application

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

C.C To.

1.      Honorable Court of Mr. Ibrahim Asghar, Judge Accountability Court Multan.

2.      Director General NAB Punjab, Lahore.