In The Court of Senior Civil Judge, Multan

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IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN

 
 
 
 
 

 
  

Civil Suit No.___________/2020

1. Muhammad Zubair
2. Muhammad Ajmal S/o Shokat Ali Caste Rajpoot
R/o Dara Muhammadi Tehsil & Distt. Multan.
                                                                        Plainti
ffs
VERSUS

1. Ali Hassan
2. Abdul Sattar S/o Ghulam Qadir Caste Awan
R/o Chah Bagh wala Dara Bhudho malik Post office
Ramkali Tehsil & Distt. Multan.
3. Faizan Ahmed S/o Abdul Aziz Caste Shaikh R/o 2-
Khayaban e Aziz Bosan road Multan.
4. Muhammad Javid Sindho S/o Muhammad Aslam
Caste Sindho jatt R/o Basti Shorkot Near Fazal
Model Bhawalpur Rd. Multan
                                                                     Defenda
nts
***
SUIT FOR PERMANENT INJUNCTION
RESTRAINING THE RESPONDENT FROM
INTERFERING INTO THE LAWFUL
POSSESSION OF THE PLAINTIFF.

Detail of Suit Property:


Khawat No. 673 Black ink, 665 Red ink, Khatooni No.
1128 to 1138, combined Khata 225/37410, Total Land
62K-07M, Transferred Land 07M-15Y, Situated at Mouza
Dera Muhammadi Tehsil City Distt. Multan. Mutated No.
27792 Dated 29-06-2019

 
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 Defendants No. 2&3 purchased 62K-07M land
which includes above stated suit property, from
defendant No. 1 and other co-owners through
registered agreement of sale deed No. 14446 dated
24-12-2013.
3. That Defendants No. 2&3 after acquiring/
Possession of 62K-07M land, developed into
systematic plots by sub-division of land.
4. That plaintiffs purchased bona fide the above stated
suit property from defendants no 2&3 vide Mutation
Deed No. 27792 dated 29-06-2019.
5. That plaintiff became sole owner and possessor of
the suit property from the date of purchase from
defendants No. 2&3 and since then plaintiffs are
enjoying their legal rights peacefully.
6. That a few months ago plaintiffs started to
construct a dwelling house at suit property.
7. That some days ago the defendant along with some
persons approached to the plaintiffs at suit property
and threatened the plaintiffs to dispossess the
plaintiffs forcibly. The plaintiffs showed their
ownership documents to the defendants.
8. That the plaintiffs had been enjoying the possession
for the almost last 2 years without any interference,
the defendant No. 1 has not adopted the legal
process to resolve the matter.
9. That the plaintiffs have invested a huge amount on
the said land from his own pocket and if the
defendant has succeeded in his malicious &
nefarious design, the plaintiffs would suffer an
irreparable loss and injury, hence this suit.  
10. That the cause of action accrued, in favour of
the plaintiffs and against the defendant No. 1 some
days ago when the defendant No. 1 tried to dispose
the plaintiff from his owned land without any
document, cogent reason and justification and still
is continuing.
11. That the parties reside in Multan and cause of
action has also arisen here, therefore this learned
court has got jurisdiction to try and adjudicate
upon this matter.
12. That suit value for the court fee is affixed
1000/- PKR which is exempted hence this suit. 

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 plaintiffs and
against the defendants, with a direction to restrain
the defendant No. 1 to dispossessing the plaintiff
from the suit property.
                It is further prayed that during the
pendency of this suit, the defendants be
permanently restrained from disposing the plaintiffs
from the suit property.
               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
plaintiffs may also be awarded. Cost of the suit may
also be awarded.

 
Date Plaintiffs
 

Through:-
                                                                       
                    
Tariq Raheem Khan
Advocate High Court

Junaid Faizan
Advocate
17 – Ansari Block. District Courts 
Multan
 

VERIFICATION:
Verified on oath at Multan on this th day of November
2020 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

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