paid for by the SupremeCourt. Dr. Arsalanwas drawing petrol for this car on Sup.remeCourt couponsfrom a Caltex Pump (Kakasian Autos) at QueensRoad, Lahore. Petrol was filled in vehicle CIA-2 while the endorsementon the COuponswas for vehicle RegistrationNo. IDL- 9966. {See: Affidavit of Mr. Ali Ahmad, II

-Manager, Kakasian Autos, Lahore and SampleBills]

(C) Jrreeular T A Claims

(a) CJP claimed hundredsof thousandsof Rupees as TAIDA for his family members in violation of the relevant Rules. On a number of occasions, reimbursement of airfare was claimed for wife and children, in spite of the fact that they were not officially entitled. The wife of the CJP is entitled to TA only whenshe is accompaniedby CJP and the duration of the stay exceedsfive (5) days. Children are not allowed T A evenif accompaniedby CJP,as per Rules.

(b) CJP evenclaimed DA for himself for a private visit to Nathiagaliin June,2006.

(c) The claims were submitted and payment , received by the CJP under his own signatures.[See:(i) Certificate by the Office of AGPR, (ii) TA bill of family members -of .' CJP, (ill) T A bill of CJP for visit to Nathiagali (iv) T A bill of CJP and wife and (v) Summary)

(D) llil2to Nathia!!ali

(a) jDuring a private trip to Nathiagali, CJP and his j:amily forcibly occupied the Governor House {;m 17 June 2006, without reservation and uespite the fact that the House was already 12

bookedfor former GovernorK. M. Azhar w.e.£. 17 June 2006 and thvt the same had been conveyedto the PersonalStaff Officer of the CJP,a day earlier, on 16June 200&. The former Governorwas requestedto delay his arrival by one day.

(b) The CJP and his family refused to vacate the premises even the next day when the fonner Governorand the other dignita.ies arrived and also did not allow them to usethe toilet.

(c) Despite all this the CJP and his family left the place annoyed. [See: Affidavit by Lt Co) Saeedullah,MS to Governor NWFPj

(E) Harassmentof Judl!cs

(a) CJP orally ordered Mr. Jllstice Akhtar Shabbir and, Mr. Justice SheikJI Abdul Rashid of Lahore High Court not to corne to court tili their retirement. Mr. lustice Sheikl1. Abdul Rashid accordingly did not attend office till his retirement.

(b) CJP launched a campaign of indiscreet character assassinationagainst a number of judgesof the High Courts.

(c) The CJP wantedto initiate proceedingsin the SIC for misconduct against a number of judges of the Lahore High Court as well as of the High Court of Sindh and the Peshawar High Court. The Federal Government, 13

however, had nothing against them. These judges included:

~ore Hil!h Co!!!:,!

(i) Mr. JusticeAbdul ShakoorPiracha (ii) Mr. Justice ShabbarRaza Rizyi (iii) Mr. JusticeAkhtar Shnbbir (iv) Mr. JusticeSheikh Abdul Rashid

Hieh'Court ofSin@

(i)

Mr. Justice MushirAlam

(iii)

Mr. Justice Amir Hani Muslim

Mr. Justice Afzal Soomro

&$hawar Hil!h ~o-!!!!

(i) . Mr. Justice Shah JehanKhan

(ii) Mr. Justice"Ejaz uf.Hassan Khan ~ (iii) Mr. Justice JehanzebRahim

(F)

(a) His insistence on appointment of judges of his choice, in complete disregard to the recommendations of the other constitutional consultees, created an impasse, resulting in a large number of vacant posts in the High Courts of Punjab and Balochistan, which adversely affected the working of these 14

courts. Lahore.High Court is, thus, short of seventeen(17) judges while Balochistan is short of three (3) judges. A total number of [.1' seven (7) appointmentsto the High Court of Sindhwere also pendingwith the CJP.

(b) He agreed, ill his meetings with the Governor

Balochistan and CJ, Balochi:.tan High Court (Constitutional Consultees) on appointment of certail:Jjudges to the BHC, but later refused to honour the mutual understanding. The Governor reported this to the President in his letter on 10 February2007.[See: Governor Balochistan's letterj

(G)

(a) The CJP insisted that the previous Chief Justiceof FSC Mr. JusticeCh Ijaz Yousaf be retired: He laterpressurized Mr. JusticeNasim Sikandar, Judge Lahore High Court, to withdraw his nomination after he had -been notified as CJ of FSC. The post of CJ FSC remainedvacant for a considerabletime.

(b) Finally, following the appointment of Mr. Justice Haziqul Khairi the current CJ FSC he insistedon forcing uponthe new CJ,judges of his own (CJP's) choice. The CJ FSC refused to acceptthis and threatenedto resign. The C1P,thus, createdan impasse,which resulted in an incomplete and dysfunctional Federal ShariatCourt for severalmont~s. .15 :~;i

o~

The CJP summonedAdditional Chief SecretaryMr. K~ushnood Lashari and later Chief SecretaryMr. !;ta', Kamran Rasool and made them wait for hours on }, being provided a Mercedes Benz car of an older f model.He wantedMercedes car of latestmodel. The ! two officers were pressurized to immediately Suspendfrom service, Mr. Mushtaq Hamdani, DG (Protocol), Punjab, for this alleged lapse. Mr. Hamdani saved his skin only after tendering an unconditionalapology. (See: Unqualified apology tendered by Lt Col (R) Mushtaq Hussain Hamdani, DG{Protocol) Punjab and Affidavit by Mr. Khushnood Akhtar Lashari, former Additional Chief SecretaryPunjab).

(I)

(a) While passing tllrough Hyderabad, enroute to

Sukkur, .the CJP got extremely annoyed with DPO, Hyderabad, Mr. AJi Ahm~d Junejo, for not being personally present to escort him. ,.,

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(J) Interference in Administration~~---;

During a private visit to Pishin with his family, the CJP orderedthe DPO, Mr. Amil ShamimWynne, to immediatelypromote his personalorderly, Constable Abdur Rehman. The DPO submitted that the Constable did not meet the requisite criteria and could not be promoted under the rules. The CJP, however,insisted compliance of his directionsbefore end of the day. The DPO eventually, had to oblige, the same day, under pressure of the CJP. [See: Affidavit by Mr. Ami) Shameem Wyne, former DPO Pishin]

(K) Self Projection

Hi!!" Visihilit~0" Media

(a) The CJP, unlike the former Chief Justices of Pakistan, who generally spoke through their judgments, desireda lot of self-projectionand .- especially employed an officer to arran~e specialmedia projectionfor him. The PRO was tasked to ensure prominent reporting of CJP's activities in all newspapersand the electronic media.

(b) PTV was ordered to ensure that the CJP was given daily coveragein the news prominently. [See: Affidavit by Mr. Khalid Bilal, former PRO Supreme Court of Pakistan)

~Icer/l with Protocol 17

(c) The CJP used hooded and armed security guardswhose presence created harassment and panic for citizens at airports and public places uponhis arrival.

(d) Deeplyconcerned with protocol, tJle CJPwould insist in writing on provision of cars of his choice (Mercedes or BMW) at the places he was visiting, evengoing to the extent of asking for police escorts consisting of personnel nominated by him. More recently he also ordered sealing of all traffic during his movementin Islamabadand other cities. [See: (i) Affidavit by Mr. Muddassir Iqbal, DG(Protocol), Sindh (ii) Affidavit by Mr. Zia-ul-Hasan Khan, former IG Punjab (iii) Affidavit by Mr. Mushtaq Hussain Hamdani, DG(Protocol) Punjab and (iv) Supreme Court's letters dated 20 August 2005, and 22 March, 20 April, 21 October and 7 December2006J , '.:."':"

,is

Affidavit by Mr. Jebangir Mirza, for-mer I.G SindbJ;

Penchantfor E_~DensiveCars

(f) Two Honda Accord cars were purchasedfrom Governmentfunds, in relaxation of rules, for protocol duty for a 2-day conference,at a cost of Rs. 60 lacs. Thesecars have since then been used by CJP's family and son at Islamabadand Lahore for purely private and personal use. CJP's son Dr. Arslan Iftikhar who was using one of thesecars (CIA-2) in Lahore drew petrol on SupremeCourt Account againstRegistration NumberIDL-9966. [See: (i) Affidavit by Mr. Safdar Ali, Constable (ii) Affidavit by Mr. Muhammad Naeem, Assistant Incharge (Security Guard), (iii) Affidavit by Mr Murravat Bari, Incharge Security and (iv) Affidavit by Ali Ahmed, M3;nager, Kakasian Autos, Lahore]

23. Besidesthe above information a large number of 'other ~ complaints were received by the Federal Government againstthe CJP.

24. In his affidavit, the CJP has tried to create an impression as ij' the Mercedes Car in his use had been sent by the Priltle Minister of his own volition. To the contrary, CJP obtaiined the said car by exerting maximum pressure.

25. Und(~rthe SupremeCourt Judges (Leave, Pension and Privileges)Order, 1997,a Judge is entitled to the use of only one official car (1600 cc), subject to fuel limit of 400 Mitresper month. (Article 21). [See: Statement of Mini!;try of Law, Justice & Human Rights] 19"

26. The Mercedescar in the use of the then Chief Justice of :Pakistanin 1997 was surrenderedby his successorMr. Chief JusticeAjmal Mian in March 1998. who also laid down guidelines that in case of shortage of Cars in the S;upremeCourt Car Pool, the Honourable Judges would s]llarethe: available cars but in no case the Court would rt~questthe Cabinet Division for providing cars to any oj:'the Judgesof the SupremeCourt at Islamabad.[See: Sllpreme Court's Order regarding use of official tr:~nsportJ

27. Contraryto the aboverules/guidelines, Mr. JusticeIftikhar MtlhammadChaudhry pressurized the Principal Secre~ to 1J1ePrime Minister Mr JavedSadiq Malik for provision of a MercedesBenz car from the pool of the Cabinet , Di\"ision, which wasprovided in July2005.

28. Being dissatisfied with the 1993 model car, CJP soon started agitating for its replacementwith a 2004 model Mer~~edesBenz car. He keptpressing the matter till Prime Minister's approval. for replacementof the car in February 2006. (See: Affidavit by Mr. Javed Sadiq Malik, former PSPM] - 29.

f

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intellig,encechiefs were askedto join the meeting when the CJF'so desired.

30. Throughthe affidavit, an attempthas beenmade to create an impressionthat CJPwas madeto stay at the President's Secretariat,Camp Office, , against his will. The contentsof the CJP's affidavit are self-contradictory. He on 1:heone hand has statedthat an officer, "prevented the exi1:of the deponent"and on the other he has stated that he was kept at the CampOffice "on one pretextor the other".

31. As a routine security measure, persons visiting the Presidentare requestednot to carry mobile phones with them. The CJP,however, during the courseof the day had a messageconveyed to his Staff Officer that his family be informed that his programmeto go to Lahore had been cancelle:d.The messagewas duly communicatedby the Staff Officer. It is, therefore, incorrect that the CJP was held iru;ommunicadoand against his will at the Camp Office. By distorting the facts and relying mostly on conjecturing, a very misleading pictUre has been portrayed,which is far from the truth.

The fact of the matter is that CJP went to call on ~the President on his own request. He even asked DO MI to be- present there to support him. Earlier, he had met the DG IB and DG ISI and had sought their support. The CJP enjoyed cordial relations with all the intelligence chiefs who we:re present. Personally no one bore any ill will towards him. He and his family were on visiting terms with the: DG lB. The DG MI and CJP spoke frequently and the ;[ormer visited the latter, at his residence, a number of time:). The environment during the entire duration remainelj polite and the decorum was maintained at all

32. 21

times. No one threatenedthe CJP. No one coercedhim to write out a resignation.Resignation in such situations is always an option. The CJP chose to face the Reference. [See: Affidavit of Brig (Retd.) Ijaz Ahmad Shah, DG IB].

At the peI"Sonallevel the CJP enjoyed excellent relations with al:l who mattered including the President. The Presiden:twas, however, obligated underthe provisionsof the Con~)titutionto makethe Referenceafter he had been so advisc~d.

34. When tl1leCJP wanted to have the details of the points raised, 1:heintelligence chiefs were called in, at his request.The President,the Prime Minister, the cas to the Presiden1tand Military Secretaryto the President left at 1400 hrs and the Chief Justicestayed behind for further di~cussionswith the Intelligenceheads with whom he had cordial relations. The entire file of the reference with supporting documentsand intelligence information in severalf<)lders remained available and a lot of time was consumedas the CJP discussedthe matter in detail with , those present.The DG IB and DG ISI also left at 1500 hours. T:he CJP remained with the DG MI till his .. departure;,the latter went to see him off till his car. While. with the ;OG MI, the CJP kept discussingthe Reference and the possibility of anothermeeting with the President which could not be arranged.[See: Affidavit of Major Generall~an NadeemIjaz Ahmad, DG MI].

35; the statelment in the affidavit of CJP that any special plane was: made available for the Chief Justice, Lahore High Coul1 is incorrect.

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36. It may. also be stated tlmt the President usually is In unlfornrl.The meetingwltll the CJP was scheduledon the insistence of the CJP for 9 March 2007 after re-adjusting .the schedule of the President. This, as stated above was done on 8 March 2007.

37. The CJP has also given the impression that he was for severaldays, held incommunicadoat his residencewhere his tel~:phonelines were disconnectedand the mobile phonesof his family membersjammed. This is incorrect. From 5 p.m. on 9 March 2007 till 13 March more than three hundredand fifty calls were made/receivedfrom/on the mobile phone of his son. Amongst others Mian Mohammad Nawaz Sharif also called on this mobile line.[Sele:The News, press clipping]. The land line was also in IJSeand in additionto the local calls which are not recorded in the exchange,a number of outstation and mobile Jphonecalls were made. [See: Toll data of phone

companiies)

38. Mindful of the dignity of the high office of tile CJP and given it1;esteem for the institution of the judiciary, it is with col1lSiderable~eluctancethat the aforementionedfacts have bel~nraised. This course has now been reluctantly adoptedmerely to bring the facts on the record. Th1shas beendone becausethe CJPhas filed an affidavit which is incorrec1:in materialparticulars and statementshave been madeby counselboth in and out of court that as the CJP's affidavit remainsunrebutted it mustbe deemedtrue.

II. That whateverstated hereinabove is true and correct.

DEPONENT 23

~RIFICA T]~

Verified on oa'ththis dayof June,2007 at Islamabadthat thetru~ contentsof th~:above affidavit are and correct to the best of my knowledge, be:lief and infonnation and nothing has been concealed thereinfrom this'Hon'ble Court.

DEPONENT

Solemnly affirmed before me this day of June 2007 at Islamabad by the Deponent named above who is known to me personally.

COMMISSIONERFOR TAKING AFFIDAVITS

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