IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN

 
 
 
 
 

 
  
 

Civil Suit No.___________/2020

SHAFIQ UR REHMAN S/o Umer Din Caste Rajpoot R/o Dara

Muhammadi Tehsil & Distt. Multan.
                                                                         Plaint
iff
VERSUS
1. Ali Hassan S/o Ghulam Qadir Caste Awan R/o
Chah Bagh wala Dara Bhudho malik Post office
Ramkali Tehsil & Distt. Multan.
2. Muhammad Javid Sindho S/o Muhammad Aslam
Caste Sindho jatt R/o Basti Shorkot Near Fazal
Model Bhawalpur Rd. Multan.
3. Faizan Ahmed S/o Abdul Aziz Caste Shaikh R/o 2-
Khayaban e Aziz Bosan road Multan.
                                                                      Defenda
nt
***
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 05M-00Y, Situated at Mouza
Dera Muhammadi Tehsil City Distt. Multan. Mutated No.
27068 Dated 11-01-2019.
 
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 plaintiff purchased bona fide the above stated
suit property from defendants no 2&3 vide mutation
deed No. 27068 dated 11-01-2019.
5. That plaintiff became the sole owner and possessor
of the suit property from the date of purchase from
defendants No. 2&3 and since then plaintiff is
enjoying his legal rights peacefully.
6. That a few months ago plaintiff started to construct
a dwelling house at suit property.
7. That some days ago the defendant No. 1 along with
some persons approached to the plaintiff at suit
property and threatened the plaintiff to
dispossessed the plaintiff forcibly. The plaintiff
showed his ownership documents to the defendant
No. 1.
8. That the plaintiff has been enjoying the possession
for the almost last 2 years without any interference,
 the defendants has not adopted the legal process to
resolve the matter.
9. That the plaintiff has invested a huge amount on
the said land from his own pocket and if the
defendant No. 1 has succeeded in his malicious &
nefarious design the plaintiff suffer an irreparable
loss and injury, hence this suit.  
10. That the cause of action accrued, in favour of
the plaintiff and against the defendants 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 plaintiff and
against the defendants, with a direction to restrain
the defendants to dispossessing the plaintiff from
the suit property.
                It is further prayed that during the
pendency of this suit, the defendant No. 1 be
permanently restrained from disposing the plaintiff
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
plaintiff may also be awarded. Cost of the suit may
also be awarded.

Plaintiff
 
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