IN THE COURT
OF SENIOR CIVIL JUDGE,
Muhammad Naveed son of Kamran Baig, resident of House No.--
Street No. – Samay Bakers Badami
Bagh,
Plaintiff
Malik Ramzan son
of Malik Javed resident of
House No. -– Street No. -- Near Wadi Masjid, Mohala Rajpootan, Shadi Pura,
Defendant
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SUIT FOR PERMANENT INJUNCTION RESTRAINING
THE RESPONDENT FROM INTERFERING INTO THE LAWFUL POSSESSION OF THE PLAINTIFF.
1.
That
the names and addresses of the parties have been given completely and correctly
for effecting service upon the parties.
2.
That
the plaintiff is bona fide purchaser of land measuring 2 Kanals
2 ¾ Marlas & 4 Kanals
situated in Mohala Islampura
Aalia Town, Sukh Nahar, Mouza Mehmood
Booti, Near Band Road, Lahore vide agreement dated
05-12-1984 & 28-12-1984 and since than the plaintiff is enjoying the
possession of the land without any interfering.
3.
That
some day ago the defendant alongwith some persons approached to the plaintiff
at site and threatened the plaintiff to dispossessed the plaintiff forcibly. The
plaintiff showed his agreement /entitlement documents to the defendants.
4.
That
the plaintiff has been enjoying the possession for the last 26 years without
any interference, the defendant has not adopted the legal process to resolve
the matter.
5.
That
the plaintiff has invested a huge amount on the said land from his own pocket
and if the defendant has succeeded in his nefarious design the plaintiff suffer
an irreparable loss and injury, hence this suit.
6.
That
the cause of action accrued, in favour of the plaintiff and against the
defendant some days ago when the defendant tried to dispose the plaintiff from
his owned land without any document, cogent reason and justification and still
is continuing.
7.
That
the parties reside in
8.
That
the prescribed court-fee has duly been affix on the petition.
PRAYER:
Under
the circumstances and submission expounded above, it is therefore, humbly
prayed that a preliminary decree may very graciously be passed in favour of the
plaintiff and against the defendant, with a direction to restrain the defendant
to dispossessing the plaintiff from the suit property/ land measuring 2 Kanals
2 ¾ Marlas & 4 Kanals
situated in Sukh Nahar, Mouza Mehmood Booti,
Near Band Road, Lahore
It is further
prayed that during the pendency of this suit, the defendant be permanently
restrained from disposing the plaintiff from the suit property/ land measuring 2 Kanals
2 ¾ Marlas & 4 Kanals
situated in Mohala Islampura
Aalia Town, Sukh Nahar, Mouza Mehmood
Booti, Near Band Road, Lahore.
Ad-interim status
quo may also be ordered to be maintained till the final decision of this
suit.
Any other relief
which this honourable court deems fit and appropriate in favour of the
plaintiff may also be awarded. Cost
of the suit may also be awarded.
Plaintiff
Through:-
Mudaber Hussain Qureshi
Advocate High Court
127 - District Courts
VERIFICATION:
Verified
on oath at
Plaintiff