from:Henry lawrance <hassansyed5758@gmail.com>

to:info@almustafa.pk,
info@almustafatrust.org

date:Jul 6, 2022, 6:03 PM

subject:WRIT PETITION

mailed-by:gmail.com

 

BEFORE THE HONORABLE ISLAMABAD HIGH COURT, ISLAMABAD

 

WRIT PETITION No. _______/2022

Paul Eliya S/o Hassan Syed R/o Eternal Christ Catholic Church pauleliyachristian.wixsite.com/catholicchurch Lalazar Colony Tulsa Road, House No.25 A, Street No. 5 A, Rawalpindi Cantt

…Petitioner

VERSUS

State

...Respondent

WRIT PETITION UNDER ARTICLE 199 OF THE ISLAMIC REPUBLIC OF PAKISTAN

 

Respectfully Sheweth,

1.    That the petitioner along with his family is the permanent resident of above said address and was a respectable citizen of the Islamic Republic of Pakistan.

 

2.    That the petitioner is a landlord and owner of properties situated in Rawalpindi and other cities of Pakistan including Islamabad in Sangjani

 

3.    That some criminal persons Raja AmjadIqbal Abbasi, Abdul Qudoos, Abdul Rauf, Syed Shahbaz Haider, Farhat Bano, Shafaq Rahid, Rahid Sameeh and others who illegally and unlawfully threatened dire consequences dispossessed the petitioner from his valuable properties situated in Rawalpindi and in Islamabad in this regard the petitioner file some civil suits for possession and cancellation of Sale Deeds Registries Transfers of properties in Rawalpindi and in Islamabad since the year 2000 in the civil court Rawalpindi in the year 2015, after that the above-named persons tried to murder the petitioner and threaten dire consequences and registered a criminal case vide No. 151/16 dated 03.08.2016, u/s 506/34, 364 7ATA 420 154 CrPC and Other Relevant Sections as Per Law and Constitution of The Islamic Republic of Pakistan PPC P.S Noon. (Copies of Civil suits and FIR are annexed herewith).

 

4.    That previously the above named persons kidnapped the father of petitioner and also severely harassed the petitioner and his family on gunpoint and by many ways Persecuted the Petitioner and his family and Petitioner and his family has been facing experiencing Persecution since many years and their fundamental Human Rights and Properties have been snatched fraudulently ,the Petitioner asked for Justice regarding the Repossession of his all properties, and now petitioner along with his family want to leave State Pakistan Forever, the petitioner also submitted his Application and supporting documents evidences proofs of ownership at the Ministry of Interior on dated 07-06-2022 3:15 PM received and Signed by Morning Shift Staff of R&I Room of Interior Ministry Diary # 3038, (Copy is attached) ,The Petitioner want Justice and Legal Action Against Accused and want Repossession of His Properties in Lalazar Rawalpindi and in Islamabad Sangjani The Documents are Attached, The Petitioner along with his Family are Minorities in Pakistan will, Be forced to Cross International borders at Arabian Sea on their own to save their lives. The Petitioner along with his Family do not Care about their Surroundings because they are suffering from trauma and Persecution Risk of Immediate Death. The Petitioner Filed Many Criminal cases against the Accused. The Petitioner and His Family also Filed many Claims And Compensations against the Accused. The Petitioner along with his Family have shifted 21 Houses in 7 years from 2014 till now due to Persecution The Petitioner and his Family have Filed Criminal Cases against Accused House Owner Waqas Mehmood, Asma Naqvi, Awaise Murtaza, and Against Raja Amjad Iqbal Abbasi, Abdul Qudoos, Abdul Rauf and Sleeper Cells Taliban TTP ISIS Daish Alqaida Anti Shia Criminals Terrorists in Rawalpindi and In Islamabad are involved, on Humanitarian Grounds and Any other Relief from Islamabad High Court and from Pakistan Army ISI, The Petitioner Paul Eliya and His Family are facing Severe Violation of Their Fundamental Human Rights, and Facing Death Threats, The Petitioner along with His Family want to Permanently move out of Pakistan due to Persecution, The Petitioner’s Father Hassan Syed is A Heart Patient and If Anything Happens to The Petitioner or to His Family, The Accused Will Be responsible and Criminal negligence of the Responsible Persons And Authorities, The Petitioner along with his Family are on The Road and Are Going out of Pakistan

 

5.    That the above-named persons are land grabbers (Qabza Mafia)  who are trying to murder the petitioner and his family and now the petitioner is suffering from severe mental agony and fear because the above-named persons have too much influence on the local police, state authorities and criminal persons.

 

6.    That due to the above said reasons, it is impossible, and difficult to survive in Pakistan and if the above-named persons succeed in their nefarious designs the petitioner and his family will suffer irreparable loss to their body mind and life. If The Petition is Not Filed before This Honourable Court then in that situation the Petitioner will be Forced to Cross International Borders for saving his life alone and leaving his family behind and leaving everything behind or along with his family because the petitioner has No one to Help petitioner and His Family will Die In Pakistan if They wait and Stay in Pakistan due to Persecution to Death, Petitioner and his Family have become  Refugees, Asylum Seekers, Potentially Stateless Persons and Internally Displaced Persons Forced to Flee Home Country Pakistan due to Persecution and other many Valid Reasons

 

7.    That the petitioner’s Family wants to surrender their nationality and is willing to take the Indian nationality due to the petitioner has voluntarily surrendered his Pakistani nationality u/s 14-A of Pakistan Citizenship Act 1951 and also inherited properties in Ambala, India through his real grandfather namely Brig. Syed Ahmed Passport No. D495043 CNIC No. 210-25-141742

 

8.    That petitioner due to fear and mental agony has surrendered his Pakistani nationality u/s 14-A of Pakistan Citizenship Act 1951(Diary No 1070-R Dated 5-7-21 Islamabad Police) and petitioners along with his whole family names mentioned below are willing to take asylum in India or in any Christian Country ,they want to Exercise their Right to Seek Refuge Asylum and Find safe refuge in another country on Humanitarian Grounds, They will Face Irreparable loss of the Petitioner along with his whole family if they do not flee Pakistan through Wagah border towards Indian UNHCR for their Further travel to Canada or to Australia or to UK or to United States of America, The Petitioner and His Family want Renounce Letters NOC and The Petitioner and His Family have No Money to Directly Immigrate to Canada from Pakistan that is why Petitioner along with his Family finds safe and Easy Route from Wagah Border towards Indian UNHCR for Further Options Available to Petitioner and for his family and The Petitioner and His Family are Common People and Poor People living In Poverty and their story is mentioned in, The Petitioner also want his 81 Billion Rupees Worth Properties Recovery of Pan Am Hijacking Claim 5th September 1986 Flight 73 at Karachi Airport Which is the Claim of Petitioner’s Father Hassan Syed Pan Am Passenger Victim and Recovery of Investment of Petitioner’s Grand Father Late Brig Syed Ahmed from Steel Mill Steel FABS Pvt Ltd Amounts to Be Recovered from Accused of State, The Petitioner want to File his petition before this Court to Get Justice, The Petitioner want to Appear in Person before this Honourable court because of the Nature of The Case, in this regard the petitioner approached to respondent who refused to do so without direction of this Honourable court and the petitioner along with his Family also approached to Indian embassy and filed application for Indian Citizenship and stated affidavits for surrender of nationality 23.11.2021 and UNHCR Multi Country Office LM Protection Unit USAWA@UNHCR.ORG (Email and Copies of applications & affidavits are annexed herewith). The Petitioner says that His Faith Christianity comes First and Is Above everything in the Universe  Due to the Beliefs and Religion of Petitioner and his Family, the Petitioner and His Family have been facing Persecution for many years and Petitioner’s Properties and Fundamental Human Rights have Been Snatched during Persecution, The petitioner and his family want safe passage to India through Wagah Border towards Indian UNHCR to India and want Renounce Letters for him and for his family from Pakistan 

                               i.            Paul Eliya  petitioner (IN PERSON) along with family

                            ii.            Ambereen Fatima (Mother)

                         iii.            Hassan Syed (Father)

                         iv.            Sheharbano (Sister)

 

9.    That the petitioner has no other remedy, hence this petition.

 

PRAYER:

Under the circumstances it is most humbly prayed that by accepting the instant petition the respondent may kindly be directed to proceed with application of petitioner along with his whole family and Immediate Urgent Issuance of NOC and 4 Renounce Letters/Certificates and a Safe Passage to India

Any other relief, which this Honourable Court may deem just and proper also be awarded.

Petitioner

PAUL ELIYA S/O HASSAN SYED

CNIC No. 37405-0365980-9

Passport No. LL1019802

 

  

 

BEFORE THE HONORABLE ISLAMABAD HIGH COURT, ISLAMABAD

 

WRIT PETITION No. _______/2022

Paul Eliya

VERSUS

State

 

WRIT PETITION UNDER ARTICLE 199 OF THE ISLAMIC REPUBLIC OF PAKISTAN

AFFIDAVIT

I, Paul Eliya S/o Hassan Syed R/o Eternal Christ Catholic Church Lalazar Colony Tulsa Road, House No. 25-A, Street No. 5-A, Rawalpindi Cantt, do hereby solemnly affirm declare as under:

 

That the content of the instant petition is true and correct to the best of my knowledge and belief and nothing has been concealed therein.

Deponent

VERIFICATION:

It is verified on oath that the day of _____July 2022 and the content of this affidavit are true and correct to the best of my knowledge and belief and nothing has been concealed therefrom.

 

Deponent