BEFORE THE CHAIRMAN NATIONAL
ACCOUNTABILITY BUREAU, ATTATURK AVAENUE, ISLAMABAD
Mst. Naseem Malik Widow of Malik
Muhamamd Nasim R/o House # 739, Near Masjid Abu Huraira, Sabzazar Colony, Bosan
Road Multan. (Petitioner)
ACR No. 27/2008
State Vs Hameeda Ejaz etc
APPLICATION U/S 25(II)
OF NAB ORDINACE 1999 FOR VOLUNTARY RETURN/PLEA OF BARGAINING A SUM OF RS.
29,490/- FOR RELEASE OF ACCUSED/ PETITIONER
Respectfully
Sheweth,
1. That
the above captioned reference has been filed against the petitioner and others which
is pending adjudication in the court of Mr. Muhammad Ibrahim Asghar, Judge Accountability
Court Multan. Wherein the next date of hearing is 13-11-2014.
2. That
the formal charge against the accused and the others have been framed.
3. That
at page # 2 of the reference (supplied by prosecution), the petitioner, Hameeda
Ejaz accused # 1 (since accepted plea bargain) and Muhammad Nawaz accused # 8
(since died) were held responsible for a total amount Rs. 69, 180/-.
4. That
at page # 3 of the reference the cases of misappropriation mentioned at serial
# 1-3 belongs to the petitioner and other co-accused, have already been paid prior
to the investigation /enquiry of this reference as admitted in the reference.
5. That
yourhonour has accepted the plea of bargain of two others accused of the same
reference i.e. Hameeda Ejaz and Rana
Nasir Ali with the approval of EBM on 02-12-2009, in consequence thereof both
the accused has made payment of Rs. 39,090 and 25,880 respectively.
6. That
Mst. Hameeda Ejaz (Co-accused of reference) has already paid Rs. 10,199 on
account of charge in relation of payment of Altaf Begum PTC. That accordingly
detail of schedule with regard to petitioner and other is as under.
|
Sr. No
|
Teacher
|
Token #
|
Amount
Rs.
|
Accused Liable
|
Liability Payable by petitioner
|
|
1.
|
Ghulam Haseena
|
2566/20/5/1996
|
38,583/-
|
3
& 8
|
19,291/-
|
|
2.
|
Altaf Begum
|
2565/20/5/1996
|
30,597/-
|
1,
3 & 8
|
10,199/-
|
|
|
|
|
TOTAL
|
29,490/-
|
7. That
in view of the above liability fixed by prosecution, a sum of Rs. 29,490/- is
payable by the accused in case of return of money voluntary to the NAB.
8. That
the petitioner by understanding all the consequences mentioned in section 15 and
25(ii) of NAB ordinance 1999, voluntarily wants to pay the amount determined by
the prosecution or now by your goodself, with the approval of honorable Accountability
court Multan for purpose of release / discharge of the petitioner.
9. That
under principle of equality before law and equal treatment before the law as
enshrined in constitution of Pakistan, the petitioner also deserve the same
treatment/ opportunity as provided to the other accused i.e. Mst. Hameeda Ejaz and
Rana Nasir by accepting this application.
10. That
the petitioner is a widow, chronic patient of Heart, debaties, and blood
pressure. The petitioner is facing this enquiry investigation since 1998 before
ACE Multan, NAB and trial court. It is worth mentioning that the petitioner was
also departmentally proceeded and punished for this irregularity.
In
view of the above, It is humbly prayed that this application may kindly be
accepted by providing the petitioner opportunity of Prebargaining/ voluntary
return. The petitioner is ready to deposit Rs. 29,490 with the NAB.
ii) That
after accepting this application, the accountability court at Multan may kindly
be requested to accept the plea bargain and release/discharge the petitioner.
HUMBLE
PETITIONER / ACCUSED
Mst. Naseem
Malik
R/o House 739, Near
Masjid Abu Huraira,
Sabzazar
Colony Bosan Road Multan.
Through:
Ameer Umer Bhatti (Advocate)
AZIZ BLOCK DISTRICT COURT, MULTAN
1.
Honorable
Court of Mr. Ibrahim Asghar, Judge Accountability Court Multan.
2.
Director
General NAB Punjab, Lahore.
