IN THE COURT OF SENIOR CIVIL JUDGE, RAWALPINDI

Pukhraj Kumar S/O Kumar Singh, R/O House 31-E, Village Sadiqabad,
Rawalpindi.
…PLAINTIFF
Versus

Deeru Raj S/O Raj Pankaj, R/O House 31-F, Village Sadiqabad, Rawalpindi.

…DEFENDANT

SUIT FOR PERMANENT INJUNCTION

Respectfully Sheweth:

1. That both parties are residing in Village Sadiqabad, Rawalpindi, so

address are sufficient for process server.

2. That brief facts giving rise to the instant suit are that on 10-10-10,
plaintiff bought house 31-E in Village Sadiqabad, Rawalpindi which is
extended 20 Marlas on Khewat number 312, Khatuni number 321,
Khasra number 132 wide Registered Sale Deed 2534. (Attested copy of
Sale Deed annexed at Annexure A)

3. That the supra mentioned area is a purely residential area and people
belonging to different backgrounds and distinct nature, creed, cast,
religion and mentality dwell in the said locality.

4. That the plaintiff had occupied the supra purchased house on 14-10-10
along with his family and noticed that defendant along with his cricket
team, used to play cricket daily between 6pm – 10pm in the ground
adjacent to plaintiff’s house which is 40 Marlas extended on Khewat
number 212, Khatuni number 317, Khasra number 132.
5. That apart from defendant’s cricket players, many spectators gather at
the site for uproar and turmoil. That some pictures of defendants playing
cricket have been captured by plaintiff. (Picture annexed at Annexure
B)

6. That the blind shots that defendant takes negligently cause damage to
property of plaintiff. That the ball landed several times in the property of
plaintiff and had once hit the front window of the house, twice hit the
bumper of car (Registration Number 1371), once hit the glass door of
front and back balcony each and the twice hit the water tank of plaintiff’s
house, resulting in damages.
That the spectators also caused damage to plaintiff’s vehicle (Registration
Number 8752) three times and killed all precious ornamental plants
outside plaintiff’s residence. (Pictures of damaged property annexed at
Annexures C, D, E, F, G, H, I)

7. That due to nuisance caused by defendant, there is environment with

lack of peace and discomfort. Residents are suffering mental torture and
the jobs and business of people are being affected due to lack of comfort.
That plaintiff also incurred penalty in lieu of arriving late on job every
day. That following damages are incurred by plaintiff due to negligence of
defendant and nuisance caused;
a. 34,000 PKR/- for repairing damaged window (Receipt annexed at
Annexure J)
b. 80,000 PKR/- for repairing car’s bumper (Receipt annexed at
Annexure K)
c. 92,000 PKR/- for repairing car’s bumper (Receipt annexed at
Annexure L)
d. 2,22,000 PKR/- for repairing broken front door of balcony (Receipt
annexed at Annexure M)
e. 2,12,000 PKR/- for repairing broken back door of balcony (Receipt
annexed at Annexure N)
 f. 1,50,000 PKR/- for repairing broken water tank (Receipt annexed at
Annexure O)
g. 1,50,000 PKR/- for repairing broken water tank (Receipt annexed at
Annexure P)
h. 20,000 PKR/- for repairing vehicle’s back glass (Receipt annexed at
Annexure Q)
i. 35,000 PKR/- for repairing vehicle’s side door (Receipt annexed at
Annexure R)
j. 50,000 PKR/- for repairing vehicle’s headlights (Receipt annexed at
Annexure S)
k. 70,000 PKR/- as total cost of all ornamental plants (Receipt annexed
at Annexure T)
l. 2,80,000 PKR/- as penalty for arriving late at job (Letter annexed at
Annexure U)
Total Damages: 1,395,000 PKR/-

8. Cause of action first arose on 15-10-10, when the plaintiff approached

defendant during cricket match and asked him to wind up and leave the
ground, but he denied explicitly and continued with the match.

9. Cause of action arose second time on 04-11-10 when on the request of

the plaintiff, the owner of the supra mentioned adjacent ground, Mr.
Ranjeet Oberoi forbade the defendants from playing in the ground but
when the owner left the village to return back to his residence in Kohat,
the defendants again started playing.

10. Cause of action arose third time on 30-11-10 when plaintiff issued
legal notice to the defendant intimating him of the damages mentioned in
para 7, clauses a, c, e, d, g and i, but the defendants refused to
compensate for damages in respond to the legal notice. (Copy of Legal
Notice and Response annexed at Annexures S and T respectively)
11. That cause of action has accrued in Rawalpindi where the suit
property situate and the parties reside hence this Hon’ble Court has
jurisdiction to try this suit.

12. That prescribed court fee has been affixed with plaint.

PRAYER:

Its beseeched submission to this Hon’ble Court that kindly may accept
this instant suit for damages of rupees 1,395,000 PKR/-.

It is further prayed that kindly may grant permanent stay order to

defendants from playing in the ground.

It is further prayed that kindly may decree this instant suit along with
filing cost in favour of plaintiff and against the defendant.

If court deems fit and appropriate, kindly may grant interim relief.

Any other relief which this Hon’ble Court deems just and proper may
also be awarded to Plaintiff to meet ends of justice. 

PLAINTIFF

Through

FARYAL SHABBIR SAVEEZA KABSHA

ABBASI
Advocate High Court Advocate High Court
Rawalpindi Rawalpindi

NABILA ASIF ANUM

JARRAL
Advocate High Court Advocate High Court
Rawalpindi Rawalpindi

Verification
Verified on oath in Rawalpindi on 14 th day of December 2010 that the
contents of Para No. 1-10 are true and correct to the best of my knowledge
and 11-12 to the best of my information and belief.

Plaintiff