IN THE COURT OF SENIOR CIVIL JUDGE, LAHOR

Suit No. _______/2015

Sana Butt W/o Mehmood Butt R/o Nathoki’ Post Office Bata Pur’ Tehsil Cantt’ District Lahore.

Plaintiff

Versus

1. Public-at-large.
2. NADRA through its Director General, Provincial Headquarter Punjab, 14/1 Sarwar Road, Lahore Cantt.

Defendants

SUIT FOR DECLARATION

Respectfully Sheweth:

1. That the names and addresses of the parties have been correctly provided in the heading of the suit which are sufficient for the purposes of service of summons/notices and other processes to be issued by this Honorable Court.

2. That the brief facts of the case are that the name of the plaintiff is Sana Butt which was correctly written in the birth certificate of plaintiff and as well as on the old national identity card, issued by concerning authority.

3. That the correct name of the plaintiff which is also written in the Nikha Nama is Sana Butt. (A copy of birth certificate, Nikaha Nama and Old CNCIC is attached as (Annexure-A, B and c).

4. That the name of plaintiff as per NADRA record was wrongly written as Sania Butt instead of Sana Butt which is not correct.

5. That the plaintiff approached the defendant No.2 along with above record with the request to correct her name in the record of NADRA and issue a new CNIC with corrected name of the plaintiff but defendant No.2 flatly refused to accept the genuine request of the plaintiff.

6. That the cause of action firstly accrued when defendant No.2 issued CNIC of the plaintiff with incorrect the name of the plaintiff and secondly a few days ago when plaintiff approached the officials of the defendant No.2 who refused to accept the genuine request of the plaintiff.

7. That the plaintiff is residing in Lahore, office of defendant also present in Lahore and cause of action also accrued in Lahore, hence this Hon’ble Court has got the jurisdiction to adjudicate upon the matter.

8. That the value of suit for the purpose of court fee and jurisdiction is fixed for at Rs. 200/- hence no court fee is required to be affixed.

PRAYER:

In view of the above, it is most respectfully prayed that:

(i) A declaratory decree may very kindly be passed in favour of the plaintiff and against the defendants with corrected the name of the plaintiff as per birth certificate, old CNIC and Nikha Nama.

(ii) Respondent No.2 may very kindly be ordered to correct the plaintiff’s name in plaintiff’s CNIC.

(iii) Any other relief which this Hon’ble Court may deem fit and appropriate may also be awarded.

Plaintiff

Through;-

Mudaber Hussain Qureshi
Advocate High Court

Verification:

It is verified on oath at Lahore on this 18th day of Nov, 2015 that para No. 1 to 4 are correct to the best of my knowledge and para No. 5 to 7 are correct to the best of my belief.

Plaintiff