IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

 

 

 

 

 

 

 

 

 

Civil Suit No.___________/2012

Muhammad Naveed son of Kamran Baig, resident of House No.-- Street No. Samay Bakers Badami Bagh, Lahore.

Plaintiff

VERSUS

Malik Ramzan son of Malik Javed resident of House No. - Street No. -- Near Wadi Masjid, Mohala Rajpootan, Shadi Pura, Band Road, Lahore.

Defendant

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SUIT FOR PERMANENT INJUNCTION RESTRAINING THE RESPONDENT FROM INTERFERING INTO THE LAWFUL POSSESSION OF THE PLAINTIFF.

 

Respectfully Sheweth:-

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 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 Lahore and cause of action has also arisen here, therefore this learned court has got jurisdiction to try and adjudicate upon this matter.

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 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 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 Lahore

 

VERIFICATION:

Verified on oath at Lahore on this 16th day of January 2012 that the contents of the Suit are true and correct to the best of my knowledge, information and belief and nothing has been concealed so far.

 

 

 

 

Plaintiff