Complaint Regarding Stock Exchange Rule Violation

TO THE SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN / PAKISTAN STOCK EXCHANGE LIMITED, ISLAMABAD

COMPLAINT REGARDING VIOLATION OF PAKISTAN STOCK EXCHANGE RULES AND SECURITIES ACT 2015

Complainant: complainant_name, CNIC No. complainant_cnic Address: complainant_address Contact: complainant_phone Respondent (Trading Member): member_name, Broker Code broker_code Address: member_address Respondent (Regulated Person/Company): regulated_company_name, Listed on stock_exchange

The respondent member member_name (Broker Code broker_code), registered with stock_exchange, has committed multiple violations of the Pakistan Stock Exchange Rule Book and the Securities Act 2015: RULES VIOLATED: 1. Rule rule_1 (rule_1_subject) 2. Rule rule_2 (rule_2_subject) 3. Rule rule_3 (rule_3_subject) MATERIAL IRREGULARITIES IN TRANSACTIONS: The complainant initiated a transaction on transaction_date for transaction_description. The violations occurred on violation_date as follows: 1. Failure in delivery of delivery_details 2. Unauthorized commission overcharge of overcharge_amount on the transaction value 3. material_irregularity_3 4. material_irregularity_4 These irregularities constitute systematic breach of exchange rules designed to protect investor interests and maintain market integrity. WITNESSES AND EVIDENCE: Witness 1: witness_1_name Witness 2: witness_2_name Both witnesses have firsthand knowledge of the violations and are prepared to testify. FINANCIAL LOSS: The complainant has suffered quantifiable financial loss of loss_amount due to the respondent's misconduct. A formal demand was made on demand_date but remains unresolved. The respondent's violations of rule_numbers demonstrate flagrant disregard for regulatory requirements and investor protection standards.

The respondent member member_name (Broker Code broker_code), registered with stock_exchange, has committed multiple violations of the Pakistan Stock Exchange Rule Book and the Securities Act 2015: RULES VIOLATED: 1. Rule rule_1 (rule_1_subject) 2. Rule rule_2 (rule_2_subject) 3. Rule rule_3 (rule_3_subject) MATERIAL IRREGULARITIES IN TRANSACTIONS: The complainant initiated a transaction on transaction_date for transaction_description. The violations occurred on violation_date as follows: 1. Failure in delivery of delivery_details 2. Unauthorized commission overcharge of overcharge_amount on the transaction value 3. material_irregularity_3 4. material_irregularity_4 These irregularities constitute systematic breach of exchange rules designed to protect investor interests and maintain market integrity. WITNESSES AND EVIDENCE: Witness 1: witness_1_name Witness 2: witness_2_name Both witnesses have firsthand knowledge of the violations and are prepared to testify. FINANCIAL LOSS: The complainant has suffered quantifiable financial loss of loss_amount due to the respondent's misconduct. A formal demand was made on demand_date but remains unresolved. The respondent's violations of rule_numbers demonstrate flagrant disregard for regulatory requirements and investor protection standards.

The respondent member member_name (Broker Code broker_code), registered with stock_exchange, has committed multiple violations of the Pakistan Stock Exchange Rule Book and the Securities Act 2015: RULES VIOLATED: 1. Rule rule_1 (rule_1_subject) 2. Rule rule_2 (rule_2_subject) 3. Rule rule_3 (rule_3_subject) MATERIAL IRREGULARITIES IN TRANSACTIONS: The complainant initiated a transaction on transaction_date for transaction_description. The violations occurred on violation_date as follows: 1. Failure in delivery of delivery_details 2. Unauthorized commission overcharge of overcharge_amount on the transaction value 3. material_irregularity_3 4. material_irregularity_4 These irregularities constitute systematic breach of exchange rules designed to protect investor interests and maintain market integrity. WITNESSES AND EVIDENCE: Witness 1: witness_1_name Witness 2: witness_2_name Both witnesses have firsthand knowledge of the violations and are prepared to testify. FINANCIAL LOSS: The complainant has suffered quantifiable financial loss of loss_amount due to the respondent's misconduct. A formal demand was made on demand_date but remains unresolved. The respondent's violations of rule_numbers demonstrate flagrant disregard for regulatory requirements and investor protection standards.

The following PSX Rules have been breached: Rule rule_1 regarding rule_1_subject; Rule rule_2 regarding rule_2_subject; Rule rule_3 regarding rule_3_subject.

Material Irregularities: (1) The trading member failed to deliver delivery_details; (2) The trading member overcharged commission of overcharge_amount without justification; (3) The trading member material_irregularity_3; (4) material_irregularity_4.

Evidence: Trade confirmations, statement of accounts, bank statements, correspondence with the trading member, and settlement records are attached. witness_1_name and witness_2_name can testify to the irregular conduct.

Financial Impact: The complainant suffered financial loss of loss_amount as direct result of the trading member's violations. The complainant demanded refund on demand_date, but the trading member refused.

IN THE RESULT, the complainant humbly requests that the Securities and Exchange Commission of Pakistan and/or Pakistan Stock Exchange be pleased to: 1. Accept this complaint and initiate disciplinary proceedings against the trading member; 2. Conduct investigation into alleged violations of PSX Rules rule_numbers; 3. Direct the trading member to refund loss_amount plus accrued interest; 4. Impose penalties and sanctions on the trading member as per PSX Rule Book; 5. Suspend the trading member's license if warranted; 6. Recommend criminal prosecution where applicable; 7. Award compensation to the complainant. And for such other relief as may be deemed just.

That the cause of action has accrued wholly within the territorial jurisdiction of this Honourable Court at territorial_jurisdiction_basis, and the value of the subject-matter of the suit is within the pecuniary jurisdiction of this Honourable Court. The suit has been valued at Rs. suit_valuation for purposes of court fee and jurisdiction.

That the requisite court fee of Rs. court_fee_paid has been duly affixed on the plaint in accordance with the Court Fees Act 1870. The suit is properly stamped and is otherwise maintainable in form and substance.

That the Plaintiff has approached this Honourable Court with clean hands, has made full and frank disclosure of all material facts, and has not concealed anything that might be relevant to the just decision of the suit.

That the Plaintiff has not previously instituted any suit, application, or other proceedings in respect of the same cause of action before any other forum, and there is no other suit, appeal, or revision pending between the same parties on the same subject-matter, save and except as expressly stated above.

PRAYER

In view of the foregoing, the Applicant / Petitioner / Complainant most respectfully prays that the Honourable Authority may be pleased to:

(a) Take cognizance of the present complaint against the regulated market participant for violation of the PSX Rule Book and the Securities Act 2015;

(b) Initiate disciplinary proceedings against the regulated person under the Pakistan Stock Exchange Regulations and the Securities Act 2015;

(c) Suspend or cancel the licence / authorisation / registration of the regulated person, pending or following determination of the proceedings, where warranted;

(d) Direct disgorgement of any profits made or losses avoided as a result of the violation;

(e) Direct restitution of the Complainant where warranted; and

(f) Pass any other order that the Pakistan Stock Exchange / Securities and Exchange Commission of Pakistan may consider just, fit, and proper.

complainant_counsel_name Advocate/Representative for Complainant Enrolled on Roll No. advocate_roll_no Date: filing_date