wazir khan

8/13/2019 Wazir Khan

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Before the honourable Session judje Session courts Peshawar

Munir Hussain s/o Wazir Khan (late) R/o Street Behram bad o/s Kohati !ate Peshawr

("he Petetioner/#om$lainant)

%/S

(&) 'r Rahim Shah M ne$hrolo*+ Ward ,RH (-) 'r .ahad "M ne$hrolo*+ Ward ,RH

() 'r 0htar li Shah 1nchar*e ne$hrolo*+ Ward ,RH

(2) SH PS Khan Razi3 Shaheed

(4) 'r 1l+as saeedi 1nchar*e Medical B Ward ,RH(5) 'r 1l+as Khatta0 'MS 67 ,RH

(8) 'r .a+az li 'MS 9one (2)

(:) 'r 13bal fridi MS ,RH

(Res$ondents)

Subject; $$lication ->

accused of the death of the $atiant Wazir Khan s/o Badshah !ul on -4=&-=-?&-

in ,RH Hos$ital

Res$ectfull+ Sheweth>

1t is submitted as under

(&); "hat the father of the $etetioner Wazir Khan s/o Badsha !ul is ta0en to ,RH

hos$ital ?n &=&-=-?&- for chest infecton caused due to infected dialasis machines

when he was brou*ht $rior to a$$ro@; &? da+s of the date mentioned aboAe

(-); "hat due to 1n=abilit+>lac0 of 0nowled*e and mismana*ement of the doctors on

dut+ sud*ested dialasis of the $atiant rather than to treat his chest infection and didntcall the chest doctors $ro$erl+ or to transfer the $atiant to chest ward for to control

his infection but done the dialasis on &2=&-=-?&- 6 &4=&-=-?&- as he was needed but

not on emer*enc+ basis

(); "hat on &2=&-=-?&- when father of the $etetioner was ta0en for homodialasis

and when returned to ward >he was unconsciouse and the main reason of his

unconscciouseness was h+$o*l+cemia(low su*ar state) but the doctor on dut+ namel+


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'r fahad(Res$ondent no -) was unable to dia*nose his condition and whenun0nownl+ in emer*enc+ basis the+ sudjested Steroids(sodium cartison) 6injected in

$ladi@(4C *lucose infusion) from which the $atiant had receiAed *lucose then at

once he *ot in consciouse and awa0ed as normal So the steroids (sodium cartison)had no need in that condition because the main reason of his unconsciouseness was

*lucose defficianc+ due to low su*ar state which was un0nownl+ fulfilled throu*h the

$ladi@(4C !lucose infusion)

(2); "hat on &4=&-=-?&- the $atiant is called a*ain for dialasis while in lo$athic

Medicine a dialasis cant be done re*ularl+ da+ after another but there should be *a$

of to 2 da+s eAen in seAere conditions de$endin* u$on the a*e of the $atiant and thea*e of the fatehr of the $etetioner was 8- so durin* the dialasis he *ot in

unconsciouse and when he was shifted in ward the doctor on dut+ 'r Rahim Shah

(Res$ondent no &) and other staff

could not understant u$on his condition due to in=abilt+ and lac0 ofmedical 0nowle*e as most of the doctors selected in *oAt hos$itals on the basis of

reference and bribeSo Res$ondent Do & could not understant the cause ofunconsciouseness till & and half hour u$to the notification of the $etetioner towards

his chronic deseases ie diabetic

(4); "hat u$on the notification of the $etetioner that the $atiant is the chronic

biabetic $atiant of t+$e ->the doctor sud*ested the blood su*er test for which the

com$lanant brou*ht the deAice from home on u*ent basis as there is no an+ su*ar

chec0in* deAice and blood $ressure chec0in* machine aAailable in such a seriousward the credit of this carelesseness and mismana*ement *oes on the head of 'r

0htar li(Res$ondent no )(1nchar*e of Ward)

(4); "hat as when su*ar leAel was tested >it was 24m*/dl which is too low and fatal to

*et a normal $erson unconsciouse and that was the reason that at both da+s the $atiantwas *ot unconsciouse but the doctors on dut+ could not reach u$ to the main reason

of his unconsciouse

(5); "hat after detected the fatal low su*ar leAel of the the $atiant when he was *iAenh+$ertonics(the *lucos solution) > he at once awa0ed and recoAered as normal after

one and half hour a$$ro@; ie from 8 $m to :;? $m

(8); "hat after recoAerin* the $atiant tal0ed with relatiAes and famil+ members on cell

and then ate some custured which means that he was normal in that time and

remained awa0ed and too0 discussions till &-;? am >then sle$t But it is well 0nownfact in medical field that once a $atiant facin* h+$o*l+ciamia(low su*ar leAel) > and

he is recAered b+ *iAin* su*ar or h+$ertonics should be monitor in interAals of time

wheneAer he is not stabilised to start his routine food >thoru*h which he ma+ *et

*lucose at normal wa+


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(:); "hat due to the carelessness and ne*li*ence of the doctor of dut+ 'r Rahim Shah

(Res$ondent no &) >the father of the $etetionert a*ain *ot in low su*ar

state(H+$o*l+cemia) and was noticed at mornin* durin* the routine round of thedoctors at mornin* at about E;?? am and chec0in* the blood su*ar test his su*ar leAel

was 4? m*/d which is too low as com$ared to the normal leAel of &-?ml/dl

(E); "hat remainn* for such a low su*ar leAel for cou$le of hours>a $erson *ets in coma

and the coma occurs due to h+$o*l+cemia causes braim dama*e and his/her chances of

come out from this t+$e of coma state is Aer+ rear accordin* to medical researches

(&?); "hat after bien* comatose the $atiant was 0e$t in the same ward while he should

be transferred steadil+ in the 1#< >and then in the same ward a lad+ doctor sud*esteda #" scan for to chec0 his brain state but didnt showed her o$enion and after - da+s

when the ward inchar*e chec0ed his condition >he sud*ested to tranfer the $atiant in1#< >so he was tranferred in 1#< on &:=&-=-?&- and eAen in such a sensitiAe $lace

as 1#< >the dialasis machine 0e$t there b+ he ne$hrolo*+ ward was defectiAe and

often would not wor0 6 also the ne$hrolo*+ staff would not come to chec0 the urealeAel of the $atiant and the staff of the 1#< had to write call to the ne$hrolo*+ staff

a*ain and a*ain but the+ would i*nore and come after da+ or two and in this wa+ the

$atiant died due to braim dama*e caused b+ h+$o*l+cemia and cardiac arrest due to

undial+sis 6 e@eeded blood urea leAel after a wee0 in 1#


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(&);"hat the en3uir+ team com$letel+ i*nored the inchar*e of the ne$hrolo*+ ward

$rofessor 'r 0htar li(re$ondent no ) while 'r a0htar li as the incha*e of theward is also *uilt+ in this case as whole the s+stem of the ne$hrolo*+ ward is ruined

due to Res$ondent no and the defectiAe dilasis machines 0e$t in the dialasis section

of the ne$hrolo*+ ward as well as in the 1#< are in the leadershi$ and mana*ement of'r 0htar li(Res$ondent no ) and he ma+ not be e@cluded from the $unishments

it is the matter of the $reciouse human liAes

(&2); "hat the dialasis machines 0ee$in* in the dialasis room are also infected be+onddefectiAe that is wh+ most of the $atiants causes the chest infection and other Airal

deseases li0e in the case of the $etetioners father> Wazir Khan which also causes

seAere chest infection and a$art from this before few months a scandal of Ha$itaitis #

is hi*hli*hted in the hos$ital as well as in $ress and electronic media after the raid ofthe helth minister u$on the ne$hrolo*+ ward 1n which 1nchar*e of the ne$hrolo*+

ward 'r Khtar li and technetion of the dialasis section Dasarulla were alle*ed andare under en3uir+Who are inAolAed in usin* the used infected a$$aratus and tubes in

$lace of the new one a*ain and a*ain bou*ht for the innocent and $oor $atiants of

the dialasis

(&4); "hat *ettin* the attested co$+ of the en3uir+ re$ort the $etetioner a$$lied to the

SH PS 0han Razi3 Shaheed on -?=:=-?& to lod*e .1R a*ainst the conAicted

'octors mentioned in the en3uir+ re$ort But the SH is usin* dela+in* tactics to notlod*e .1R for the last -6 half months a$$ro@;

($$lication for .1R is attached as nne@ B)

1t is therefore re3uested to 0indl+ direct the SH of PS Khan Rari3 Shaheed(res$ondent no 2) to lod*e .1R a*ainst the alle*ed doctors 'r Rahim Shah

(Res$ondent no &) >'r .ahar (res$ondent no -) >'r 0htar li (Re$ondents no )

res$osible for the death of the .ather of the $etetioner Wazir Khan S/o Badsha !ul

Fours Sincerel+ >

"he com$lanant /$etetioner Munir Hussain

"hrou*h

Mala0 mjad 1na+at 6 dnan Haider dAicate Peshawar


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