IN THE COURT OF SENIOR CIVIL JUDGE Islamabad.

Mr. _________, S/o __________R/o _______________District Islamabad.

…PLAINTIFF

VERSUS

__________ S/o ____________ R/o _______________, Islamabad.

Halqa Patwari, ______.
Tehsildar, Islamabad.
…DEFENDANTS

SUIT FOR DECLARATION AND PERMANENT INJUNCTION.

CERTIFICATE:-

(a). That no subject matter or material in issue in the instant suit has directly or substantially been
in issue in former suit between the same parties or between the parties under whom they or any
of them claim litigating under the same title before a court of competent jurisdiction.
(b). Further the subject matter or material in issue never came up before the Honorable High Court
or the Supreme Court.

RESPECTFULLY SHEWETH:-

1. That the plaintiff is owner in possession of land measuring 05 marlas, falling in khewat No.
______, Khatooni No. _______ Khasra No. _____, situated in revenue estate of
_______________, District Islamabad. (Hereinafter referred as suit land.).
That the plaintiff became the owner of the suit land through inheritance and the suit land
got mutated in the name of plaintiff through mutation No. ______dated __________(Copy
of fard is enclosed herewith as annexure “A”).

2. That the plaintiff is enjoying peaceful possession of the suit land without any interruption
or interference.

3. That now the defendant No. 1 who has no concern whatsoever with the suit land, has
started interference into the peaceful possession of the plaintiff over the suit land and wants
to illegally dispossess the plaintiff from the suit land without any rhyme and reason, which
act of the defendant No.1 is illegal, unlawful and ineffective upon the rights of the plaintiff.

4. That the defendant No. 1 for the purpose of illegally grabbing the suit land and to
dispossess the plaintiff has placed the building material beside the suit land.

5. That the defendant No. 1 is continuously threatening, harassing and blackmailing the
plaintiff for the dire consequences, that defendant is going to grab the suit land forcibly,
illegally and without adopting due course of law, dispossessing the plaintiff from the suit
land.

6. That the above said acts of the defendant No. 1 are illegal, unlawful, and ineffective upon
the rights and interests of the plaintiff.
 7. That the plaintiffs repeatedly requested the defendant1 not to threat, harass or blackmail,
interfere and dispossess the plaintiff from the suit land. Further be restrained from their
illegal designs, but the defendant who is under influence, is adamant to do so, hence this
suit.

8. That the cause of action firstly accrued to the plaintiff one week ago when the defendant
No. 1 started interference into the peaceful possession of the plaintiff over the suit land
and lastly a day before when the defendant No. 1 refused to accede the request of the
plaintiff, and it continued.

9. That the cause of action accrued at Islamabad and the suit land is also situated at
Islamabad, hence this honorable court has got the jurisdiction to entertain and try the suit
and adjudicate upon the matter.

10. That value of the suit for the purposes of court fee and jurisdiction is fixed at Rs. 800/-
which is exempted from levy of the court fee.

PRAYER:-

Under the circumstances, it is respectfully prayed that a decree for declaration to the effect
that the plaintiff is lawful owner in possession of suit land. Further that the acts of the
defendant No.1 are illegal unlawful, null and void ineffective upon the rights of the plaintiff
may kindly be passed.

As a consequence relief that the defendant No. 1 may kindly be restrained from
threatening, harassing, blackmailing, interfering, dispossessing the plaintiff illegally and
unlawfully, further more the defendant No. 1 be restrained from changing the nature of the
suit land may kindly be passed in favour of plaintiff and against the defendant No. 1 in the
best interest of justice and fair administration of law.

Any other relief, which this honorable court deems fit and proper, may also be awarded to
the plaintiff.

PLAINTIFF
THROUGH
ADVOCATE