Appeal to NADRA Citizens Tribunal

BEFORE THE NADRA CITIZENS TRIBUNAL, tribunal_location

Appeal No. _____ of year

appellant_name, son/daughter of appellant_father, resident of appellant_address, holding CNIC No. appellant_cnic ... Appellant

VERSUS

1. The Director General, NADRA, Islamabad 2. The Deputy Director, NADRA Regional Head Office, nadra_office 3. The Registrar, NADRA, nadra_office ... Respondents

APPEAL AGAINST BLOCKING / REFUSAL TO ISSUE CNIC / NADRA DECISION

The Appellant respectfully submits:

1. That the Appellant is a law-abiding citizen of Pakistan and has filed the present appeal with bona fide intent to challenge an unfair, unjust, and arbitrary decision taken by the Respondents.

2. That the Appellant applied to NADRA on date_of_application for purpose_of_application

3. That despite the lapse of reasonable time and repeated follow-ups, the Respondents have nadra_action_taken the Applicant's CNIC / have refused to issue the requisite documentation.

4. That the reasons assigned by the Respondents for such blocking / refusal are as follows: nadra_reasons

5. That the aforesaid reasons are appellant_objections, and the Respondents have acted without lawful authority in taking such action against the Appellant.

6. That the Appellant has been prejudiced by the arbitrary action of the Respondents and has been deprived of his / her fundamental rights to obtain identity documents.

7. That the Respondents have not provided any reasonable opportunity to the Appellant to correct or clarify the alleged discrepancies.

8. That the Appellant filed an administrative review request / approached NADRA on date_of_review_request, but the Respondents have not redressed the grievance.

9. That the Appellant has no other efficacious remedy except to approach this Tribunal for redressal.

LIMITATION: The present appeal is filed within the period of limitation prescribed by the parent statute, computed from the date of communication of the impugned order to the appellant. The certified copy of the impugned order has been obtained and is annexed.

PRAYER

It is, therefore, respectfully prayed that this Tribunal may be pleased to:

(a) Allow the present appeal;

(b) Set aside the decision of the Respondents and direct them to remove the block / issue the CNIC / provide the requisite documentation to the Appellant;

(c) Direct the Respondents to complete the verification process expeditiously and issue the necessary documents within a specified period;

(d) Award compensation for the harassment and loss caused to the Appellant; and

(e) Grant such other relief deemed just and proper in the circumstances.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of paragraphs 1 to 9 of the above appeal are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ appellant_name Appellant CNIC No. appellant_cnic Through: _____________________________ counsel_name Advocate