SHEHZAD & CO ADVOCATES & CORPORATE LEGAL CONSULTANTS 9-Fane Road, Lahore 0333-4692559 Mr. Suleman General Manager Orange Line Project NESPAK House I-C, Block N Model Town Extension, Lahore Dated: 11 July 2016 through Courier Subject: Legal Notice Dear Sir, 1 act for Mr. Sajjad H Sheikh, Director and Professor, Institute of Environmental Engineering, University of Engineering and Technology, Lahore (hereinafter the “Client’) who has instructed me to send you the following Legal Notice (the “Notice”. 1 My client resides in the staff colony of University of Engineering & Technology, Lahore, in front of GT Road. Orange line construction is under way and is being supervised by NESPAK. The Client states that: environmental protection measures and their cost is inbuilt in development project, which include sprinkling of water to avoid dust, However, the dust present at the place of traffic jam choked the lungs of the Client. The Client further complains that the whole of UET including all departments and residences of teacher are full of dust. The residents of UET are suffering from many respiratory diseases due to excessive dust levels, which otherwise could have completely been avoided if proper sprinkling with required frequency would have been conducted by the contractor. The agony and pain thus caused is, too great to be described in words. This dereliction on your part amounts to a CRIME AGAINST HUMANITY carrying the penalty of death. It must be further noted in particular that all the waste generated from construction activities must be disposed by the contractor. Slush and water from construction activity on GT road is making plying of vehicle impossible. The construction area must be cordoned off. However, the barriers are not installed at many places, at others, these are broken. Peoples’ safety is at the gravest riskIt is stated that the waste material must be contained within the cordoned off area by the contractor. However, itis lying outside the cordoned off area. There is no traffic management plan. Traffic remains jammed for hours. The narrow route along orange line, for traffic movement, is so rough that traffic movement on it is highly difficult. This amounts to the psychological murder of the citizens. . From the above narration, its clearly manifest that NESPAK supervision staff is completely ignoring the environmental factors mentioned above. Life of people has become miserable as they are continuously exposed to hypertension and in case of desperateness can even commit suicide. That without going into the finer details, | can assure you being a legal practitioner of 15 years standing relating to offences regarding environmental pollution, that you are liable to be tried for various offences under the Pakistan Environmental Protection Act 1997 and Rules thereunder and offences committed under relevant provisions of the Pakistan Penal Code for causing distress, anxiety, mental pain and severe health risk to the Client. The punishments. prescribed under the aforementioned laws comprise several years and the offences are non-bailable. . You are therefore required in your own interest to do the needful within seven days of the receipt of this Notice so as to ensure that no such incident as aforementioned is repeated and the work at site must be carried out strictly in accordance with prescribed rules, methodologies and standards. In case you fail to do the needful as required in Para no. 6 above, | have clear instructions to move against you by filing cases for substantial damages and also pursue the case of the Client by bringing into motion the criminal process of the Realm. am retaining a copy of this Notice in my office and also copying the Notice to MD NESPAK. Sd l Co Shehzad & Co ce: MD NESPAK