In respect of:
(Commission of Inquiry into the conduct of General Elections 2013)

SUBMISSIONS ON THE BASIS OF THE CONCRETE MATERIAL AND EVIDENCE UNDER SECTION 5(3) OF THE ORDINANCE VII OF 2015 FOR THE CONSIDERATION BY THE HON’BLE COMMISSION.

Respectfully Sheweth:

1. That this Hon’ble Judicial Commission invited the Submissions up to 15.4.2015 for its consideration which follow as under:

A) That the appointment of the Members of the Election Commission of Pakistan were illegal being in violation of Article 213 of the Constitution as no proceedings with regard to HEARING AND CONFIRMATION of any one person were conducted by the Parliamentary Committee which were the essential requirements as per letter and spirit of the Constitution 1973. Copy of the Article 213 of the Constitution is enclosed herewith. The Commission may verify this fact of serious violation through summoning the records of such meetings of the Parliamentary Committee as well. The copy of the press clippings of Daily News dated 28.1.2013 of coverage of the Press Conference of PPP Government Coalition Parties & Dr. Muhammad Tahir-ul-Qadri titled “Govt: refuse to dissolve ECP” but admitted in its 3rd paragraph “…the PPP Senior leadership agreed that the reservations of Dr. Qadri about the appointment of ECP members were correct,….” is also enclosed herewith to establish this fact.

B) That the express and mandatory directions made by the August Supreme Court of Pakistan in Constitutional Petition No.87/2011 regarding challenging the election campaign expenses regulation case titled Workers Party Pakistan Vs Federation of Pakistan etc. vide its Judgment dated.8.6.2012 were not complied with despite the further orders of the August Supreme Court of Pakistan for the implementation of the judgment dated.8.6.2012. The first page and last relevant pages regarding relief/directions are enclosed herewith. Furthermore the enclosed relevant copies of the proceedings for its implementation before the SCP would also establish this fact.

C) That the Federal Government of PPPP coalition failed to comply with the commitments/undertakings made in Islamabad Long March Declaration 2013 dated.17.1.2013 duly signed by the PPP Coalition Govt. Parties including the Prime Minister and Dr. Muhammad Tahir-ul-Qadri the Chairman Pakistan Awami Tehreek,which copy is enclosed herewith to be considered as an integral part of these submissions. The copy of the press clippings of Daily News dated. 28.1.2013 of coverage of the Press Conference after its next scheduled meeting on 27.1.2013 of the same party leaders and others is also enclosed herewith to establish this fact.

D) The Federal Government and the Provincial Governments did not block the discretionary funds of the PM, CM & Ministers as well as the grants of funds to the MNAs & MPAs in the name of Development funds. The copy of the press clippings of Daily News dated. 28.1.2013 of coverage of above said Press Conference dated.27.1.2013 is also enclosed herewith to establish this fact of its refusal. The Commission may verify this fact of serious violations through summoning the records of the Federal & Provincial Governments Finance Departments as well.

It is therefore most respectfully prayed that in the light of the above submissions based upon concrete material and evidence; the General Elections 2013 may kindly be declared illegal and void being not organized and conducted impartially, honestly, fairly, justly and in accordance with law.
It is further prayed that the commission may kindly pass the directions/recommendations to the concerned for the Elections Reforms in the light of the above submissions, the Judgment dated.8.6.2012 and the Islamabad Long March Declaration 2013 keeping in view the prime interest and bright future of the Nation & Pakistan. If we are provided a chance to present ourselves before the commission we would like to present the evidence ourselves and also to argue out our case.

Letter from
Dr Raheeq Ahmad Abbasi
President PAT