Article-213[ Regarding making of samples of of affidavit and Writ Petitions by Al ChatGPT whose Appeals are remanded back to High Courts]

 Article-213

نوٹ :جن ساتھی دوستوں کی اپیلیں سپریم کوڑٹ نے اپنے  10 جولائی 25 کے فیصلے میں ھائی کوڑٹوں کو ریمناڈ بیک کا تھیں کے انکو  گورمنٹ والے پنشنری بینیفٹس  اپروو کئیے جاتے اگر متعلقہ ھائی کوڑٹیں یہ ثابت کردیں کے ے جب یہ  ٹی اینڈ ٹرانسفڑڈ ھوکر کاپوریشن  آرھے تھے تو یہ سول سرونٹ  تھے( تفصیل میں نے Article-212 میں لکھی ھے )  تو ایسے پٹیشنرز کی Applications/Petitions کے ڈرافٹ چاٹ جی پی ٹی نے تیار کئیے ھیں جو نیچے پیش کئیے جارھے ھیں  اگر وہ چاھیں تو اپننے  اپنے وکیلوں سے اسکی توثیق کراکر  عدالت میں جمع کرا سکتے ھیں۔شکریہ

(طارق)

16-7-25

Certainly. Below is a sample petition/application draft in English for filing before the High Court by a petitioner whose CPLA has been remanded back by the Supreme Court (as per the judgment dated 10 July 2025)—for determination of civil servant status at the time of transfer from T&T to PTCL in 1991.

This draft is formatted as an Application Under Direction of the Supreme Court for adjudication of status under remand.

⸻

IN THE HONOURABLE HIGH COURT OF [Insert Province]

(Original Constitutional Jurisdiction)

Civil Miscellaneous Application

Under the Directions of the Hon’ble Supreme Court of Pakistan dated 10.07.2025

In Re: Remanded CPLA for Determination of Civil Servant Status

⸻

In the Matter of:

[Petitioner’s Full Name]

Son of [Father’s Name],

Resident of [Complete Address],

CNIC No. [XXXXX-XXXXXXX-X]

…Petitioner

VERSUS

1. Pakistan Telecommunication Company Limited (PTCL)

Through its CEO, G-8/4, Islamabad

2. Pakistan Telecommunication Employees Trust (PTET)

Through its MD, PTET HQ, G-8/4, Islamabad

3. Ministry of Information Technology and Telecommunication (MoITT)

Government of Pakistan, Islamabad

…Respondents

⸻

APPLICATION UNDER DIRECTION OF SUPREME COURT FOR DETERMINATION OF CIVIL SERVANT STATUS OF THE PETITIONER AT THE TIME OF TRANSFER FROM T&T TO PTCL IN 1991

⸻

Respectfully Submitted:

The Petitioner above-named most respectfully submits as under:

1. That the petitioner was initially appointed in the Pakistan Telegraph and Telephone Department (T&T) under the Ministry of Communications, Government of Pakistan, on [Date], in Basic Pay Scale (BPS)-[XX] under the rules of the Civil Servants Act, 1973.

2. That the petitioner served as a Federal Government civil servant, and was drawing salary from the Federal Consolidated Fund, with all entitlements as per Civil Servants Act, 1973.

3. That pursuant to the Pakistan Telecommunication (Reorganization) Ordinance, 1991, the petitioner was transferred to Pakistan Telecommunication Corporation (PTC), subsequently PTCL, without any fresh appointment or resignation. The transfer preserved continuity of service and pension rights.

4. That the petitioner never relinquished civil servant status, nor signed any contractual employment terms with PTCL that altered their original service terms under government law.

5. That after retirement, the petitioner has been denied the periodic pension increases granted by the Federal Government, despite being legally entitled under the judgments of the Hon’ble High Courts and now affirmed by the Supreme Court of Pakistan in its judgment dated 10 July 2025, dismissing the CPLAs filed by PTCL and PTET.

6. That the Hon’ble Supreme Court has remanded certain CPLAs, including that of the present petitioner, for factual determination by this Honourable Court as to whether the petitioner was a civil servant at the time of transfer in 1991.

7. That the petitioner now submits this application along with an affidavit and documentary evidence in support of their civil servant status, including:

• Appointment order under Federal Government;

• Service book entries and salary slips;

• GP Fund deduction record;

• Notification of transfer under 1991 Ordinance;

• PPO/Retirement documents.

8. That the petitioner respectfully requests this Honourable Court to adjudicate and declare, based on the evidence, that:

• The petitioner was a civil servant as defined under the Civil Servants Act, 1973 at the time of transfer;

• Accordingly, the petitioner is entitled to pension benefits and increases as announced by the Federal Government periodically.

9. That the interests of justice, equity, and constitutional protections under Articles 9 and 25 of the Constitution demand that the petitioner not be arbitrarily deprived of rights lawfully accrued by virtue of Federal service.

⸻

PRAYER

In view of the above, it is most respectfully prayed that this Honourable Court may kindly:

a) Adjudicate and declare that the petitioner was a civil servant at the time of transfer from T&T to PTCL in 1991;

b) Direct the respondents, particularly PTET and PTCL, to revise the petitioner’s pension in accordance with the increases announced by the Federal Government, from the date of retirement to the present;

c) Grant any other relief that this Honourable Court deems just and proper in the circumstances.

⸻

Petitioner

(Signature)

[Full Name]

Through:

[Name of Advocate]

Advocate High Court

[Law Firm, if applicable]

[Contact Address and Phone]

Date: ___________

Place: ___________

Certainly. Below is a sample affidavit in English that a petitioner can submit in the High Court to support their case—specifically to prove that they were a civil servant at the time of their transfer from T&T to PTCL in 1991. This affidavit should be signed, attested, and accompanied by relevant documents.

SAMPLE AFFIDAVIT

(For Establishing Civil Servant Status at the Time of Transfer from T&T to PTCL)

IN THE HONOURABLE HIGH COURT OF [Insert Name of Province]

(Civil Original Jurisdiction)

AFFIDAVIT OF PETITIONER

I, [Full Name of Petitioner], son of [Father’s Name], CNIC No. [XXXXX-XXXXXXX-X], resident of [Full Address], do hereby solemnly affirm and state as under:

1. That I was appointed in the service of Pakistan in the 

Pakistan Telegraph & Telephone Department (T&T)

 under the Ministry of Communications, Government of Pakistan, on 

[Exact Date of Appointment]

, against the post of 

[Designation]

, in 

Basic Pay Scale (BPS)-[X]

, through a regular selection process, in accordance with the 

Civil Servants Act, 1973

 and the rules framed thereunder.

2. That my appointment was made under the administrative control of the 

Establishment Division

, and I was treated as a 

Federal Civil Servant

, enjoying all rights, protections, and benefits guaranteed under the Civil Servants Act, 1973.

3. That I served in the T&T Department continuously until the promulgation of the 

Pakistan Telecommunication (Reorganization) Ordinance, 1991

, whereby employees of T&T were transferred to 

Pakistan Telecommunication Corporation (PTC)

, later succeeded by 

PTCL

, without any break in service.

4. That I was 

transferred

 to PTCL under the said Ordinance in 

[Month, Year]

, 

without being required to resign or reapply

, and my service continued with full recognition of my earlier status and seniority as a government servant.

5. That I never executed any fresh contract with PTCL relinquishing my civil servant status or waiving off my pensionary rights under the Federal Government rules.

6. That my pension has been sanctioned by PTET/PTCL, but 

without the periodic increases and benefits announced by the Federal Government

, to which I am legally entitled as per the judgments of the Honourable Supreme Court of Pakistan, including the recent judgment dated 

10 July 2025

.

7. That I am submitting this affidavit in compliance with the directions of the Honourable Supreme Court to establish my 

status as a civil servant at the time of transfer to PTCL

, and I request this Honourable Court to examine the enclosed documentary evidence in this regard, which includes:

• Copy of my initial appointment order in T&T Department;
  
  
• Copy of my service record / service book indicating service in BPS under Federal Government;
  
  
• Copy of salary slips before and after transfer showing pay under Federal Pay Scale;
  
  
• Copy of GP Fund record / deduction slips;
  
  
• Copy of the official transfer notification issued under the 1991 Ordinance;
  
  
• Copy of Pension Payment Order (PPO) or retirement notification.
  
  

8. That I reserve the right to file additional documents, affidavits, or request the Court to summon official records from PTCL, PTET, Ministry of Information Technology, or Establishment Division to further support my claim.

9. That all the contents of this affidavit are true and correct to the best of my knowledge, belief, and information, and nothing material has been concealed.

Place: ___________

Dated: ___________

DEPONENT

(Signature of Petitioner)

Verification:

Verified on oath at ___________ on this ___ day of ___________, 2025, that the contents of the above affidavit are true and correct to the best of my knowledge and belief.

DEPONENT

(Signature)

Notes for Submission:

• Attach all supporting documents as Annexures (A, B, C, etc.).
  
  
• Have the affidavit attested by an Oath Commissioner or Notary Public.
  
  
• Include this affidavit with your written statement or application before the High Court.