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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
* * *
SUIT FOR PERMANENT INJUNCTION RESTRAINING THE RESPONDENT FROM INTERFERING INTO THE LAWFUL POSSESSION OF THE PLAINTIFF.
Respectfully Sheweth:-
- That the names & addresses of the parties have been given completely & correctly for effecting service upon the parties.
- That the plaintiff is bona fide purchaser of land measuring 2 Kanals 2 ¾ Marlas & 4 Kanals located in Mohala Islampura Aalia Town, Sukh Nahar, Mouza Mehmood Booti, Near Band Road, Lahore vide agreement dated 05-12-1984 & 28-12-1984 & since than the plaintiff is enjoying the possession of the land without any interfering.
- That some day ago the defendant alongwith some persons approached to the plaintiff at site & threatened the plaintiff to dispossessed the plaintiff forcibly. The plaintiff showed his agreement /entitlement documents to the defendants.
- 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.
- That the plaintiff has invested a huge amount on the said land from his own pocket & if the defendant has succeeded in his nefarious design the plaintiff suffer an irreparable loss & injury, hence this suit.
- That the cause of action accrued, in favour of the plaintiff & against the defendant some days ago when the defendant tried to dispose the plaintiff from his owned land without any document, cogent reason & justification & still is continuing.
- That the parties reside in Lahore & cause of action has moreover arisen here, therefore this learned court has received jurisdiction to try & adjudicate upon this matter.
- That the prescribed court-fee has duly been affix on the petition.
PRAYER:
Under the circumstances & submission expounded above, it is therefore, humbly prayed that a preliminary decree may very graciously be passed in favour of the plaintiff & 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 located 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 located in Mohala Islampura Aalia Town, Sukh Nahar, Mouza Mehmood Booti, Near Band Road, Lahore.
Ad-interim status quo may moreover be ordered to be maintained till the final decision of this suit.
Any other relief which this honourable court deems fit & appropriate in favour of the plaintiff may moreover be awarded. Cost of the suit may moreover 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 & correct to the best of my knowledge, information & belief & nothing has been concealed so far.
Plaintiff
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