(Original Jurisdiction)


Human Rights Case No 8730-S/2015



Mrs. Yasmeen Lari                                                           ………………   Petitioner




  1. The Culture, Tourism & Antiquities Dep’t,

Government of Sindh                                 ………….   Respondent


  1. Mohatta Palace Museum …………..  Respondent


  1. Endowment Fund Trust …………… Respondent





Respectfully submitted:


  1. That the Respondents have no answer and have not replied to the Pettitioner’s plea/response dated 30th December 2015 in Human Rights Case No 8730-S/2915 (Annexure ‘E’).


  1. That instead the Respondents have started blackmailing to force the Petitioner to withdraw my above Human Rights Case No 8730-S/2915.


  1. That Mr. Abdul Hamid Akhund of Respondent 2 & 3 who is neither an architect nor a structural engineer, has falsely and mischievously alleged in his letter dated 16 February to Respondent No 1 that “the Heritage Foundation has about 2-3 months back damaged the outer shell of the tomb of Sultan Ibrahim which puts the structural integrity of the dome at risk” (Annexure ‘A’).


  1. That Mr. Qasim Ali Qasim, Director of Archaeology & Museums, Sindh Culture Tourism & Antiquities Department of Respondent No 1, who is an MA in History, replied to Mr. Akhund the same day, wrongly stating that “the Dome has been damaged by M/s Heritage Foundation and necessary action is under way” (Annexure ‘B’).


  1. That the Respondents have made the allegation of damage without seeing the tomb which is kept locked by the Petitioner. That in fact in a letter to the Petitioner, the Respondent No 1 has complained that he has not been able to visit the tomb as it is kept locked by the Petitioner.


  1. That to harass and defame the Petitioner, daily Dawn managed by Hameed Haroon of Respondent 2, has published the false news with the heading, ‘Historical Sultan Ibrahim tomb damaged during rehabilitation work’ (Annexure ‘C’).


  1. That none of the Respondents named above have defined or detailed the nature or extent of the alleged damage as the Respondents have not been inside the tomb.


  1. That to further harass and defame the Petitioner, the Respondent No 1 has stopped M/s Heritage Foundation from carrying on any work at the site (Annexure ‘D’).







  1. That the 20th Century World Architecture Atlas, comprising architecture between 1900 and 1999 in 97 countries of the world, published from London and New York, has chosen one of Petitioner’s works among 757 most outstanding works built during the twentieth century.


  1. That the Petitioner has received the UN recognition award for her work and UNESCO has devoted a chapter on the Petitioner as one of sixty women from all over the world who have made a significant contribution to UNESCO since its inception.


  1. That UNESCO which is the repository of heritage all over the world appointed the Petitioner, the National Advisor and the leader of the team to restore the endangered Shish Mahal and prepare master plan of Lahore Fort.


  1. That the Petitioner was one of the first to document and help save urban heritage of Pakistan.


  1. That when GPO on Mall Road in Lahore caught fire and was to be demolished the Petitioner restored it.


  1. That when Flagstaff House, Hindu Gymkhana and Mohatta Palace in Karachi came under threat the Petitioner documented them and restored Flagstaff House as Quaid-i-Azam House Museum despite opposition by the Dawn group.


  1. That the Sindh Cultural Heritage (Preservation) Act 1994, proposed by the Petitioner was unanimously passed by the Sindh Assembly whereby about 600 Karachi buildings catalogued and published by me were notified and provided protection.


  1. That the then secretary to the Government of Sindh, Abdul Hamid Akhund Respondent No. 2 & 3, is reputed to have said that it has been passed on at gun point. By that he meant that despite being the blue-eyed boy of Sindh Governor Mahmood Haroon and soul brother of Mr. Hameed Haroon of Dawn, he was helpless before the support the Pettitioner had of Prime Minister Benazir Bhutto, Chief Minister Abdullah Shah and the opposition in the Sindh Assembly.


  1. That the Respondents got themselves nominated to the Advisory Committee under Sindh Cultural Heritage (Preservation) Act 1994, to defeat its purpose. After about two decades even its byelaws have not been formulated and meetings are held irregularly. That thousands of heritage structures are languishing in Karachi, Shikarpoor, Hyderabad and other districts of Sindh. And, several hundred heritage structures in Karachi and other Sindh cities have been declared dangerous.


  1. That therefore the Petitioner resigned from the Advisory Committee and to counter their attempt to delist heritage buildings I created Karavan Karachi to generate public awareness and support for heritage. Karavan Karachi met every Sunday at a heritage building where school, Pakistan Army or Pakistan Navy bands would start playing in the afternoon to attract people. With thousands of people watching, the chief guest would place a plaque on the heritage building, followed by speeches, plays, skits, and music shows relating to heritage offered by schools and theatre groups.


  1. That further without any assistance or funding from the government, in over fifteen hundred villages of Sindh alone, affected by flood and earthquake, the Petitioner has helped people build over forty thousand earthquake and flood proof houses at almost zero carbon footprint as well as over thirty thousand smokeless chulahs and latrines, benefitting over 300,000 persons.


  1. That the Petitioner’s work for flood and earthquake affected communities is being exhibited at RIBA as one of eight architects chosen from around the world, titled “Creativity from Catastrophe” beginning with Christopher Wren who rebuilt London after the Great Fire.


  1. That to influence the Petitioner, the Respondents got the Petitioner nominated to Endowment Fund Trust and Mohatta Palace Museum Board of Governors/Trust. That as a member of their boards, the Petitioner constantly pointed out flaws and proposed improvements, but it had no effect and the Secretary, in both cases the Respondent No. 2 & 3 Mr. Akhund, drafted minutes which were false or which twisted my statements.


  1. That therefore the Petitioner proposed in the presence of Governor Sindh that all of us should resign and be de-notified and new boards should be constituted as some members had been there for too long to do much good, but the government officials and politicians are all afraid of Dawn media empire.


  1. That the Petitioner was making a speech bemoaning the state of heritage in Sindh when a former judge of the Hon’ble Supreme Court among the audience suggested that the Petitioner should petition the Hon’ble Supreme Court to save heritage and history of our country.


That the Petitioner’s simple plea to the Hon’ble Supreme Court dated 30 December 2015 (Annexure ‘E’), is that no organization or institution formed with public funds should have any one nominated or elected for more than two years and more than two terms and no one should be appointed without merit and public

        1. advertisement, and their balance sheets and activities should be placed on their website for everyone to study.


        1. That in retaliation the Respondents have tried to defame and blackmail the Petitioner by publishing false news in media under their control that the tomb of Sultan Ibrahim has been damaged during rehabilitation work by Heritage Foundation (Annexure ‘C’) when neither Mr. Abdul Hamid Akhund (Respondent No 2 & 3) nor Mr. Qasim Ali Qasim (Respondent no 1), who have made the allegation, are architect or structural engineer.


        1. That the media group controlled by Respondents 2 & 3, also stated that US $260,000 has been provided by the US Ambassadors Fund to Heritage Foundation (Annexure ‘F’). That in fact US embassy reimburses the expenses only after scrutinizing expenses incurred by the Heritage Foundation.


        1. That neither any director nor the Petitioner take any salary, dividend, or profit from Heritage Foundation. Can Mr. Abdul Hamid Akhund and Mr. Qasim Ali Qasim say the same.


        1. That to further harass me they have got Culture Department to stop me from working on the tomb of Sultan Ibrahim and formed a committee to investigate alleged damage to the said tomb.


        1. That they have ignored the fact that the US Ambassadors’ Fund regularly sends expert from Washington to inspect our work. That the expert last visited the tomb and dome of Sultan Ibrahim on 3rd February 2016, and approved the works carried out there.


        1. That recently a high powered team of experts from UNESCO inspected all our work at Makli on 19th February 2016, and was in praise for all the work executed by us there including conservation work on Sultan Ibrahim’s tomb.


        1. That the Petitioner has formed a consultative committee of experts which visits Sultan Ibrahim’s tomb to evaluate the work of our artisans, architects and experts and the reports are published on our website for everyone to see.





        In the light of above facts the Petitioner humbly prays that the Hon’ble Supreme Court may be pleased to issue directives against the respondents:

        1. To direct the Sindh Government to ask UNESCO, which is responsible for all the World Heritage Sites, to undertake a review of the state of World Heritage Makli, as well as the work carried out by us and the work carried out by others.
        • To direct the Respondents not to take any coercive action against the Petitioner, that their attempt at blackmailing should be stopped and a restraining order may kindly be issued to the daily ‘Dawn’ not to publish further defamation material related to the Heritage Foundation’s work at Makli.
        • That action may kindly be taken against defamation against the Petitioner by the Respondents, who would like me to withdraw my Human Rights case pending before the Hon’ble Supreme Court.
        • That a restraining order may kindly be issued against the respondents not to do any illegal action, coercive action and not to pressurize the petitioner for withdrawal of this petition.
        • That Heritage Foundation may kindly be allowed to continue with its conservation work at Makli.
        • Any other relief which this Hon’able Court deems fit and appropriate in the instant case may kindly be granted.









        Mrs. Yasmeen Lari SI HI

        CEO, Heritage Foundation

        E6 Fourth Gizri Street

        Dated: ___________________                                                 DHA-4, Karachi

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