JUDGMENT J. - This MUHAMMAD MUZAMMAL KHAN, as embodied in section 120 of the Income Tax Ordinance, those revised200I, all the returns of income, other thar under sub-section (6) of section 114, filed for the tax year, 2003 and on wards to fall in this category.
Central Board of Revenue itself mentioned in its circular that the returns qualifying for acceptance under this scheme, shall be deemed to be the assessment made and issued by the Commissioner on the date those returns were furnished.
3. In the light of 10.3.2001 and exercising his 2001 passed the petitionersThe Commissioner Income Ta* directions issued through letters dated 12.3.2004 issued by the Member Audit, powers under section 177 of the Ordinance orders on 4.5.2004 that income tax returns of filed under "Universal Self Assessment" have been selected for audit. This order reads as under:- "In accordance with the provisions under section 177 of the Income Tax Ordinance, 2001, your return for Tax Year 2003 has been selected for an Audit in pursuance to the order by the Central Board of Revenue, notices were issued to the petitioners intimating them, selection of their income Tax returns for audit, of which aggrieved, the petitioners filed the constitutional petitions before this Court assailing the order/notice by the Commissioner Income Tax. The respondents in response to the notice by this Court have appeared through their counsel. Since short point of interruption of provisions of section 177 of the Ordinance, 2001 was involved in all these petitions, those were admitted to regular hearing and by concurrence of the parties, were taken up for final disposal.
4. All the counsel for the writ petitioners argued the case on alike lines and main arguments were addressed by M/s. Dr. Iliyas Zafar* Shahbaz Ahmed Butt, Shafqat Mehmood Chohan and Muhammad Latif Qureshi, Advocates, in their submissions, the income tax returns once having been accepted in form of assessm ent orders by virtue of section 120 of the Income Tax Ordinance, 2001, the same could not be reopened and that too, without notice/hearing of the concerned assessee and that without giving reasons and without detailing under what clause of the section 177 of the Income Tax Ordinance, 2001, their cases have been selected for audit. According to the learned counsel for the petitioners Commissioner Income Tax was required under law to give reasons before passing an order under section 177 of the Ordinance (ibid) but the order impugned in ail the writ petitions being sketchy and without any reason is not sustainable at law in view of section 24-A of the General Clauses Act, 1897. it was also submitted that the Commissioner Income Tax at the time of assumption of jurisdiction under the above referred provisions of law was needed to act judiciously, by applying conscious judicial mind to the cases, and after giving opportunity of hearing, was to pass a speaking order but this was not done, negatively reflecting on the orders impugned. Learned counsel for the petitioners further elaborated their arguments by asserting that the Commissioner Income Tax had no jurisdiction to select any income tax return for total audit, the same having been culminated in an assessment order under section 120 of the Ordinance and thus, reopening of cases is not only arbitrary/fanciful but the same is also discretionary and opposed to constitutional warrantees, in the sense that once the assessee who had already been audited in the preceding year, cannot be again subjected to the agony of audit and that too, without any just cause or reason. According to the submissions of the learned counsel for the petitioners, the orders impugned are opposed to circular No.5 dated 30.6.2003 issued by the Central Board of Revenue, as well, which in itself has the force of law and was binding on the Commissioner Income Tax, being its subordinate functionary thus the impugned orders are not sustainable, it was also urged on behalf of the petitioners that income tax returns under "Universal Self Assessm ent" were filed in September, 2003 and the parameters given for selection of return for audit on 13.5.2004 are illegal, without lawful authority and jurisdiction, as those could not act retrospectively. Replying on the judgments of the Hon'ble Supreme Court in the case of Director Food, NWFP and another Versus Messers Madina Flour and General Mills (Pvt.) Ltd. And 18 others (PLD 2001 SC 1) it was contended that discretion vesting in an authority discharging administrative, judicial or qua-sai judicial functions, has to be exercised within the framework of the statute giving such discretion, in an intelligible and reasonable manner by giving reasons. Reference was also made to the alighted judgment of the Hon'ble Supreme Court in the case of Col. (Retd.) Ayub Ali Rana Versus Dr. Carlite S. Pune and another (PLD 2002 SC 630) with the argument that discretion vesting in an individual has to be exercised by application of judicial mind based on relevant considerations, in a just and proper manner to advance the cause of justice and not whimsically or arbitrarily.
Regarding maintainability of constitutional petitions, judgment by a Full Bench of the Karachi jurisdiction in the case of Messrs Pak Saudi Fertilizers Ltd. Versus Federation of Pakistan and others (2002 PTD 679) was heavily emphasized.
5. Learned counsel for the respondents refuted the arguments of the petitioners, supported the impugned orders passed by the Commissioner Income Tax and urged that this notice is not, as a matter of fact, an order and is an intimation to the assessee regarding selection of his return for audit and thus, it required no reasons to be given therein. He further submitted that under section 177 of the Ordinance, before issuance of notice or confronting the tax payer for the purposes of selection of his return, his hearing is not a requirement of law because no prejudice by selection of the returns of the petitioners is issued to them. According to his submissions, unless and until a prejudice is shown by the assessee, he cannot maintain a constitutional petition. He further submitted that the audit simply means verification of the declaration of the taxpayer and in case of any inconsistency, the matter will be dealt with in accordance with section 122 of the Ordinance for amending the assessm ent order. Learned counsel for the respondents further elaborated his arguments by alternatively saying that requirement of a notice and that of a speaking order, are satisfied in the cases in hand, because a press release was issued on 13.5.2004 laying the parameters for the selection of the cases for audit wherein reasons have been given for such selection, it was also submitted on behalf of the respondents that section 24(a) of the General Clauses Act 1897 is not applicable to the cases in hand because the action under section 177 of the Ordinance has not caused any prejudice to the assessee. Replying to the arguments of the petitioners regarding exercise of discretion by the Commissioner Income Tax, it was submitted that the discretion has correctly and lawfully been structured, according to the guidelines laid down by the Hon'ble , Supreme Court in the case of Aman Ullah Khan and others Versus The Federal Govemment of Pakistan through Secretary, Ministry of Finance, Islamabad and others (PLD 1990 SC 1092). Learned counsel for the respondents made a comparison of the provisions of old Income Tax Ordinance, 1979 with the new Ordinance, 2001 to contend that earlier under section 62 of the Ordinance, 1979, the "Self Assessment Scheme" was available subject to 20% increase of income, from the last year's declared or assessed income and inspite of this increase, assessees were subject to, general audit of his return according to the formula given therein, whereas under the present Ordinance, assessee need not increase his previous income by 2% and is only liable to audit in case, he is covered by section 177 of the Ordinance, 2001. According to his submissions, the concept of audit envisaged by section 177 of the Income Tax Ordinance, 2001, though is new in this country but is being applied in different countries like United State of America etc. Where it has worked with success. Referring the assessment order mentioned in section 120 of the Income Tax Ordinance, 2001 it was explained that by it no vested right is created in tax payer that he cannot be audited/asked to substantiate his version by producing supporting documents under section 177 of the Ordinance, it was also urged that the department has a right to check the veracity of declared version of the assessee and the same cannot be denied, having been provided by the statute and that the rational behind section 177 is only to give caution to the tax payer to file correct return which, otherwise is his legal and moral obligation. Reference to the circular dated 11.6.2004 by the Central Board of Revenue was also made for the submission that classes of business can be made for the purposes of audit because all the assesses are liable to audit under Ordinance, 2001.
6. I have anxiously considered the respective arguments of the learned counsel for the parties and have examined the record, appended herewith. The relevant provision of law under which the impugned order/notice was issued by the Commissioner Income Tax is section 177 of Ordinance, 2001 which reads as under:- "Audit:- (1) The Commissioner may select any person for an audit of the person's income tax affairs having regard to:
(a) the person's history of compliance or noncompliance with this Ordinance.
(b) the amount of tax payable by the person,
(c) the class of business conducted by the person, ' and
(d) any other matter that the Commissioner considers relevant.
(1-A) After selection of& person for audit under subsection (1), the Commissioner shall conduct an audit of the income Tax affairs (including examination of accounts and records, enquiry into expenditure, assets and liabilities) of that person.
(1-B) After completion of the audit under sub-section (1-A) or sub-section (3), the Commissioner may, if considered necessary, after obtaining taxpayer's explanation on all the issues raised in the audit, amend the assessm ent under subsection (1) or sub-section (4) of section 122, as the case may be.
(2) The fact that a person has been audited in a year shall not preclude the person from being audited again in the next and following years where there are reasonable grounds for such audits, particularly having regard to the factors in sub-section (1).
(3) The Central Board of Revenue may appoint I firm of Chartered Accountants as defined under the Chartered Accountants Ordinance, 1961 (X of 1961), to conduct an audit of the income tax affairs of any person and the scope of such audit shall be as determined by the Central Board of Revenue on a case by case basis.
(4) Any person employed by a firm referred to in sub-section (3) may be authorized by the Commissioner, in writing, to exercise the powers in section 175 and 176 for the purpose of (conducting) audit under that subsection."
Examination of the above produced provision of law, no doubt, equips the Commissioner Income Tax with the powers to select any person for an audit having regard to four categories of person detailed therein. Clause (d) of subsection (1) of section 177 gives discretion to the Commissioner to audit any person on the basis of any other matter which he considers relevant. This clause (d) of sub section (1) of section 177 is quite wider in scope, an compared to other clauses wherein categories/classes ol different persons have been mentioned but is more demanding, as Commissioner Income Tax has to detail the matter/basis of his selection and has to give reasons which he considered relevant for this exercise. Any way, while invoking powers under section 177 of the Income Tax Ordinance, 2001, the Commissioner Income Tax is not only require to mention the clause of the above-referred law under which the assessee was selected for audit but was also supposed to give reasons for such selection because his return having been filed under-section 114 of the Ordinance (ibid) was to be treated as an assessment order under section 120 of the Ordinance which is reproduced for the convenience: "Section 120: Assessm ents: (1) Where a tax payer has furnished a complete return of income (other than a revised return under sub-section (6) of section 114) for a tax year ending, on or after the lst day of July, 2002,
(a) the Commissioner shall be taken to have made an assessment of taxable income of the Tax Payer for that tax year, and the tax due thereon, equal to those respective amounts specified in the return, and
(b) the Tax payer's return shall be taken for all purposes of this Ordinance to be an assessment order issued to the taxpayer by the Commissioner on the day the return was furnished.
(underlining is mine, to high-light the effect of it, in this case)
7. Besides the provisions above produced, circular 5 of the Central Board of Revenue dated 13.5.2004 is also self-explanatory on the point that the income tax returns filed under the "Universal Self Assessm ent" shall be deemed to be the assessment orders. Relevant portion of circular 5, is as under:- "The concept of Universal Self Assessment is embodied in section 120 of the Income Tax Ordinance, 200I. Accordingly, all returns of income, other that the revised returns under subsection (6) of section 114, filed for the tax year 2003 onwards shall be returns of Universal Self Assessment, in view of clause (b) of section 12Q, a return gualifying for acceptance under Universal Self Assessment shall be deemed to be the assessme nt order made and issued by the Commissioner on the date the return was furnished."
(under-lining is by me).
This provision leave no ambiguity regarding the fact that return of an assessee filed under section 114, at the strength of section 120 of the Income Tax Ordinance, 2001, becomes an assessment order the moment it is filed and receipt thereof, is acknowledgement by the department, by operation of law, if found to be completed and no notice under sub-section (3) of the latter mentioned section is issued. The primary point which hinges for determination is as to whether after once having passed an assessm ent order by accepting the returns, the same could be reopened for audit or otherwise, without notice/hearing of the assesse and that too, without giving any reason, without pointing out any of the clauses of section 177 of the Ordinance, as to under what clause and category he is being subjected to scrutiny. The abrupt answer is No, it cannot be done} because under clause (a), audit can be done keeping in view the person's history of compliance or non- compliance with the Ordinance, while proceeding under clause (b), the; amount of tax payable by the person has to be kept in mind, under clause (c), class of business conducted by the; assessee, has to be considered and under the remaining clause (d), Commissioner can proceed against any person for any other reason which is considered by him to be; relevant. Under last mentioned clause, unless the; Commissioner Income Tax narrates reasons for the action of picking the persons for audit, his order would not reflect his mind, which is not the intention of law, as the same is obvious from the language of clause (d). This brings me to hold that Commissioner Income Tax can proceed against any person but while so doing he has to mention under the clause of section 177 (1) of the Ordinance, 2001, under which he proposed to proceed and at the same time, he has to give reasons for the action against the assessee because his assessment order is to be reopened and declaration in the return is to be scrutinized which is an order adverse to the provisions of section 120 of the Ordinance (ibid).
8. Learned counsel for the respondents attempted to negate the assertions of the petitioners by urging that no notice is needed before proceeding under section 177 of the Ordinance, because by the exercise of audit, no prejudice is caused to the assessee. Though this contention has no substance in it and cannot be accepted even on its face value because general audit of a person does result in prejudice to the assessee as he becomes subject to scrutiny even regarding his meals and wearings yet the law itself provided that the return filed by the assessee would amount to an assessm ent order and when the department opts to reopen the case for scrutiny/audit/detailed analysis, a notice to the assessee has to be given before proceeding adverse to his interest, inspite of absence of specific provision of notice, in the said law. Law regarding notice to the Concerned party is settled by this time and the superior judiciary of country is consistent on the question of giving notice to the concerned persons before proceeding against, him, besides the applicability of principles of natural justice whereunder no one is to be condemned unheard. The Hon'ble Supreme Court of thus country has very graciously mandated that provision of notice to the person against you propose to proceed, has to be read in every statute irrespective of the fact that no such provision is incorporated therein. Reference in'this behalf can be conveniently made to a chain of judgments, a few of those are in the cases of Mst.
Sattan and others Versus Group Captain Masroor Hussain, Officer Commanding P.A.F. Station Sargodhga Cantt. (PLD 1962 Lahore 151), Abdul Rashid Versus Govemment of the Punjab through the Chief Conservator of Forests, Lahore and 2 others (1985 CLC 199), Mst. Abeda Begum Versus Govemment of Pakistan and others (1985 CLC 2859), Muhammad Tufaii Versus Government of Punjab (1990 Law Notes (Lahore) 138), Gul Muhammad ana 8 others Versus Buxal and 2 others (1991 CLC 229), Messrs Murree Brewery Company Limited Versus Director General, Excise and Taxation and 3 others (1991 MLD 267), Fateh Muhammad Versus Mushtaq Ahmed and 9 others (1981 SCMR 1061) and Mst.Zahida Sattar and others Versus Federation of Pakistan and others (PLD 2002 SC 408).
9. in the case of Assistant Collector Customs and other Versus M/s. Khyber Electric Lamps and 3 others (2001 SCMR 838) manufacturer? Of the Electric Bulbs imported raw material for their product which was exempted from payment of customs duty but the custom authorities issued demand notice under section 32 of the Customs Act, 1969 requiring short assessed duty on the ground that the imported goods were components and not the raw material. The notice was challenged in constitutional jurisdiction of the High Court where maintainability of writ petition was challenged in view of appeal provisions in the statute but the writ was issued by the High Court holding demand notice to be void, having been issued without notice. Matter was graciously considered by the Hon'ble Supreme Court and judgment of the High Court was maintained and it was held that demand notice was defective and not maintainable and as it did not reflect whether the alleged untrue declarations /statements were collusive or inadvertent and did not contain specific particulars relating to the provisions under which it was issued, it was further observed that notice being not in conformity with law was rightly struck down by the High Court. This alighted judgment of the Hon'ble Supreme Court applies to instant case with all force and I respectfully following the dictum laid down , hold that Commissioner Income Tax is bound to issue notice to the assessee before exercise of his power under section 177 of the Ordinance {ibid).
10. Adverting to the structure of impugned order/notice , it is not denied during the course of hearing of the case that there is no other independent order at the back of the order / notice impugned , giving detailed reasons selecting the petitioners or their returns for audit. The order impugned , reproduced in the factual part of this judgment , demonstrates that besides the fact that no clause of section 177 (1) of the Ordinance is mentioned therein , no reason of P.CT.LR.
Any Kind have been given for the impugned selection, Absence of reasons / logic of any Kind , in the impugned order clearly depicts non - application of conscious judicial mind by the Commissioner Income Tax before issuing it who by so doing appears to have acted mechanically , I would have readily accepted the assertion of the learned counsel for the respondents that it is merely an intimation of selection for audit, had there been some independent speaking order on its back but in absence of it, the argument has no credence in it for determination. Assuming for the sake of arguments that it. Is an intimation of audit to the assessee even in that case reasons should have been detailed therein for an action under section 177 of the Income Tax Ordinance, 2001. To my mind, whatever it may be, order, notice or intimation, it is defective for the reasons detailed above and cannot be sustained because under law a power to make any order or to give any direction conferred on any authority, officer or person, has to be exercised reasonably, fairly, justly and for advancement of the purpose of the enactment. If such an authority does not demonstrate application of its anxious mind to the case by giving reasons, one cannot assess that the order passed is in advancement of the purpose of the enactment under which the same is passed. We can conveniently refer to section 24(a) of the General Clauses Act, 1897 which requires, as far as necessary, giving of reasons for making an order or for issuing any direction. The Hon'ble Supreme Court in the cases of Messrs Airport Support Services Versus The Airport Manager, Quaid- i-Azam International Airport, Karachi and others (1998 SCMR 2268) and Col. (Retd) Ayub Ali Rana Versus Dr. Carlite S. Pune (PLD 2002 SC 630) mandating that where a statute confers any power to an authority, the same should be exercised reasonably, fairly and justly for the advancement of the enactment and the concerned authority must reflect reasons for its order or direction and in case those reasons are lacking, the affectee can demand, the same by having the order annulled.
11. I have already remarked in the foregoing paragraph that the Commissioner Income Tax did possess discretion of selecting any person for audit under the provisions subject of scrutiny which are, also, open to excessive use and abuse of power and viewing such wide- worded powers, the Hon'ble Supreme Court graciously laid down principles governing exercise of the discretion in many cases like Aman Ullah Khan and others Versus The Federal Govemment of Pakistan through Secretary, Ministry of Finance, Islamabad and others (PLD 1990 SC 1092), Govemment of NWFP through Secretary and 3 others Versus Majee Flour and General Mills (Pvt.) Ltd, Mardan and others (1997 SCMR 1804) and Director Food NWFP Versus Madina Flour and General Mills (PLD 2001 SC 1) by holding that discretionary decision has to be made according to rational reasons which means findings of primary facts, based on good evidence and that wherever wide-worded powers conferring the discretion exists, there remains always the need to structure the discretion which means regularizing of the so created discretion by organizing it, requiring the exercising authority to give reasons, so that decision may achieve the high quality of justice. The seven principles laid down by those judgments, for structuring discretion are, open plans, open policy statements, open rules, open findings, open reasons, open precedents and fair informal procedure. The order impugned if tested on the touchstone given by the Hon'ble Supreme Court, it falls to the ground, as none of those has been followed by the Commissioner Income Tax.
12. Adverting to the parameters given by the Central Board of Revenue for audit, it is an open secret that the press release in this behalf was issued on 13.5.2004 conveying the parameters for corporate/non-corporate returns though these parameters were also not mentioned in the impugned order yet the claim of the respondents that the writ petitioners were selected for audit on the basis of those parameters given by the Central Board of Revenue, in itself shows that the Commissioner Income Tax selected the cases without applying his own independent mind, through a mechanical process, being oblivious of his own powers under section 177 of the Ordinance, 2001. it goes without saying that non-mentioning of the basis for selection, the reasons or parameters in the impugned order, is not only an attempt to trap the unwary assessee but has also a tint of discrimination in it which is prohibited under the provisions of the constitution of this country. The press release dated 13.5.2004 issued by the Central Board of Revenue subsequent to the filing of the returns by the assessees is of no legal consequence as it could not work retrospectively, as those were not in the knowledge of the assesses at the time of filing of their returns. Reference in this behalf can be made to the judgments of this Court in the cases of Sadiq Brothers Poultry, Rawalpindi Versus Appellate Additional Commissioner, I.T.A/V.T., Rawalpindi (2003) 88 Tax 355 (H.C. Lahore) and (2004) 89 Tax 155 (High Court), in both these cases, the circular issued by the Central Board of Revenue specifying certain categories of the assesses whose cases were selected for special audit for the assessm ent year 1998-99 were held to be unjustified and it was ruled that all the categories of assesses should have been given information well before filing of their returns under the "Self Assessm ent Scheme" with an added findings that such circular after filing of self assessment returns are illegal exercise of discretion vesting in the Revenue authorities.
13. For the reasons noted above, I have no hesitation to hold that the impugned order/notice is defective as the same lacks the essential required by law to be noted therein which at the same time is abuse of exercise of the vested discretion and thus the same is not sustainable at law and is declared to be illegal/void and non existent. Before parting with the judgment, I must observe that the Commissioner Income Tax can initiate fresh proceedings of audit strictly in accordance with law and according to the observations made above. Resultantly, all the writ petitions mentioned in the schedule appended herewith, are accepted and writ, as prayed, is issued, with no order as to costs. .
SCHEDULE OF THE CASES DECIDED VIDE ORDER PASSED IN WRIT PETITION NO.10150/2004.
1. W.P. No.9926/2004 27. W.P. No. 10600/2004.
2. W.P. No. 10056/2004.
28. W.P. No. 10601/2004.
3. W.P. No. 10057/2004.
29. W.P. No. 10667/2004.
4. W.P. No. 10058/2004.
30. W.P. No. 10668/2004.
5. W.P. No. 10059/2004.
31. W.P. No. 10669/2004.
6. W.P. No. 10103/2004.
32. W.P. No. 10671/2004.
7. W.P. No. 10104/2004.
33. W.P. No. 10671/2004.
8. ' W.P. No. 10108/2004.
34. W.P. No. 10672/2004.
9. W.P. No. 101,24/2004.
35. W.P. No. 10673/2004.
10. : W.P. No. 10126/2004 36. W.P. No. 10674/2004.
11. W.P. No. 10132/2004.
37. W.P. No. 10675/2004.
12. W.P. No. 10148/2004 38. W.P. No. 10676/2004.
13. W.P. No. 10150/2004.
39. W.P. No. 10686/2004.
14. W.P. No. 10150/2004.
40. W.P. No. 10874/2004.
15. W.P. No. 10238/2002.
41. W.P. No. 10875/2004.
16. W.P. No. 10578/2004.
42. W.P. No. 10876/2004/
17. W.P. No. 10579/2004.
43. W.P. No. 10877/2004.
18. W.P. No. 10591/2004.
44. W.P. No. 10878/2004.
19. W.P. No. 10592/2004.
45. W.P. No. 10925/2004.
20. W.P. No. 10593/2004.
46. W.P. No. 10927/2004.
21. W.P. No. 10594/2004.
47. W.P. No. 10929/2004.
22. W.P. No. 10595/2004.
48. W.P. No. 11082/2004.
23. W.P. No. 10596/2004 49. W.P. No. 11083/2004.
24. W.P. No. 10597/2004 50. W.P. No. 11084/2004.
25. W.P. No. 10598/2004.
51. W.P. No. 11091/2004.
26. W.P. No. 10599/2004.
53. W.P. No. 11093/2004.
54. W.P. No. 11094/2004.
55. W.P. No. 11095/2004.
56. W.P. No. 11096/2004.
57. W.P. No. 11097/2004.
58. W.P. No. 11098/2004.
59. W;P. No. 11099/2004.
60. W.P. No. 11100/2004.
61. W.P. No. 11101/2004.
62. W.P. No. 11102/2004.
63. W.P. No. 11103/2004.
64. W.P. No. 11104/2004
65. W.P. No. 11105/2004
66. W.P. No. 11106/2004.
67. < W.P. No. 11107/2004.
68. W.P. No. 11123/2004.
69. W.P. No. 11255/2004.
70. W.P. No. 11256/2004.
71. W.P. No. 11257/2004.
72. W.P. No. 71258/2004.
73. W.P. No. 11259/2004.
74. W.P. No. 11260/2004.
75. W. P. No. 11261/2004.
76. W.P. No. 11262/2004.
77. W.P. No. 11263/2004.
78. W.P. No. 11264/2004.
79. W.P. No. 11265/2004.
80. W.P. No. 11266/2004.
81. W.P. No. 11267/2004.
111. W.P. No. 11729/2004.
52. W.P. No.11092/2004.
82. W.P. No. 11268/2004.
83. W.P. No. 11269/2004.
84. W.P. Fao. 11270/2004.
85. W.P. No. 11348/2004.
86. W.P. No. 11349/2004.
87. W.P. No. 11350/2004.
88. W.P. No. 11354/2004.
89. W.P. No. 11355/2004.
90. W.P. No. 11356/2004.
91. W.P. No. 11357/2004.
92. W.P. No. 11358/2004.
93. W.P. No. 11359/2004.
94. W.P. No. 11360/2004.
95. W.P. No. 11361/2004.
96. W.P. No. 11362/2004.
97. W.P. No. 11363/2004.
98. W.P. No. 11364/2004.
99. W.P. No. 11365/20t)4.
100. W.P. No. 11366/2004.
101. W. P.No. 11373/2004.
102. W.P. No. 11374/2004.
103. W.P. No.11381/2004.
104. W.P. No.11382/2004.
105. W.P. No.11383/2004. t
106. W.P. No.11432/2004.
107. W.P.No. 11562/2004.
108. W.P.No. 11726/2004,
109. W.P.No. 11727/2004.
110. W.P.No. 11728/2004.
122. W.P.No. 12069/2004.
112. W.P. No. 11730/2004.
123. W.P.No. 12070/2004
113. W.P. No. 11731/2004. 124.W.P. No. 12081/2004
114. W.P. No. 11740/2004 125.W.P. No. 12082/2004.
115. W.P. No. 12799/2004 126./W.P. No. 12083/2004
116. W.P.No. 11800/2400. 127.W.P. No. 12084/2004
117. W.P. No. 12053/2004.
128. W.P. No. 12085/2004
118. W.P. No. 12056/2004.
129. W.P. No. 12158/2004
119. W.P. No. 12066/2004.
130. W.P No. 12279/2004
120. W.P. No. 12067/2004. 131.W.P. No. 12280/2004
121. W.P. No. 12068/2004. Sd/