BEFORE LAHORE DEVELOPMENT AUTHORITY COMMISSION,LAHORE

PRESENT:

Mr. Najam Saeed, Chairman.

Mr. Javaid Akhtar, Member.

Reference No. 12/2015

Sardar Dildar Ahmad Cheema, Plot No. 107-B-III, Gulberg III, Lahore

Applicant

Vs.Lahore Development Authority through Additional Director General(Housing) IAuthorized Officer, 467/0-11, Main Boulevard, M.A. JoharTown, Lahore.

Respondent

Order

The applicant in response to the notices issued by the LOAsubmitted vide One Window receipt NO.2205008 dated 28-09-2015, anapplication for filing a reference to the LOACommission. Additional DirectorGeneral (Housing)/Authorized Officer, LOA, filed this reference under sub­section (4) of section 32 of the LOA (Amendment) Act, 2013 read with sub­rule (1) of Rule 7 of the Lahore Development Authority Commission Rules,2014 in respect of the illegal construction made by the applicant on Plot No.107-B-III, Gulberg III, Lahore, Gulberg III, Lahore.. Reference received on11.12.2015 was entered in the Institution Register at Serial No.12 of 2015.Noticeswere issued to the applicant along with a copy of the reference filedby the LOA for submission of their written statement. Col.(R) Javed Akhtarand Mr. Kamran Iqbal appeared on behalf of the applicant. Miss SalehaShahid, Dy. Director, Mr. Sikandar Haroon, Assistant Director, TownPlanning, LOA appeared on behalf of LOA. The parties have been heard.The site of the plot was visited by the Commission in the presence of therepresentatives of the parties on 07.01.2016 and on 04.04.2016.

2. Facts of the case as contained in the referenceare as under:-

- The Proposed building plan comprising of 2 basements, ground,mezzanine and 5 upper floors + Mumty was submitted on 29-01-2004 and the plans upto plinth level were sanctioned and releasedon .13.0~.2004.~~ \

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_ On 22-02-2005 the field staff observed that the owner, aftercompleting the construction upto plinth level, has started theconstruction of ground floor without further release of plans. Theowner was informed accordingly to stop the illegal construction atsite and apply for further release of plans above plinth level.Thereafter as per available record the file remained silent.

_ On 28-11-2005 the then building inspector reported that the ownersubmitted the building plan for the approval of ground to 5th floors,but these plans were not released. However without approval ofthe Authority, the owner illegally constructed the ground,mezzanine and 1st to 9th Floors.

- Action as per law was initiated and further construction work wasstopped by the field staff.

- Owner then submitted the revised building plans comprising 2B +G + Mezzanine + 10 floor on 22.12.2005 through one windowthereafter as per policy a letter for joint inspection comprising ofDirector Town Planning, Town Nazim and Union Council Nazimwas sent on 15-03-2006. In reply the Town Nazim vide letter no375-GT dated 17-05-2006 has pointed out that the structure of thebuilding was completed prior to creation of TMA and has offeredno objection for proceeding of approval of plans by the LOA at itsown.

- Therefore, on 18-08-2006 the site was visited by the then DirectorTown Planning alongwith Deputy Director Town Planning and fieldstaff and observed that the owner has again started constructionwork above 9th floor without release of plans. Therefore, againnotice uls 40 (i) was issued at site on 24-08-2006 and theconstruction work was again stopped at site.

- On 20-11-2006 the Worthy Director General LOA discussed thecase with Director Town Planning and directed to finalize the plansapproval after fulfilling all the codal formalities and after receivingpenalties if any. As per orders passed by the then Director Generalthe penalty was calculated for prior approval construction andremaining plan fee accordingly and a Challan amounting Rs.7,32,671/- was issued to the owner.

- The owner deposited Rs. 7,32,671/- in LOA account andrequested to release the plans therefore the revised plan weresanctioned and released on 23.12.2006.

- The HRBC inspected the site on 19.06.2007 and observedfollowing violations:

- The width of ramp is 16 feet against 18 feet.- Noemergencyexitfrombasemeb) I

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- Two emergency stairs required but in this case nostairs found on 8th and 9th floor and only one stair foundfrom 2nd to 7th floor.

- The width of stair case is less than 4 feet.- Lift at North face shown within mandatory space.- Apartment 1st to 9th shown extended in mandatory

open space.- The violations are non-compoundable and must not be

condoned.- The owner then again submitted the revised plans on

17.03.2008 and requested to the commission for there-inspection. The commission again revisited the siteon 3.06.2008. The commission observations are asunder:

• Ramp width is 16'-6" against required 18'.• No emergency exit from basement.• External fire escape stairs lack access.• The width of helical stair case is less than 4 feet.• Apartment extends in mandatory space• Four halls measuring 3500 8ft have been

constructed on top floor whereas only two hallshave shown in the submitted plans. This result inadditional parking and building height exceedsthe permissible height limit of 150'.

• The violations are non-compoundable and mustnot be condoned.

- Note. The width of ramp for parking in the approvedplan dated: 13.03.2004 was 16 feet in accordance withthe prevailing regulations of LOA and the observationregarding width of ramp to be 18 feet was noted by theHigh Rise Building Commission under a mistake offact.

- The High Rise Building Commission did not allow thebuilder to complete the building until the defects areremoved.

- Owner was advised vide letter dated 24.07.2008 to remove theviolations and stop the construction activity. The owner submittedhis reply vide letter dated 4.12.2008 which was not satisfactory.This office vide letter dated 24.02.2009 again advised him tosubmit revised plan showing removal of defects. The owner videhis apPlica,tiond~ted4.4.20:9 stated th~vised plans

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I. Against the approved plan, an additional floor measuring2720.72sft is constructed for lift rooms. As a result, total heightof building from crown of road to parapet wall is 176.66ft,instead of approved height of 141'-3". Note: Height of thebuilding from crown of road to roof slab of 9th floor is 125.5ft.Whereas, height of the building from roof slab of 9th floor toparapet wall is 51.16ft. Thus, total height of building from crownof road to parapet wall is 176.66ft.

II. Guard room measuring (8.5'*7'= 59.5sft) is extended in sidespace as a result, reducing the side space to only 10'-7.5".

iii. However, 2 guard rooms measuring (4'-6" * 9'-6"= 42.75 sft)and (3'-10" * 12'-5" = 47.56 sft) are constructed in setback.

iv. 2 Generators are placed in the side space, hence reducing theside space to only 10'-3.5" and 10'-5.5" respectively.

v. Rear & side spaces are temporarily covered.vi. Emergency stair case for basement is not constructed.vii.Width of stair case is 3'-7" instead of 4'.Against the approved

plan, a void (30'-2" * 60'-3") is covered on 2nd floor. Thus, thereis excess coverage of 1817.7 sft.

viii. At site, instead of area measuring 1817.7sft, only 1518sftarea is left open as void on each floor, except 2nd floor.Therefore, there is excess coverage of 299.74 sft on each floor,resulting total excess coverage on 9 floors of 2697.66sft.

ix. There are projections of (2.5' * 32') on both sides of building,from 6th to 9th floor, hence, creating excess coverage of 640 sft.

x. Against the approved plan, both sides mandatory spaces are16'-4.5" each instead of 18'-4" each. Due to which, there isexcess coverage of 574.06 sft on ground floor.Present parking required banq.halls/restaurant = 32.5 CarParking requirement for office area = 1.53 CarsParking requirement for shopping area = 0.17 CarsParking requirement for hotel suits = 20.17 CarsTotal parking requirement = 54.37 CarsNote: Parking requirement for 11th floor is calculated as 4.56Cars. If added as per decision of the Commission then totalparking requirement would be 58.93 Cars.

xi. Parking requirement for motor cycles will be calculated as 16%of total car parking requirement.

xiii.Against the approved plan, basement is being used for differentother purposes besides using for parking.xiv. In the current parking plan, at some point drive way is less

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- .xv. Against the approved plan, helical stairs are not provided from2nd to th floor.

6. The main non-compoundable violation in this case isconversion of two basements constructed exclusively for parking to otheruses including offices, stores, laundry, banquet hall etc. As per recordavailable in the building file the plan for a hotel comprising two basements,mezzanine and five floors was sanctioned and released on 13.03.2004. Asthe two basements were exclusively reserved for car parking, those wereallowed to be extended under the mandatory spaces. Area of eachbasement was shown 17263 sft. for housing 113 cars out of the total of 126cars and also providing space for 70 motorcycles and 116 bicycles. On11.03.2004 the owner Sardar Oildar Ahmad Cheema entered into anagreement with the LOA to provide 38,713 sft. area for parking. Theagreement inter alia provided

"4. b. The developer and/or management body will ensure that atno stage the approved parking plan is altered or used for anyother purpose than the parking.

5. Whereas in the case of any default of any of the above saidconditions on the part of the 1st Party, the 2nd party shall beempowered to proceed against the 1st Party or his authorized /electedmanagement group in accordance with the law by penalizing in theshape of fines or cancellation of building plans or to take other legalaction including removal of illegal construction or any other hindrancefalling in the parking space or any other remedy penal action underthe law."

7. The representative of the applicant contended that theagreement dated 11.03.2004 stands superseded by the subsequentapproval of the building plan according to which the car parking area wasreduced and no fresh agreement was signed. According to the record theowner submitted a revised building plan for a hotel cum apartmentsbuilding comprising two Basements + Ground floor + Mezzanine + 10 flooron 22.12.2005, which were approved on 23.12.2006. The car parkingrequirements were worked out on the basis of the then prevalentRegulations @ one car for every 500 sft. for hotel area of 27254 sft. and @one car for each of the 62 apartments. Total parking requirement wasworked out 116 cars and 116 motorcycles. However, space for 126 carswas provided in the approved plan. The two basements were to house 115cars and 116 motorcycles and 11 cars were to be parked in the frontsetback. In the revised plan submitted on 18.03.2008 space for 102 carswas provided out of which 97 cars were to be housed in the two basem nts

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and 5 on the ground floor. Thus the area for car parking was reducedagainst the area of 38,713 sft., to be provided as per agreement. Thus theagreement was not adhered to by the parties. However, notwithstandingthe above mentioned deviation from the agreement, again both thebasements were reserved for car parking only in the plans approved on23.12.2006 as well as in the revised plans submitted on 18.03.2008. At thetime when the building plan up to the plinth level was released on13.03.2004, the LOA Building Regulations, 1984 as amended from time totime were in the field. The regulations No. 66 is reproduced below:

"The lower ground floor/basement if used for car parkingpurposes can be constructed after leaving 4 ft. space all aroundwithin the plot. No ramp or parking is allowed in the side andrear mandatory spaces, if these spaces are not abetting aroad."

"However, the level of the basement roof in the spaces requiredto be provided under Regulations 19, 20 & 21 shall not exceed6" from the centre of the road."

The lower ground floor/basement if used other than Car Parkingpurposes can be constructed after leaving all the mandatoryspaces as required under these Requlations."

In view of the above quoted regulations the basement extended under thesetbacks can only be reserved for car parking and its use other then carparking cannot be allowed. Provisions of inadequate parking or conversionof car parking area into other usages is a serious non-compoundableviolation. This is not an issue only related to urban development regulationsbut it is a public importance matter concerning general public welfare.Shortage of car parking resulting from the inadequate parking provided bythe owners of high rise building ultimately affects the public services. If theowners of high rise buildings will not provide car parking as stated in theplan or use the area reserved for car parking for other usages, it willaugment the traffic hazard and traffic congestion on roads and publicplaces. Such a violation will be at the cost of public interest and willaggravate the ever increasing parking problem in the City particularly incommercial areas. It is, therefore, recommended that the applicant shouldremove the entire additional construction in the basement to restore it asper approved plan.

8. The other issue which needs consideration is the raised level ofthe basement roof in the area of set-backs which is a non-compound ableviolation. It should have not been more than 6" above the level of M.M.Alam Road as per Regulation quoted in the preced·D<"t--.o

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Regulation, No. 5.6.3.d of the 2008 Regulations in vogue, the level of theroof of must not exceed 6" above the crown of the road. The Regulation isreproduced below:

"However, the level of the roof of the basement in themandatory open spaces required to be provided underthese Regulations shall not exceed 6 inches above thecrown of the road."

It was observed by the Commission during the visit that the raised platformin the front setback area is about 3~ ft. and in the rear is 1 ~ ft. above thecrown of the road. However, the applicant has pointed out that the level ofthe roof of basement does not exceed 6" above the road level. The level ofthe roof of the basement cannot be determined without properinvestigation. Raising the level of the roof of basement above 6" from theroad level is prohibited in the Regulations and not raising the setbackabove the basement roof level is prohibited. No regulations exist requiringto limit the height of the setback area above the level of the roof of thebasement. Therefore, it is recommended that the Director, Town Planning,LDA should get investigate and determine through the experts i.e. StructureEngineer/ Architect, height of the roof of the basement. In case as a resultof the investigation it is established that the roof of the basement has beenraised above 6" from the road level, then it is a non-compoundableviolation. As no penalty for its composition has been provided in theRegulations, the penalty has to be determined by the Commission. In casethe violation is established and the Structure Engineer advises that therectification can be made without damage to the main structure or withoutreducing the mandatory height of the basement in the area under thesetbacks, only then the applicant instead of its regularization may opt for itsdemolition. Otherwise, this violation, if established in the investigation, isrecommended to be regularized subject to the payment of penalty. In asimilar case of 83-Garden Block, New Garden Town (Reference No. 07)where the roof of basement was 1 ~ ft. above the crown of the road it wasrecommended to be regularized on payment @ Rs. 720/- per sft. The samepenalty is recommended to be imposed in this case subject to the result ofinvestigation.

9. Two generators are placed in the side space, hence reducingthe side space to only 10'-3.5" and 10'-5.5" respectively. Obviously it is nota permanent structure and at the same time, it is an essential requirementdue to electricity load shedding problem. As no regulations existed inrespect of the placement of the generators at the time of approval ofbuilding plans, it is recommended that the generator should be temporarilyallowed to be placed in the set back. In future . for placement

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generators should be specifically indicated in the building plan within thebuilding line or in some additional space in the front setback. The applicantshall abide by the regulations when framed by the LOA.10. Width of the main stair case is 3'-7" instead of required 4 feet.Width of the stairs cannot be increased without damage to the stairsstructure, therefore, it is recommended to be regularized on payment of apenalty of Rs. 10,0001- per floor.11. Two guard rooms measuring (4'-6" * 9'-6"= 42.75 sft) and (3'-10" * 12'-5" = 47.56 sft) are constructed in front setback area. Due tosecurity concerns deployment of guards is essentially required. Under theregulation one guard room of 100 sft., is allowed. Area of the two guardrooms does not exceed 100 sft. Therefore, it is not a serious violation. Theabove mentioned two guard rooms are recommended to be allowed for thetime being. A third guard room measuring (8.5'*7'= 59.5sft) is extended inthe side space resulting in reduction of the side space to only 10'-7.5". Inthe presence of two guard rooms even if the third one at its present placewas required, it should have been extended within the building line.Therefore, it is recommended that the extended area of the 3rd guard roomshould be demolished.12. Emergency staircase for the basement has not beenconstructed, the representative of the applicant agreed to provideemergency stairs in the revised plan. Thus the issue will be resolved. It willbe further ensured that the emergency stairs should be provided for safeexist for all the floors including those constructed above the permissibleheight if not demolished. The temporarily covered spaces in the rear andside setbacks can be made open without any problem. It is recommendedthat this violation should also be removed by the applicant.13. As per reference there is an excess coverage of approximately4274 sft. in the shape of projections, which should be worked out exactly inthe presence of the representative of the applicant. These projection formintegral part of the authorized building but violates space regulations. It is acompoundable violation and penalty thereof has been provided in theBuilding Regulations, 2005 under which the building plans were processedand approved. Penalty for the compoundable violation, therefore, isrecommended to be worked out and imposed at the rates provided at serialNo. 1 of the Appendix-O of the Regulations ibid. i.e. @ Rs. 226 per sft.Tentative amount of penalty comes to Rs.226 x 4274 sft.= Rs.9,65,924.

14. The applicant contended that the extra floors constructed inaddition to those provided in the sanctioned building plan are just lift headsand should not be counted for the purposes of height of the building,excess area and car parking. The area of each floor is 2720.72 sft. an

such a huge area cannot be considered a lift head. The area of lift headshould not exceed the area used for lifts in the other floors of sanctionedplans which is approximately 500 sft. The applicant's contentions that theextra floors are lift head only cannot be accepted. Therefore, the excessarea leaving the area of lifts and stairs is a useable area which has to becounted towards extra height, excess coverage and car parking. In therevised plan uses of the area of these floors must be specified. In view ofthis fact the height of these floors will also be taken into consideration fordetermination of the total building height. The excess coverage in theshape of extra floors constructed in addition to those sanctioned in theapproved plans is a non-compoundable violation as it exceeds theprescribed height restriction. As per Regulations, 2006, prevalent at thetime of sanction of building plans on 23.12.2006, provisions relevant to theheight of converted plots were as under:

"56. iii. For converted/commercialized plots in LOA jurisdiction,on payment of fee as may be fixed by the Authority from time totime and subject to fulfillment of other Regulations, the heightshall not exceed 1.5 times the width of right of way plus thewidth of the setback in front of the plot if any, subject tomaximum height of 200 ft. whichever is less and maximum FARof 1:8."

In the 2007 Regulations No. 3.6.2 as amended in 2014 the prescribedheight is the same. Relevant provisions reproduced below:

3.6.2. The height of any building shall not exceed 1.5 times thewidth of the right of way plus the width of the set back.However, extra height charges will have to be paid above 38ft.(11.58 m) height. (Building height = (ROWx1.5+setback)

The width of the road on which the plot is situated is 80 ft. Therefore, theprescribed building height in this case could have not exceeded accordingto the above mentioned formula 150 ft. i.e. (80'+40'+30'). At presentheight of the building is 176 ft. This being a non-compoundable violationcannot be condoned without penalty but subject to the provision ofstructure stability certificate from the Structure Engineer. In view of clause(c) of SUb-section(5) of Section 32 of the Lahore Development Authority(Amendment) Act, 2013, the amount of penalty for a non-compoundableviolation has to be determined by the Commission according to the natureof each case. Maximum extra height normal charges provided in theAppendix: C of the present Regulations are Rs. 100/- per sft. As exceedingthe prescribed height is a non-compoundable violation, three times of thecharges is recommended to be recovered as pe t to discourage non-

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compoundable violations, as already recommended in the similar cases ofPlot No.8 & Plot No. 16-Commericial Zone, Liberty Market (Reference No.08/2015 and 14/2015), wherein penalty for extra height has been charged@ Rs. 3001- per sft. in addition to the penalty for construction of extra floor@ Rs. 1800/- per sft. of excess coverage. In this case as well additionalcovered area has been created as a result of violation of the prescribedheight. Therefore, a penalty @ Rs. 2100 per sft. i.e. Rs.300+Rs.2100, isrecommended to be imposed according to the covered area above the 150ft. height. On payment of penalty and subject to the structure stabilitycertificate by the Structure Engineer approved by the LOA, the violationshall stand condoned. The exact covered area of the construction will beworked out on the basis of the revised plans to be submitted by theapplicant in pursuance of this order and the amount of the penalty will beworked out accordingly. In case of shortage of car parking additionalpenalty @ Rs. 9,52 ,000 per car will be recoverable as imposed in othercases of car parking shortage, already decided by the Commission.15. Unless the applicant submits revised building plans andspecifies the usage of the area not specified in the sanctioned plans andremoves violations made illegally in the basement as discussed above, theexact amount of penalties for compoundable and non-compoundableviolations cannot be determined. Therefore, the amount after submission ofthe revised plans will be determined by the LOA in the light of therecommendations contained in this order except where the penalty isalready worked out by the Commission.

16. In case any of the above recommended penalties or the ratesthereof, where penalties have not been worked out, are not acceptable tothe applicant, he may opt to rectify any or all the violation to avoid thepenalty. In case of any patent error or omission apparent from the face ofthe record, is subsequently discovered in any or all the abovemeasurements or computations, the Commission may rectify the same onan application by either party after affording an opportunity of being heardto the other party.

17. In view of the above discussed facts, the record perused, theevidence examined and discussions made with the representatives of theLOA and the applicant, recommendations of the Commission are as under:-

1) The applicant shall remove the entire additional construction inthe basement to restore it as per approved plan for car parkingonly.

2) The applicant shall provide emergency stairs in the basementsand for all other floors as per Regulati which cannot becondoned even by imposition of penalt

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3) The applicant will revise the building plans accordingly, eitherby rectification of the violation or on payment of penalty asdiscussed above. The revised plans submitted by the applicantwill be processed expeditioUsly by the concerned Director TownPlanning and if they are in line with these recommendationsand have no other non_compoundable violation, those will beaccepted within four months from the date of submission of therevised building plans at One Window by the applicant.

4) Unless the applicant files an appeal, he can opt at any timeafter receipt of this order but not later than 15 days after theexpiry of the period of appeal, to rectify the above discussednon-compoundable violation. In case he opts to rectify the non­compoundable violation, he shall ensure that all or any of theviolations which he agrees to remove are rectified before he

files the revised building plans.5) Within 30 days after clearance of the building plans or after the

expiry of the above mentioned period of four months, whicheveris earlier, Challan for payment of finally determined amount ofpenalty for the above discussed violations, simultaneouslyalong with the Challan(s) for any other penalties @ rates of2005. Regulations for the compoundable violations ofsanctioned building plans, already committed, if any, but notdiscussed above or not mentioned in the present reference bythe ~DA as well as any other charges recoverable from thea~ll~ant as per law, will be issued by the LOA to the applicant

:~~iPt s;a;~:~:a~I~n:YI the applicant within 60 days of th~regards the fi I . n case of any difference of opinion asthe revised n~I:;o~~~ of ~enalty de~erminedon the basis ofrecommendations of th~ c~proved In the light of thereferred to the Cornmissi mrrussron, the matter may be

rssion on appli t'the final amount of penaltles i .Ican s request to determine

6) The owner already d l~tS In the light of this order.eposi ed Rs 7 32 6711 . L

compoundable violations but t' , '. - In DA for certainIndicated in the refere N he detail of Violations is notf nce. 0 further p Itor the violations in res ect ena y shall be imposeddeposited by the owner p whereof the above penalty was

7) In case the applicant i tins ead of panon-compoundable violation 0 t yment. of. a penalty for theChallan will be reduced ~ s to rectify It, the amount ofat the ooti accordingly Re tif .e option of the applicant. . c I ication of violations,the approval of the revised I'Will be ensured by the LOA before~ pans. ~

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8) It is further recommended to resolve the issue that on paymentof the penalty as finally determined, the issuance of CompletionCertificate will be ensured by the LOA within 60 days of thepayment of the penalty or on completion of incomplete work, if

any, whichever is later.9) In case the applicant does not opt for payment of penalty and

does not demolish the illegal construction or rectifies the non­compoundable violation or fails to submits revised plans within60 days of the expiry of the time limit prescribed for appeal, theillegal construction shall be demolished or violation shall berectified by the LOA at the risk and cost of the applicant and carparking in the basements and on the ground floor shall berestore~ as .per already approve building plan. Till the time ofthe rect~flcatlonthe building may also be sealed if circumstanceso require. '~~Q~\'

ajam Saeed) '\(JavaiMember, LOA

Announced11.04.2016

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already submitted to LOA may be sanctioned or the matter may bekept pended till the decision of the Supreme Court of Pakistan.

3. The High Rise Buildings Commission (HBRC) in their reportmade the following recommendations:

"The building is in violation of LOA Regulations noted above,including non-compoundable violations such as construction atground level in mandatory open space. Moreover, insufficientwidth of stairs and absence of emergency stairs endanger thelives of occupants and must not be condoned"

4. According to the reference at present the building standscompleted up to the 9th floor and a hotel is running with the followingviolations of the LOA Building Regulations;

SNo Non-Compoundable Violations CompoundableViolations

1. Guard rooms constructed in setbackspace.

2. Generator installed in side space.3. Rear space & side spaces are

temporarily covered.4. Emergency staircase for basement

not constructed.5. Construction of two additional lift

room halls without approval due towhich building height is about 162feet against the height of 150 feet asper submitted revised plans.

6. Excess coverage ofapproximately 4274sft. done at site in theshape of projections.However, due to thisexcess coverage carparking is not affectedas the total numbersof rooms remain thesame.

5. The representative of the LOA was asked to prepare a detailedreport regarding the violations. The report prepared b the Dy. Director, TPis reproduced below:

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