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Respectfully Sheweth:-
1. That resondant # 1 filled a suit for specific
performance titled Shahid Jameel Nasir versus
Khalid Jameel dated 3-12-12 in relation to the suit
property which after proceedings was decreed
exparte on 21-1-2013.
2. That various proceedings were done after passing
the decree of aforementioned suit. And during the
proceedings respondant # 2 filed application for
quashment of decree & order of above mentioned
suit, which was quashed consequently on 21-10-20.
Afterwards that suit was dismissed due to non
perusal on12-01-2016.
3. That after quashment, respondent # 2 sold 26K-
12M land out of his suit property to applicant vide
registary, after that mutation was generated,
verified & accepted .
4. That applicant is sole owner & possessor
aforementioned 26K-12M land. This was veiled &
kept away from te knowledge of the court which
amounts to fraud and misrepresentation.
5. That respondents obtained decree which was
collusion & complicity among them, which is far
from reality and truth .
6. That during proceedings, ownership of suit property
has not been declared & entered in the honourable
court. Resultantly decree form court is obtained due
to misrepresentation & fraud.
7. That the proceedings of suit were kept secret from
applicant which were based on surreptitious &
conspiring plot of respondents.
PRAYER:
Date
Plaintiff
Through:-
Faizan Ahmad
Advocate High Court
17- Ansari Block, District Courts
Multan
Junaid Faizan
Advocate
17 – Ansari Block. District Courts
Multan