WEEK 16-APPLICATION ORDER 1 RULE 10

Format/Draft/Specimen:

Application under Order 1 Rule 10 for impleading as party

BEFORE HONOURABLE LABOUR COURT NO. 1, LAHORE.

In Re:

MUHAMMAD NAWAZ etc V. SECRETARY IRRIGATION etc
(Grievance Petition)

A P P L I C A T I O N UNDER ORDER 1 RULE 10 C.P.C. FOR IMPLEADING THE APPLICANTS (1. NASEER AHMAD 2. RASHEED AFTAB 3.MUHAMMAD AMIR & 4. USMAN ALI) AS PESPONDENTS IN THE TITLED GRIEVANCE PETITION, BEING NECESSARY PARTIES.

Respectfully Sheweth:
1. That the titled grievance petition is pending before this Honourable Court for today i.e. 20.02.2012.
2. That the titled grievance petition has been filed by the respondents against order dated 29.12.2011 passed by Superintending Engineer, Mechanical Circle, Lahore, whereby order passed by Executive Engineer, Sheikhupura for adjustment of the respondents in District Bhalwal was cancelled.
3. That the applicants humbly seek indulgence of this Honourable Court for allowing them to be impleaded as respondents in the titled grievance petition inter-alia on the following:
G R O U N D S
(i) That the applicants are necessary party in the titled grievance petition and for proper adjudication of the titled grievance petition, it is required that they may be arrayed as respondents.
(ii) That the respondents did not array the applicants as party intentional so as to infringe the applicants of their valuable rights.
(ii) That according to Rules/policy finalized by the Government, the respondents/petitioners could not be adjusted in Bhalwal District against promotion post, therefore, order for cancellation of their adjustment was passed in accordance with law.
(iii) That if the respondents/petitioners are adjusted in Bhalwal District against promotion posts, seniority of the applicants will be disturbed as they are serving in the District Bhalwal in the Department as fitters and electricians and their priceless rights as conferred upon them by the Service Laws of the land will severely infringed and same cannot be allowed.
(iv) That if the tiled grievance petition is allowed, applicants will suffer irreparable loss.
(v) That it is in the interest of justice, it is necessary that the applicants may be impleaded as parties in the titled grievance petition and they may be allowed to contest the same and bring their version on record.
(vi) That applicants may be allowed to raise additional grounds at the stage of arguments.
P R A Y E R
In aforementioned circumstances, it is humbly prayed that the applicants may be impleaded as party in the titled grievance petition as same is in the interest of justice and fair play.

APPLICANTS
THROUGH
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Advocate High Court


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