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In the matter of:-

MYA son of KDA resident of _________ District Rawalpindi.

Dr. ANK son of NMK resident of ________________, presently C/o
______________, Rawalpindi.

Respectfully Sheweth,
1. That the plaintiff is posted as Patwari and presently is serving at Tehsil
Office, Rawalpindi and having immaculate and spotless reputation in his
2. That the plaintiff as law-abiding citizen and command great respect amongst
the locality and in the eyes of relatives and friends as well as in department.
3. That the defendant is a Doctor by profession and whatever has been done by
him mentioned below is due to misuse of his post / position.
4. That the defendant malafidely and for reasons not known has previously
filed an application before the SHO, P.S Saddar Barooni, contending therein
false and frivolous assertions and later on, the defendant by using his
influence and position got registered a false and frivolous case FIR No. 56
dated 10-02-2008 P.S Saddar Barooni, District Rawalpindi U/s 447/379/34
PPC against the plaintiff and others by narrating false and concocted story
and the story mentioned in his application, on the basis of which the said
case was registered is nothing but a cock and bull story.
5. That the defendant leveled serious allegations against the plaintiff.
6. That after the registration of the case, the plaintiff engaged counsels in the
said case and filed his post arrest bail in the competent court of jurisdiction.
7. That during the interregnum the different responsible police officers probe
and interrogated the matter and ultimately found the allegations false,
frivolous, baseless and concocted.
8. That on 14-02-2008, in Daily Jang and other renowned Newspapers, it was
published that the plaintiff has grabbed the valuable property of the
defendant and stolen certain valuable things of the defendant and
furthermore, it is pertinent to mention here that on this account, the plaintiff
was suspended from his service. This allegations was also baseless,
however, the same is derogatory and published in a newspaper, having very
high circulation in the country.
9. That due to the publication of false, frivolous and baseless news, without
any basis and purely engineered on malice and filing of false case, the
plaintiff suffered mental agonies, torture and fear.
10. That after the registration of the case, the thorough investigation was
conducted by the investigating agency and ultimately the plaintiff found
innocent in the said case. The police has prepared the Cancellation Report/
Ikhraj Report U/s 173 Cr.P.C which was duly signed by the I.O as well as
the SHO of concerned police station.
11. That when the plaintiff found innocent, he withdrawn his bail application
from the competent court of jurisdiction on the statement of the I.O of the
case that the above said case/ FIR being baseless is cancelled.
12. That the plaintiff faced the agonies to approach the competent court of
jurisdiction and during this protected period the plaintiff remained under
continuous mental torture, harassment, and fear.
13. That due to the malicious prosecution on the part of the defendant, the
reputation of the plaintiff as well as his family has been damaged in such
that there could not be repaired. The credibility built by the plaintiff during
span of time was shattered due to lodging of the frivolous, fictitious and
concocted FIR against the plaintiff. The defendant has also extended threats
for dire consequences to the plaintiff.
14. That the defamatory applications / acts by the defendant was having a
tendency injure the reputation of the plaintiff i.e. to lower him in the
estimation of others and to bring him in inobliquy contempt and ridicule and
also injured his profession.
15. That the plaintiff was prosecuted on baseless criminal charges, the same
was ended in favour of the plaintiff and all this was malicious without
reasonable and probably cause.
16. That the plaintiff claim general and special damages on account of mental
torture, agony, financial loss and injury inflicted to his reputation, honour as
well the detail of the same are mentioned as under:
17. General Damages
a. Injury/ loss to reputation as a person = Rs.3,00,000,00/-
b. Mental torture and physical agony = Rs. 1,00,000,00/-
c. Loss in family honour = Rs. 99,00,000/-
2. Legal Assistance
a. Legal assistance & General = Rs.100,000/-
GRAND TOTAL = Rs.5,00,000,00/-
17. That the plaintiff contacted the defendant and sent him a legal notice and
demanded above-referred amount as damages by the defendant against the
plaintiff but the defendant flatly refused to accede to the legitimate and legal
demand of the plaintiff, hence this suit.
18. That the cause of action firstly accrued on the submitting of false,
frivolous, baseless and concocted application, then lodging of FIR and
publication of news and finally on the refusal of the defendant to pay the
above said amount as damages and is still continuing.
19. That the parties are residents of Rawalpindi, hence this Honourable Court
has the jurisdiction to entertain the matter in hand.
20. That the value of the suit for the purposes of court fee and jurisdiction is
fixed as Rs. 5 Cror and the requisite court fee will be affixed as and when
required by this Honourable Court.
In view of above, it is most humbly prayed that the suit of the plaintiff for
recovery of Rs. 5 Crore as malicious prosecution damages, may kindly be
decreed in favor of the plaintiff and against the defendants with costs.

Any other relief, which this Honorable Court deems fit and proper may also be
granted to the plaintiff.

(Muhammad Mateen)
Advocates High Court,
Certified that the contents of the para No. 1 to 18 are true and correct and the
remaining paras are also correct and true as per information received.

No suit, appeal, revision etc is pending between the parties of same nature in
any competent court of law and this is the first suit for damages is being filed by
this Honorable Court as per information received from my client

In the matter of:-
MYA son of KDA resident of _________ District Rawalpindi.
Dr. ANK son of NMK resident of ________________, presently C/o
______________, Rawalpindi.

That I, MYA son of KDA resident of ______________________ do hereby
solemnly affirm and declare as under:-

That the contents of the above suit are true and correct to the best of my
knowledge and belief and nothing has been concealed therefrom.

Verified that the contents of the affidavit are true and correct to the best of my
knowledge and belief.