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Case no 121/19
Title Muhammad Zubair vs Director Hayatabad Medical Complex Burns and
Trauma center Peshawar
1) In the paragraph No 2, the respondent says that I have not provided any
materials regarding the experience is incorrect and is Misleading statement. I
mentioned my experience detail in my apply application but are mistakenly
mention in the wrong column. While I appear in my interview I was asked to show
the original certificates which I mentioned in my application so at that time I
realized my mistake and hand over the experience certificates to interviewing
panel. I also made it clear that I wrote my experience details in another column
and requested to be read and written correctly and remove the mistake.
2ndly my NIC attached with my applying application (here attached
provided by the respondents) clearly shows that my residence was Saudi Arabia.
This NIC( English card) is compulsory / mandatory for the workers during visa
processing so this NIC and English card also shows that I have been working in
saudi in Saudi Arabia.
2) As in the advertisement it was mentioned that the applicant must have some
knowledge about computer and MS word so it is understood that the whole
interview will be concentrated on the computer and MS office. So the copy
attached with respondent comments shows some astonishing results.
I. The Petitioner has read the following computer subject during his
education
A. Introduction to computers along with practical
B. Computer aided engg drawing
C. Computer language C++ along with practical
D. Data structure and algorithm along with practical.
E. Digital logic design along with practical.
F. Digital systems along with practical
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G. Computer architectures along with practical.
H. Data communication and networks along with practical
I. Data base systems along with practical
J. Network and security managements along with practical.
K. IP telephony along with practical
So after reading so many advance computer subjects these interview marks are
illogical and clear shows the favoritism and nepotism. (A copy of my DMC is
attached here with as annexure A).
II. The attached documents (Provided by the respondent through RTI) clearly
shows the there is no any computer subject nor any certificates are attached
so these 13.3 marks are immoral and show the partiality
3) In Para No 5 saying that the result was provided and displayed but was never
so and that’s why I approached the HMC Burns and trauma center Peshawar to
provide me the test results, interview results and final merit list.(copy of
application and a registered post are attached signed by the deputy director HMC
burn and trauma center are attached here with). The time limit of 10 days
supposed by the RTI commission for providing of the information was also
ignored by the HMc and I was never provided the required information so this
claim is denied that test results, interviews results, and the merit list have
displayed. So in last hope I approached RTI to provide me the required
information and after reminding again and again copies of results provided.
Supposing that if some information is not provided I again approached the RTI to
ask the HMC to provide full and final copies and it should be clear that each and
every available material have provided so the attached copies were provided by
the HMC through RTI commission. So this whole scenario clearly shows that the
test results, interview marks and merit list was never provided or displayed
timely.
In short I followed the following procedure to get the Test result, interview marks
and final merit list.
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1. I put up an application in front of Deputy Director Hayatabad medical
complex burn and trauma center Peshawar to provide me test results,
interview marks and merit list. (signed copy by deputy director is attached
here with)
2. Wrote another application through registered post and copy is attached
here with.
3. While getting no direct response I involved RTI to provide the information
and copies of conversation with RTI are attached here with.
4. For clarity and removing the ambiguity and any chances of forging and
destroying or editing the records I asked them twice and trice to provide
me information full and final in the conversation with RTI.
(All records of application emails and latter for getting Test result,
interview marks and final merit list are attached here with as Annexure B)
4) Para 6. The interview was never an interview as it should be because during the
interview my degree was discussed that and these question were asked
repeatedly
a. As an engineer why should I am here
b. Why I leave KSA?
c. Why I didn’t stay in KSA?
d. This is not an appropriate job for you although you are most qualified
candidate of all?
e. Some other question and arguments to discourage me to withdraw my
application
5) Flaws in the policy.
a. According to the policy proposed by the HMC burn and trauma center
Peshawar, provided to the honorable mentioned on page no 25 that
“Passing marks in interview will be 50%. If a candidate gets fails in
interview, he or she will not be considered for appointment although his or
her pre-interview marks were more or less.” This statement is technically is
meaningless and in not understandable for example if a candidate pre-
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interview marks are more than the other contesting candidates and he is
being failed intentionally in the interview so it means the candidates 16
years of education and experience were being ignored, this statement
means the whole education he got and the experience he has, of more than
20 years are decided with in few minutes and only 15 marks of interview
are preferred of his whole educational carrier?
So neglecting the whole education and overlooking the experience of a
candidate with in few minutes where there is huge chance of favoritism is
not justified.
b. Here in my case
S/No Name Pre interview Average G.Total marks
marks marks(15) out of (100)
1 Palwasha 44.98 13.11 58.09
Reema
2 Muhamma 54.96 2.44 57.4
d Zubair
Here in this case if I got one mark that 2.44+1=3.44 so G. total will be 58.4
and exceed 58.09 that is Palwasha Reema’s marks no but still my interview
marks are less than the 50% of 15 marks and considered as failed so to
remove this flaw from the policy proposed by the HMC burn and trauma is
quiet clear and understandable that I have been failed intentionally in order
to promote the blessed and blue eye candidate, Plawash Reema.
6) Favoritism details
After continuous struggle of one year through Right to information act
(RTI) I got some of the information but still it is incomplete and waiting for
some of the information’s.
To elaborate and as an evidence I would like to share some humiliating
and discriminating result that you will be surprised. As mentioned above
that the whole process was kept hidden from public then through Right to
information commission The burn and trauma HMC Peshawar provide me
some horrible and astonishing results that one of the candidates
(Inamullah s/o kontar zada) was selected as senior clerk was absent and
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was never appeared in test. But as a blessed person he was selected by
the selection committee of the istitution.(In must be noted that in their
reply through Right to information commission (RTI) it is clearly mention
that the whole result was made by computer.To display results in 24 hours
OMR (optical mark recognition) technology was used for scanning
the MCQ’s based answer sheets attempted by the candidates for the
appointments the OMR which electronically extract intended data from
marked fields, such as checkboxes and fill-infields, on printed forms. OMR
technology scans a printed form and reads predefined positions and
records where marks are made on the form and finally displays the list of
the candidates with their grading marks so there is no chances of error in
the marking, grading and marks sheets making in excel form or
displaying/making the whole results. So there is no chance of any typing
mistakes or any kind of human errors).
Conclusions:
“How can an absent candidate be seleted as a senior clerk and eligible
candidates can be ignored. So need to see in the matter and the accused
persons must be sacked”.
(For detail and as evidence a document name Annexure C is attached and
the above mention person is highlighted here with. This evidentiary
document is officially provided by HMC burn and trauma center Peshawar
through Right to information commission.)
7) corrupt practices and misuse of power and ignoring eligible candidates.
As discussed above that that in their reply through Right to information
commission (RTI) it is clearly mention that the whole result was made by
computer and there was no chances of error but still the record provided by
Hayatabad Medical complex through Right to information commission show that
the big fishes like Inamullah s/o Kawtar zada were allowed to appreare in
interview and was selected by the interview panel, although he was absent in test
and he was selected as Senior clerk (His appointment conformation is attached
here with as annexure C. So now the point to be noted is that “Inspite he is an
absent candidate so why the scrutiny committee or interviewing panel did not
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confront him that he is not eligible for interview?” This kind of conduct shows
that the whole committee and interviewing panel are involved in the whole
misconduct, misuse and fraudulent process.
Conclusions:
A. Chairman selection/ Promotion committee in not trustworthy any
more.
B. The selection committee (headed by the Chairman selection/
Promotion committee) is also not trustworthy any more.
a. For senior clerk one of the HR employee (Manzoor khan s/o Atlas khan
junior clerk) and his real brother (Sadiq S/O Atlas khan) also participated
in test so I want to make surprise that once again that Manzoor khan s/o
of atlas khan participated in two different post and both of them stood
1st or 2nd by getting 90+ marks and the average marks were obtained by
rest of candidates were only 16%.And personally I seen him he was fully
involved as administrating different activities during the written test/
examination like collecting applications , paper distribution, paper
collection, processing attendance sheets.
b. Shocking results of Muhammad Siddiq s/o Atlas khan and
brother Manzoor khan (employed as HR as junior clerk) who
appeared in different test arranged for different post and
Shocking results of Manzoor khan who appeared in different
test arranged for different post;
Muhammad Siddiq applied and appeared in 8 different kind of post and in all of
the post he stood 1st 2nd or 3rd details are shared here
S# Name Post name Obtain Total Postio Total Avg marks of
ed marks n in candidates candidates
marks test
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1 Muhammad Personal 45 50 2nd 332 19
Siddiq assistant
2 Muhammad Senior clerk 48 50 3rd 84 20
Siddiq
3 Muhammad Junior clerk 45 50 3rd 566 18
Siddiq
4 Muhammad CCTV Camera 35 50 3rd 72 17
Siddiq operator
5 Muhammad Computer 44 50 2nd 526 15
Siddiq operator
6 Muhammad CSSD 26 50 3rd 14 18
Siddiq Operator
7 Muhammad photographer 35 50 3rd 12 22
Siddiq
8 Muhammad Senior store 45 50 1st 89 19
Siddiq keeper
1 Manzoor khan Personal 48 50 1st 332 19
assistant
2 Manzoor khan Senior clerk 48 50 1st 84 20
(For detail and as evidence a document name Annexure D is attached and the
above mention person is highlighted here with. This evidentiary document is
officially provided by HMC burn and trauma center Peshawar through Right to
information commission.)
These are all the detail of Muhammad sadiq who is the brother of Manzoor
khan who was fully involved in conducting tests and recruitments. So keeping
the above facts and figure this is quite clear that Manzoor khan help his brother
in test as he remained 1st 2nd or 3rd in the 8 different kinds of tests. Therefor it is
requested to take actions against the Manzoor khan and must be removed from
the post in order to investigate what has actually done bye these corrupt
elements.
Conclustions:
How can a person and his brother who works at HR of the institution can
appear in test a candidate while he was fully involved in HR administration
also it’s a conflict of interest and be must forbidden from doing so, and I am
requesting to remove this person fron the post and responsibilities.
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c. Manzoor khan S/O Atlas khan as discussed above were selected for the
post of senior clerk. As he was already employed at the same institution
so for joining another post he must be released from the current post but
he didn’t leave or resign from the current post and join the new post of
senior clerk and started working for unknown durations. So he keeps
two posts (junior clerk and senior clerk) at the same time.
In the attached document it is clearly mentioned that Manzoor khan S/O
Atlas khan resigned from the newly joined post and now he is working on his
old post.
Conclusions:
1) How can a person keep two post at the same time it totally against
services rules.
2) He spoiled the whole process of recruitment and also one post have
been wasted as current the senior clerk post is empty. Also he discriminated
one of the candidate who was eligible for the post. . Also need to see in the
matter and the accused persons must be sacked.
(For detail and as evidence a document name Annexure C is attached and
the above mention person is highlighted here with. This evidentiary
document is officially provided by HMC burn and trauma center Peshawar
through Right to information commission.)
d. More, I have more evidence against the Deputy Director Muhammad
Zubair of the HMC who also misused his powers and fully involved in corruption
and appointing the ineligible candidates and spoiling the recruitment process.
Personally, I tried my best to request Muhammad Zubair so many times to help
me and provide me the correct records/meeting minutes and other rules and
regulation for the recruitment of BPS 16 and lower scales but he always tried to
divert my attentions by providing incorrect information. As Deputy Director it’s
not his responsibility of to keep the recruitment recording with himself. Once I
asked him to provide me some information but in reply he told me to meet
Superintendent Fida Muhammad Sb but when I went and tried to meet
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Superintendent Fida Muhammad he was absent in office then I called him and
on phone he told me that Its totally wrong statement and Deputy director
Muhammad Zubair never provide me any file/ document regarding the
recruitment as Deputy director Muhammad Zubair is worried about any kind of
inquiry so that’s the reason of hiding these files and document. Respected sir I
can appear and provide this evidentiary document at any forum in order to stop
these kinds of people from corrupt practices. Also I am requesting that a quick
action must be taken and the record must be held and take over. So that he
may not be able to destroy the documents/ evidence or can be changed and
any kind of mishap can be stopped and avoid.
e. Another case to study and to investigate Nirgas Bibi sister of “HR"
Deputy director Named as Haji Muhammad Zubair and her astonishing
results while in spite of conflict of interest she appeared.
Nirgas Bibi (She was already employed at HMC before she submitted four
applications at HMC burn and trauma) and also she is the sister of “HR”
Deputy director Named as Haji Muhammad Zubair:
Muhammad Zubair who is the “HR" Deputy director at HMC burn and
trauma center Peshawar, is involve in misuse and misconduct of his
power and seat. As an important person of HR and according to internal
sources the director of the HMC burn and trauma center Peshawar Prof
Tahir khan directed him and gives him all the responsibilities to this
Muhammad Zubair to see and look after the whole process of the
recruitment. Personally I have seen him receiving application papers,
application fees from candidates , sent feedback of their acceptance of
application, distribute test paper, collect answer sheets , compiling results
and he was responsible for any kind of queries , and participated in
interview panel and asked question from candidates. So how can her
sister take part in test and participate in interview. At is against the basic
laws and rules of any department because of the conflict of interest.
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f. Shocking results of Nargis bibi the sister of “HR" Deputy
director Named as Haji Muhammad Zubair.
Nirgas Bibi participate and applied for different post and her result make
any one shocked as shared in the following table
S Name Post name Obtained Total Postion Total Avg marks of
# marks mark in test candidates candidates
s
1 NARGIS BIBI Admin 47 50 1st 109 20.94624
Officer
2 NARGIS BIBI Junior Clerk 48 50 1st 566 18
3 NARGIS BIBI Receptionist 48 50 1st 27 21
4 NARGIS BIBI Senior Clerk 48 50 1st 84 20
(For detail and as evidence a document name Annexure D is attached and the
above mention person is highlighted here with. This evidentiary
From the conduct of interviewing panel and Hr conduct while they tried their best
to hid the real facts and figures and documents from me, I realized that the whole
processes is based on favoritism and nepotism so I was afraid that the recoirds na
documents can be destroyed or forged that’s why I clearly mention in my
application to RTI” If RTI commission allow me I would like to say that in reply to
this application from Burn and trauma Center, HMC, Peshawar it will be consider
that the above information has not been provided by the candidates in order to
save time and energy” to put a full stop on the HMC and HR HMC so that they
may not able to produce or generate additional documents
More I wrote letters to federal investigation agency (FIA) National accountability
Bureau and Khyber pokhtoonkhowa anti-corruption to take over the record ,
minutes and all other documents regarding the selection but unfortunately I
didn’t get any response from any of the above mentioned institutions
so in result, today HMC has produced a new document in front of court which
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should not be so as this document was not provided to RTI as I asked again and
again to provide me the full and final documents (letters and application to RTI
are attached here with) while the same experience certificate was not provided to
RTI not once but twice the didn’t provide any kind of letters although there were
experience letter of the other candidates who submitted for their corresponding
post. So this clearly shows that there was not experience letter provided by
respondent no 3 at that time.
More the HMC deputy director is not honest and trust worth person as I asked
HMC twice and trice through RTI to provide each and every documents regarding
the selected candidates and clear mentioned that” If RTI commission allow me I
would like to say that in reply to this application from Burn and trauma Center,
HMC, Peshawar it will be consider that the above information has not been
provided by the candidates in order to save time and enegy.” .But in provided
copies to me through RTI he provided the experience certificate copies of other
candidates but no evidentiary experience letter was provided at that time so this
person is not a honest and thrust worthy anymore and must be sacked from his
post.
8) Application and letters to National anti-corruption NAB, Federal
Investigation agency FIA and Khyber pokhtoonkhowa Anti-corruption.
As it is discussed before that I was afraid of the record being destroyed or can be
edited because the HMC Hr deputy director is not a honest person so to
overcome these worries I asked the National anti-corruption NAB, Federal
Investigation agency FIA and Khyber pokhtoonkhowa Anti-corruption to take over
the record in their own custody but I didn’t get any response from these
institutions.
Details of these letters are mentioned as bellow.
1) I wrote an email (Attached here with) in the attachment to the email I
clearly mention on page no 7 that “I would like to request The Director
General National accountably bureau to take strong action against these
wrong doers and would request to take over all the records and minutes
and other in writings documents because according to my sources from
internal of the Hayatabad Medical complex burn and trauma center
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Ppeshawar the Assistant director didn’t handover the recruitments
document to appropriate person. I am worried about the record can be
destroyed or can be crush, whip out or finished off”.
2) On page no 6 again I clearly expressed my worry in these words”
According to my information from the internal source of hospital the
Director of HMC Burn and Trauma center Hayatabad Peshawar Dr Tahir
khan also remained fully involved in whole scene. I want to inform you
that in past he was under investigation of NAB before, as he is involved
in some kind of corruption or any kind if misuse of power. So I am
requesting you to keep him under observation.”
so as no action have been taken from these agencies todays a new document
have been produced in front of the court which was never when I asked
timely to provide any kind of documents provided by the candidate to
Hayatabad medical complex burn and trauma center. All the emails and
resisted post and letters copies attached here with as annexure E.
