Lahore : The management of Chanar Sugar Mills Ltd has pleaded to president , Asif Ali Zardari, for investigations into unlawful closure of its mill to force it to sell to some powerful person of the Punjab.
President of the Islamic Republic of Pakistan,
Aiwan-e-Sadr,
Islamabad.
SUBJECT: URGENT REPRESENTATION IN THE PUBLIC INTEREST
FOR PRESIDENTIAL INTERVENTION IN THE REVIVAL OF
CHANAR SUGAR MILLS LIMITED, FOR A COMPARATIVE
AND INDEPENDENT INQUIRY INTO THE SELECTIVE AND
DISCRIMINATORY TARGETING OF THE MILL, AND FOR
ACCOUNTABILITY OVER THE UNLAWFUL SEALING AND
ATTEMPTED FORCED TAKEOVER OF THE MILL, IN
LIGHT OF NEWLY SURFACED PUBLIC EVIDENCE
Respected Sir,
Further to our representation it is submitted in continuation of our earlier
comprehensive representation, wherein vital digital evidence, including the verified Facebook profile, public photographs, and associated online records of the Cane Commissioner and Director General, Food, Mr. Amjad Hafeez
were formally placed on record. The entire contents, legal grounds, documented losses and constitutional violations set out in our aforesaid letter dated 24.08.2026 (as well
as the prior representations dated 08.06.2026 and 22.07.2026 referred to therein) are hereby reiterated, re-affirmed, and incorporated into the present representation as an
integral part thereof, to be read as an unbroken continuum of our grievances
concerning the unlawful sealing, attempted forced takeover, and continuing financial.
Chanar
Sugar Mills Ltd.
destruction of Chanar Sugar Mills Limited (“CSML”) and Chanar Energy Limited
Chanar Energy Limited (“CEL”), to place before you a matter of grave national,
economic and public importance concerning the unlawful sealing and continuing financial destruction of our Mill, and, more critically, crucial new evidence that has now surfaced publicly, indicating that this was not an act of lawful administrative regulation but a coordinated attempt at the forced acquisition of our business, carriedout through the selective and discriminatory use of statutory power against CSMI
and CEL alone.
2. This representation follows prior communications already placed on record with the concerned authorities, none of which has produced any remedial or investigative response: our detailed representation dated 8 June 2026 addressed to the Secretary,
Punjab Food Department, Government of the Punjab, setting out the unlawful
sealing of the Mill, the budgeted versus actual operational losses suffered, and the consequent risk to our employees and the sugarcane growers of the region; our
representation dated 22 July 2026 addressed to the Honourable Chief of Defence Forces, requesting intervention of the Special Investment Facilitation Council (SIFC), financial restructuring assistance, and an independent inquiry into the conduct of Mr. Amjad Hafeez., Cane Commissioner and Director General, Food, and Mr. Nadeem Nasir, the then Deputy Commissioner, Faisalabad; and further representations separately addressed to the Chief Secretary, Government of the Punjab, and to the Chief Minister, Punjab, repeating these grievances in detail.
Despite the seriousness and persistence of these representations, the provincial
hierarchy of the Government of the Punjab has taken no action whatsoever, has issued no response, and has ordered no inquiry, a silence that, in itself, is now a material fact bearing on the mala fide character of the underlying action and that compels recourse to your office. The facts and grounds set out in all of the aforesaid representations are reiterated and reaffirmed in their entirety and are treated as
forming an integral part of the present representation.
3. By way of brief recapitulation, our Mill, an established industrial undertaking located at Tandlianwala, District Faisalabad, together with Chanar Energy Limited,
a 22-megawatt bagasse-based co-generation facility integrally linked to and dependent upon the Mill’s operation, was unlaw fully sealed during the peak crushing season, first from 15 November 2025 to 26 December 2025, and thereafter once again on 19 February 2026, at the very peak of the sucrose recovery period. This sealing was carried out without any lawful speaking order, without a prior determination of liability communicated to CSML, and without observance of the due process mandated by Sections 13 and 13-A of the Sugar Factories Control Act,
1950. Other sugar mills in the vicinity, by contrast, continued to operate without interruption until almost the end of March, exposing the discriminatory and targeted
character of the action taken against us.
4. It is respectfully submitted that CSML is not the only defaulting sugar mill, operating in the Province of the Punjab. Numerous other mills carry comparable, and in some instances far larger, arrears of cane price, statutory dues and bank finance, arising from ordinary commercial cash-flow constraints inherent to the sugar sector, yet none of them has been subjected to seizure, sealing, or forcible closure of the kind visited upon CSML and CEL. This stark disparity of treatment,
sustained despite repeated representations to the Punjab hierarchy that have gone wholly unanswered, cannot be explained on any lawful or rational basis and is itself cogent evidence of targeted, mala fide action rather than even-handed regulatory enforcement. It is accordingly and respectfully prayed that the Federal and Provincial authorities be directed to disclose, on record, a comprehensive statement
of every sugar mill in the Punjab (and, so far as relevant, in the other provinces) that was in default of cane price, statutory levies, or bank dues during the 2025-2026 crushing season, together with the action, if any, taken against each such mill, so
that the selective and discriminatory character of the action against CSML and CEL may be objectively tested and established.
5. The direct, documented, bottom-line financial damage inflicted upon CSML and
CEL during the 2025-2026 crushing season amounts to Rs. 1,904.222 Million, and
in gross operational terms the loss extends well beyond Rs. 2 Billion. This loss has crippled the Mill’s ability to discharge its most basic and non-discretionary obligations: the timely disbursement of salaries and wages to hundreds of employees and workers, regular payments of cane price to the growers of the region who depend
entirely upon the Mill for the disposal and payment of their cane, the discharge of taxes, duties and statutory levies payable to the Government, and the servicing of mark-up and other charges payable to our financing banks. The continued crippling of the Mill has, in fact, compelled management to consider the distress sale of the
undertaking itself, a step that would cause irreparable harm not only to CSML and
CEL but to hundreds of workers, to the growers of the region, and to the public
exchequer.
6. It is further and respectfully emphasised that any pendency in the discharge ofcane price, statutory dues, or bank obligations is not evidence of financial.
mismanagement on the part of CSML, but is the direct and foreseeable consequence
of the very sealing complained of. In the ordinary course, such obligations are met either through periodic bank finance secured against the crushing operation or
through revenue generated by crushing itself; by sealing the Mill precisely at the peak of the crushing and sucrose recovery season, the concerned authorities disabled CSML from generating the very revenue required to discharge the dues now being
cited against it. To invoke a default that the State’s own unlawful action has caused, as a fresh ground for further coercive measures against the Mill, is legally impermissible and amounts to the authorities profiting from their own wrong.
7. It is against this background that crucial new evidence has now come to light, which fundamentally alters the character of this matter and demands your urgent and direct attention. In a televised broadcast on the news programme “Rundown with Shumaila Niaz”, Mr. Khalid Hussain Bath, Chairman of Pakistan Kissan Ittehad, publicly alleged, on record, that Mr. Amjad Hafeez, Cane Commissioner and
Director General, Food, and Mr. Junaid Safdar attempted to forcibly take over
Chanar Sugar Mills Ltd. This public allegation is consistent with a photograph presently in circulation showing the said officer in the company of political figures.
8. The public allegations of an attempted forced takeover of Chanar Sugar Mills are
now further corroborated by indisputable digital evidence: the official Facebook
profile, display pictures, and account links of the concerned officer, Mr. Amjad Hafeez, which are publicly and openly accessible at
https://www.facebook.com/share/18CAMtefQM/?mibextid=wwXIfi).This publicly
accessible material shows the officer’s continuing association with political figures, including in a display picture together with Mr. Junaid Safdar, and forms part of awider, visible pattern of self-promotional social-media activity by the officer,
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extending to the circulation of videos in a manner more characteristic of a political personality cultivating a public following than of a serving civil servant discharging a regulatory function. Taken together with the televised allegation, this material
provides strong and credible grounds to conclude that the unlawful sealing of our Mill was not a bona fide exercise of statutory regulatory power, but rather a
coordinated, mala fide design aimed at the forced acquisition of a functioning
industrial undertaking, using the machinery of the State as an instrument of the design.
9. It is respectfully placed on record that our office, legal counsel, and the entire team engaged in the preparation and issuance of this notice and connected representations have independently accessed, viewed, verified, and reviewed the
concerned officer’s Facebook profile via the direct URL
(https://www.facebook.com/share/18CAMtefQM/?mibextid=wwXIfr), including
the specific display pictures (DP) and associated material, prior to drafting and issuing these proceedings. It is expressly clarified, for the avoidance of any doubt, that even if the concerned officer, or any person acting on his behalf, were to now delete, hide, restrict access to, or otherwise remove the said profile, display pictures,
or related material from Facebook, our team and counsel have already directly seen, secured, and preserved this digital evidence firsthand. Accordingly, its existence and content as of the date of this representation stand independently confirmed and
established, regardless of any subsequent alteration or removal of the online material.
10. It is respectfully submitted that the officer’s conduct cannot be viewed in isolation from his evident proximity to, and patronage by, high political office in the Punjab. An officer who enjoys such standing and visibility, and who conducts himself publicly, including through an active, self-promoting social-media presence in a manner resembling that of a political leader rather than a neutral public servant,
raises serious concerns of a breach of the political neutrality and personal conduct obligations that bind every civil servant of Pakistan under the Government Servants (Conduct) Rules, 1964, as compiled in the Establishment Code (“ESTACODE”), and, so far as applicable, under the Removal from Service (Special Powers) Ordinance, 2000. Such conduct, when coupled with the exercise of coercive
regulatory power against a specific private undertaking, converts what ought to be
an impartial administrative function into an instrument of personal or political design, and independently warrants inquiry regardless of the outcome of the criminal
allegations set out above.
11. This revelation transforms the present matter from one of administrative overreach into one that squarely engages the criminal law, the constitutional guarantees available to CSML, CEL in particular:
(a) the arbitrary and unexplained deprivation of the Mill’s ability to operate, without a prior speaking order or hearing, offends Article 4 of the
Constitution, which guarantees to every citizen the inalienable right to be dealt with in accordance with law and to enjoy the protection of law as an inviolable right;
(b) the destruction of the Mill’s livelihood-generating capacity, and the
consequent threat to the livelihoods of hundreds of employees and thousands
of dependent growers, engages Article 9 of the Constitution, which, as
authoritatively held by the Supreme Court of Pakistan in Ms. Shehla Zia and
others v. WAPDA, PLD 1994 SC 693, gives the word “life” an expansive
meaning covering all facets and amenities of human existence to which a
person is entitled to enjoy with dignity, and not merely bare physical survival;
(c) the same conduct offends Article 14 of the Constitution, guaranteeing the
inviolability of the dignity of man, which the Supreme Court in Shehla Zia
(PLD 1994 SC 693) held must be read together with Article 9, such that the
destruction of a lawful livelihood through arbitrary State action is an affront to dignity as much as to life;
(d) the selective and discriminatory targeting of CSML and CEL, while other
similarly placed defaulting mills remain untouched, offends the guarantee of
equal protection and non-arbitrary treatment that underlies Articles 4 and 25 of the Constitution; selective and differential treatment without lawful basis or reasonable classification has been recognised by the Superior Courts as reflecting arbitrariness in the exercise of administrative authority and as offending these constitutional guarantees;
(e) the sealing and consequent closure of the Mill’s lawful business directly
offends Article 18 of the Constitution, which guarantees every citizen the right
to enter upon any lawful profession or occupation and to conduct any lawful
trade or business; and
(f) the continuing deprivation of CSML and CEL’s beneficial use and
enjoyment of their industrial assets, without lawful authority, offends Article 24 of the Constitution, which protects every citizen against compulsory acquisition or deprivation of property save in accordance with law and for adequate compensation.
12. It is further submitted that Article 5 of the Constitution, which enjoins loyalty to the State and obedience to the Constitution and law as the basic duty of every citizen,
a duty that binds public officeholders with particular force given the authority entrusted to them, has been subordinated in this instance to what appears to be personal or political loyalty on the part of the officer concerned, in derogation of the
obedience to law that Article 5 demands of him as a public functionary exercising statutory power.
13. The sealing action is further vitiated by the unguided, arbitrary and unreasoned exercise of statutory discretion, in violation of Section 24-A of the General Clauses Act, 1897, which obliges every public functionary exercising a power of decision-
making to act reasonably, fairly, justly and for the advancement of the purposes of the enactment under which the power is exercised, and to record reasons for the order passed. The Superior Courts have consistently held that every administrative order adversely affecting a party must be accompanied by a written, reasoned speaking order after due application of mind (Messrs Airport Support Services, 1998 SCMR 2268, as relied upon in Federation of Pakistan v. Tahir Latif, 2007 SCMR 152); no
such speaking order was ever passed against or communicated to CSML prior to the sealing of the Mill.
14. It is respectfully submitted that the conduct complained of also engages
Pakistan’s obligations under the international human-rights framework to which the State is a party, including the guarantees against arbitrary interference with property
and lawful economic activity and the protection of the right to work and to just conditions of livelihood recognised under the International Covenant on Civil and Political Rights and the International Covenant on Economic, Social and Cultural Rights, and the emerging body of comparative jurisprudence in other common-law
jurisdictions recognising that the arbitrary or discriminatory exercise of regulatory power to force the closure or takeover of a lawful private enterprise is amenable to judicial and constitutional review.
15. It cannot be permitted that officers entrusted with statutory regulatory authority use that authority as a lever for private or political acquisition, at the cost of the livelihoods of hundreds of workers, the interests of thousands of sugarcane growers,
the stability of the banking sector, and the revenue of the public exchequer, nor can it be permitted that a single undertaking be made an example of, while comparably placed mills across the province are left untouched, without any lawful or rational basis for the distinction.
16. As the Head of State and the constitutional custodian of the Federation’s unity and the rule of law, I humbly and respectfully appeal to your esteemed office to take cognisance of this matter, particularly in circumstances where repeated
representations to the provincial hierarchy of the Government of the Punjab have produced no response and no action, and to direct the concerned Federal and Provincial authorities to act with the urgency that the gravity of these allegations demands, so that the machinery of the State is not permitted to be used, or seen to be used, as an instrument for the forcible or discriminatory acquisition of a lawfully
operating private enterprise.
In view of the foregoing, and in the public interest as well as in the interest of justice, equity and fair play, I most respectfully pray that the Honourable President may kindly be pleased to direct or cause to be directed:
i. an immediate stay and abeyance of all coercive, recovery and execution
proceedings against CSML and CEL, whether purportedly undertaken
pursuant to any order of the Cane Commissioner or any other authority,
pending a lawful and reasoned determination of liability;
ii. the immediate and unhindered resumption of operations of the Mill and
Chanar Energy Limited, so as to safeguard hundreds of jobs, protect the
interests of the sugarcane growers of the region, and preserve the Mill’s
capacity to discharge its statutory and financial obligations;
ili. appropriate financial facilitation, including a working-capital and
restructuring package through the Special Investment Facilitation Council
(SIFC) or relevant financial institutions, to enable the revival of the Mill and the discharge of its outstanding liabilities to growers, employees, banks and the exchequer;
iv. a strict, independent and impartial inquiry into the conduct of Mr. Amjad
Hafeez, Cane Commissioner and Director General, Food, and into the role,
if any, of Mr. Junaid Safdar and any other person associated with him, in
light of the public allegations made by the Chairman, Pakistan Kissan
Ittehad, and the corroborating photographic and social-media material
presently in circulation, including a specific examination of whether the
officer’s political associations and public conduct amount to a breach of the
Government Servants (Conduct) Rules, 1964, with a view to fixing personal
responsibility and taking such further action, including criminal action, as
the findings of the inquiry may warrant;
v. that the Punjab Food Department and connected authorities be directed
to place on record a comprehensive, comparative statement of every sugar
mill in default of cane price, statutory dues or bank obligations during the
2025-2026 crushing season, and the action, if any, taken against each, so
that the discriminatory and selective character of the action against CSMI
and CEL may be objectively established;
vi. that the allegations of an attempted forced takeover be referred to the
appropriate investigative and accountability forum for examination under the applicable criminal law, independently of the administrative inquiry sought above;
vii. such other and further directions as may be deemed just and appropriate
to protect the constitutional and legal rights of CSMI and CEL, and to
restore confidence in the fair and impartial exercise of regulatory authority in the province.
It is respectfully reiterated that CSMI has, at all times, acted and remains willing to act in good faith and in full accordance with law. This representation is made with the sincere hope that your esteemed office will intervene promptly and decisively, both to prevent the permanent closure of a functioning industrial undertaking and to ensure accountability for what now appears to be a deliberate and mala fide attempt to dispossess a lawful business enterprise through misuse of public office.
An early and favourable response is most respectfully solicited.
(Authorised Signatory)
CC: The Prime Minister of Pakistan, Islamabad.
CC: The Chief Minister, Punjab, Lahore.
CC: Federal Minister for National Food Security and Research, Islamabad.
CC: The Chief Secretary, Government of the Punjab, Lahore.
CC: Muhammad Azhar Siddique, Advocate Supreme Court of Pakistan,
Muhammad & Ahmad (Constitutional, Corporate & Tax Counsel) Ground
Floor, Almas Towers Begum Salma Tassaduq Hussain Road, 26-The Mall,
Lahore
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