IN THE COURT OF SENIOR CIVIL JUDGE,
Mst. Munaza Jabbar
wife of Muhammad Jabbar D/o Haji
Allah Ditta, R/o House No. --, Mina Bazar, Hanjarwal,
Plaintiff
1.
Public at Large.
2.
Nadra through its Director
General,
Defendants
* * *
SUIT FOR DECLARATION
1.
That the plaintiff is a citizen of
2.
That the plaintiff is a illiterate lady. The father
of the plaintiff Muhammad Younas (Late) was also illiterate person and due to
illiteracy he mentioned the date of birth of plaintiff 04-04-1974 instead of
15-06-1982 and name of plaintiff Naghma Younas instead of Naghma Rohi in NADRA
and the same wrong name and date of birth was incorporated by the NADRA
National I.D. Card of plaintiff.
3.
That a fortnight ago it came into the knowledge of
plaintiff that her wrong name and wrong date of birth was incorporated in her
National I.D. Card number. The plaintiff with her brother approached the NADRA
Head Office and requested to correct her name and date of birth in her National
I.D. Card according to her original name and date of birth but the NADRA
department demanded declaratory decree for correction of name and date of birth
of plaintiff from court of competent jurisdiction, hence this suit.
4.
That the cause of action firstly arose in favour of
plaintiff against the defendant when the plaintiff came to know the insertion
of wrong name and date of birth of the plaintiff in the record of defendant
No.2, it again accrued when plaintiff
requested for correction the name and date of birth of the plaintiff but the
defendant demanded declaratory decree
for correcting name and date of birth, hence this suit.
5.
That the cause of action accrued at
6.
That the value of the suit for the purpose of
jurisdiction and court fee is fixed at Rs. 200/- which is exempted from court
fee.
PRAYER:
It is therefore, most respectfully prayed that that a declaratory decree may kindly be passed
in favour of plaintiff against the defendant No.2 and may kindly be directed
the defendant No. 2 to correct the name and date of birth of plaintiff in his
record and incorporate his original name and date of birth in his record.
Any other relief which this honourable court deems fit
and appropriate in favour of the plaintiff may also be awarded.
Plaintiff
Through:-
COUNSEL
VERIFICATION:
Verified on oath at
Plaintiff