IN THE COURT OF MR.

ASAD ISLAM MAHNI, MEMBER

(CONSOLIDATION), BOARD OF REVENUE, PUNJAB, LAHORE.

Muhammad Hussain s/o Ahmad Din, through general

attorney Aftab Ahmad, R/o H.No.36, Kausar Road,
Karishan Naghar Islampura, Canal, Lahore.

Petitioner
Versus

1. Muhammad Akram s/o Barkat Ali,

R/o Ali Street No.1 PECO Road, Hajvery Town,
Mondy Stop, Multan Road, Lahore;
2. Consolidation Officer, Niazbaig, Lahore;
3. Tehsildar, Niazbaig, Lahore;
4. Halqa Patwari, Niazbaig, Lahore.

Respondents

REVIEW PETITION U/S 8 OF THE PUNJAB BOARD OF

REVENUE ACT, 1957, IN ROR NO.1789/2019, TO
REVIEW THE ORDER DATED 24-09-2020, PASSED BY
THE MEMBER (CONSOLIDATION) BOARD OF
REVVENUE, PUNJAB.

CLAIM IN REVIEW By accepting review petition the order dated

PETITION: 18.08,2020, passed by the Additional
Commissioner (Consolidation), Lahore
Division, Lahore, may be restored
to the extent of Petitioner.

Respectfully Sheweth-

The Petitioner respectfully submits as under: -

1. That the present Petitioner purchased the land measuring

03K-07M by way of registered deed during the year, 1979

and mutation No.20544, dated 04-12-1984 pertaining to

Khasra Nos. 11495/1 and 11613/1 was sanctioned;

2. That subsequently, the said sanctioned mutation in favour

of present petitioner was cancelled by way of ex-parte

proceedings initiated on the instance of vendees on the

basis of registered sale deed No.1810, dated 20/10.1950, by

the order of Collector Consolidation;

3. That the present Petitioner filed an appeal before the

Additional Commissioner (Consolidation), Lahore Division,

Lahore, who accepted the appeal vide order dated

18.08.2015, to the extent of the claim of present petitioner

and restored the mutation No.20544, dated 04.12.1984,

sanctioned by way of registered sale deed No.7901, dated

28-03-1979 and cancelled the mutation No.41196, dated

16-01-1996, with the direction that the beneficiaries of

mutation No.41196 may approach civil court for redressal

of their grievances if they so desired;

4. That the Respondent No.1, filed a ROR No.1018/2020,

before this honourable Court, after five years, against the

order dated 18.08.2015, passed by the Additional

Commissioner (Consolidation), Lahore Division, Lahore;

5. That this honourable Court has accepted the revision

petition and set aside the order dated18.08.2015, passed by

the Additional Commissioner (Consolidation), Lahore

Division, Lahore;

6. That the order dated18.08.2015, passed by the Additional

Commissioner (Consolidation), Lahore Division, Lahore, is

well reasoned and legally justified which does not warrant

interference by this honourable court;

7. That the order dated 24-09-2020 passed by this honourable

Court is liable to be reviewed on the following and inter alia

other:

GROUNDS

a) That the order dated 18.08.2015, passed by the

Additional Commissioner (Consolidation), Lahore
Division, Lahore, is well reasoned and legally justified
 which does not warrant interference by this
honourable court;
b) That the impugned proceedings carried by Collector
Consolidation, Lahore, and his order dated 31-101996
is baseless and against the real/actual facts of the
case, hence, it is not sustainable in the eye of law;
c) That the Additional Commissioner (Consolidation),
Lahore Division, Lahore, rightly set aside the
proceedings of the Collector Consolidation which were
carried out at the back of present respondent No.1;
d) That the mutation No.20544, dated 04-12-1984, was
sanctioned on the basis of registered sale deed
executed in the year, 1979, which is still intact and
holds the field;
e) That the mutation sanctioned on the basis of
registered sale deed could not be cancelled till
existence of registered sale deed;
f) That the dictum laid down in judgments of superior
courts reported as 2013 CLC 1054, 2001 CLC1880
and 1992 CLC 1349 is fully applicable in this case in
which it was held that mutations based upon
registered sale deeds cannot be cancelled till existence
of sale deed;
g) That the dictum laid down in judgments of superior
courts reported as PLD 2008 SC 412, PLJ 2005 Lah
 138 and PLD 2011 Pesh 47 is also fully applicable in
this case;
h) That the sale deed No.1810, dated 25-10-1950 is a
bogus document which has been admitted illegally and
unlawfully and mutation of the present petitioner has
been cancelled without scrutiny of the relevant record;
i) That cancellation of registered sale deed is the subject
matter of civil court which is the court of ultimate
jurisdiction;
j) That the claim of the vendees of sale deed No.1810
was only of 18-Kanals 11-Marlas and their vendor was
owner of 21-Kanals 18-Marlas. The mutation of the
present petitioner which was 03-Kanals 07-Marlas was
wrongly cancelled by the Consolidation authorities,
Niazbaig, Lahore;
k) That the mutation No.20544, pertaining to land of the
present petitioner, was cancelled by the consolidation
staff conducting ex-parte proceedings without
summoning and hearing the present petitioner;
l) That consolidation staff cancelled the said mutation
relying upon a sale deed dated 25-10-1950 which was
presented in the year, 1996, with the delay of 46 years,
which is very strange and astonishing;
m)That the present petitioner was neither summoned nor
heard before cancellation of mutation. The
adjudication should be on meritorious grounds. The
 consolidation staff violated the golden principle of
natural justice;
n) That the mutation No.41196, dated 16-01-1996, has
no legal value against the valuable rights of the
present petitioner and is liable to be set aside to that
extent;
o) That the impugned proceedings carried by Collector
Consolidation, Lahore, and his order dated 31-101996
is also without justification, fairness and disgracing of
the natural justice as well as in violation of the
provisions contained in section 24-A of the General
Clauses Act, 1897;
p) That while conducting the impugned proceedings, the
consolidation staff did not apply judicious mind and
passed a sketchy order dated 31-10-1996, which is
liable to be cancelled and set aside under the law;
q) That the Revision Petition was filed before this
honourable Court after four years which was badly
time bared under the Limitation Act;
r) That the land in question had been acquired by the
Lahore Development Authority for residential scheme
namely Muhammad Ali Johar Town, Lahore. The
registered sale deed of the present Petitioner is still
intact which has not been cancelled. It is pertinent to
mention here that the present Petitioner purchased
 the said land from the legal heirs of Moula Bakhsh,
Rehmat Ali, etc.

PRAYER

8. In view of the above narrated facts and grounds, it is

humbly prayed that the request to review the order dated 24-09-

2020 passed in above mentioned ROR bearing No.1789/2019 may

very kindly be accepted in the best interest of justice and fair play

and the impugned order dated 18.08.2015, passed by the

Additional Commissioner (Consolidation), Lahore Division,

Gujranwala, may very kindly be restored declaring the proceedings

of consolidation authorities as illegal, void ab-initio, arbitrary and

not sustainable in the eye of law.

9. In the meantime, status quo may kindly be maintained

till the disposal of Review Petition.

10. Any other relief may kindly also be granted which this

honorable court deems fit for the Petitioner.

PETITIONER
THROUGH COUNCILS:
 Bashir Ahmad Gujjar
Advocate
Room No.108, Farid Tower,
Temple Road, Lahore.

Anees-ur-Rehman
Advocate High Court
Room No.108, Farid Tower,
Temple Road, Lahore.
NOTE
As per instructions of the client this is the first Review Petition on
the subject matter.
Advocate.
BEFORE THE COURT OF ASAD ISLAM MAHNI, MEMBER
(CONSOLIDATION), BOARD OF REVENUE, PUNJAB, LAHORE.

Review Petition No._________/2020.

Muhammad Hussain v/s Muhammad Akram, etc.

Affidavit of Muhammad Husain s/o Ahmad Din.

I the above named deponent do hereby solemnly affirm and declare as

under:

1. That the contents of the accompanying Review Petition may be

treated as integral part of this affidavit.

2. That the contents of the affidavit are correct and true to the best of
my knowledge and belief.

DEPONENT
VERIFICATION

Verified on oath at Lahore, this day of November, 2020, that the contents
of the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

Muhammad Ayub s/o Muhammad Ramzan Khan,

Caste Rajput, R/o Bhagor, Chak No.572/GB,
Tehsil and District, Nankana Sahib.

PETITIONER

Versus

1. Commissioner, Lahore Division, Lahore;

2. Rasheed Ahmad s/o Habi Khan, Caste Rajput, R/o Bhagor,
Chak No.572/GB, Tehsil and District, Nankana Sahib;
3. The State

RESPONDENTS

APPLICATION UNDER SECTION 14 OF THE LAND REVENUE ACT,

1967, FOR TRANSFER OF CASE/APPEAL TITLED ABOVE AGAINST
THE ORDER DATED 09-12-2020, PASSED BY DISTRICT COLLECTOR,
NANKANA SAHIB

Respectfully Sheweth:-

The brief facts giving rise to file this petition are respectfully
submitted as under: -
8. That the Petitioner has filed the above titled appeal before
the Commissioner, Lahore Division, Lahore, on 02-01-2021
(Annexure-A), which is pending adjudication before him in
which next date of hearing is 13-02-2021;

9. That the Petitioner is aggrieved and unsatisfied by the

proceedings being carried out by the Commissioner, Lahore
Division, Lahore;

10. That the Commissioner, Lahore Division, Lahore, seems to

be under some political influence and he does not adhere to
the arguments tendered by the council of the Petitioner
which is against the fundamental rights of the petitioner
guaranteed him under the Constitution of the Islamic
Republic of Pakistan;

11. That the gestures of the Commissioner, Lahore Division,

Lahore, reflect that he has made up his mind to
dismiss/discharge the appeal of the Petitioner without
merits;

12. That it has been clearly informed to the Hon’ble Commissioner that
there are three FIRs registered against Rasheed Ahmad (Respondent
No.4) but he takes it very light and immaterial against the said
respondent;

13. That the Commissioner, Lahore Division, Lahore, has

become prejudice and the petitioner has lost confidence as
 he seems to do favour the Respondent under some
influence and intends to dismiss the appeal of the Petitioner
without going into the merits of the case;

14. That the Petitioner has no hope of justice to be done by

the Commissioner, Lahore Division, Lahore, in this case
titled above because he is in hurry to dispose of the appeal
of the Petitioner without hearing the arguments of his
council;

15. That if the above titled appeal is not transferred to any

other court of law, the Petitioner shall suffer an irreparable
loss and injury.

PRAYER

9. In view of the circumstances explained above, it is

humbly and respectfully prayed that the instant petition may
graciously be accepted and the above titled appeal of the Petitioner
may kindly be transferred from the court of Commissioner, Lahore
Division, Lahore and entrusted to any other Commissioner, in the
Punjab, in the best interest of justice and fair play.

10. It is further prayed that the status quo order may please
be issued in favour of the petitioner till the disposal of the appeal of
the petitioner.
PETITIONER
THROUGH COUNCIL:

CH. BASHIR AHMAD GUJJAR

ADVOCATE

ANEES-UR-REHMAN
ADVOCATE HIGH COURT
ROOM NO.108, FARID TOWER,
TEMPLE ROAD, LAHORE.

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE:

Muhammad Ayyub s/o Muhammad Ramzan Khan;

PETITIONER

Versus

The Commissioner, Lahore Division, Lahore, etc.

RESPONDENTS

AFFIDAVIT OF MUHAMMAD AYYUB S/O MUHAMMAD RAMZAN KHAN

I, the above named deponent does hereby solemnly affirm and declare as
under:

1. That the contents of the accompanying Petition may be treated as

integral part of this affidavit.
 2. That the contents of the affidavit are correct and true to the best of
my knowledge and belief.

DEPONENT

VERIFICATION

Verified on oath at Lahore, this day of February, 2021, that the contents of
the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE.

Muhammad Ayyub s/o Muhammad Ramzan Khan;

PETITIONER

Versus

The Commissioner, Lahore Division, Lahore, etc.

RESPONDENTS

PETITION UNDER ORDER 39 RULE 1 AND 2 READ WITH SECTION 151 CPC, FOR
GRANT OF STAY ORDER

Respectfully Sheweth:-
1. That the Petitioner has filed the petition before this honorable Court in
which no date of hearing has yet been fixed;
2. That the balance of convenience lies in favour of the petitioner;
3. That there is a good prima-facie and arguable case in favour of the
petitioner;
4. That if the stay order is not granted the petitioner will suffer an
irreparable loss.
PRAYER

Under the circumstances explained above, it is humbly prayed that the

status quo order may very kindly be passed in favour of the petitioner during

pendency of the appeal/petition.

PETITIONER
THROUGH COUNCIL:

CH. BASHIR AHMAD GUJJAR

ADVOCATE

ANEES-UR-REHMAN
ADVOCATE HIGH COURT
ROOM NO.108, FARID TOWER,
TEMPLE ROAD, LAHORE.

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF

REVENUE, PUNJAB, LAHORE.
 Muhammad Ayub s/o Muhammad Ramzan Khan,
Caste Rajput, R/o Bhagor, Chak No.572/GB,
Tehsil and District, Nankana Sahib.

PETITIONER

Versus

1. Commissioner, Lahore Division, Lahore;

2. Rasheed Ahmad s/o Habi Khan, Caste Rajput, R/o Bhagor,
Chak No.572/GB, Tehsil and District, Nankana Sahib.

RESPONDENTS

APPLICATION UNDER SECTION 14 OF THE LAND REVENUE ACT,

1967, FOR TRANSFER OF CASE/APPEAL TITLED ABOVE FOR GRANT
OF PROPRIETARY RIGHTS OF LUMBARDARI GRANT MEASURING
112-K, 18-M, SITUTATED AT VILLAGE BHAGOR, CHAK NO.572-GB,
TEHSIL AND DISTRICT NANKANA SAHIB.

Respectfully Sheweth:-

The brief facts giving rise to file this petition are respectfully
submitted as under: -
1. That the Petitioner has filed the above titled appeal before
the Commissioner, Lahore Division, Lahore, on 02-01-2021
(Annexure-A), which is pending adjudication before him in
which next date of hearing is 13-02-2021;
2. That the Petitioner is aggrieved and unsatisfied by the
proceedings being carried out by the Commissioner, Lahore
Division, Lahore;

3. That the Commissioner, Lahore Division, Lahore, seems to

be under some political influence and he does not adhere to
the arguments tendered by the council of the Petitioner
which is against the fundamental rights of the petitioner
guaranteed him under the Constitution of the Islamic
Republic of Pakistan;

4. That the gestures of the Commissioner, Lahore Division,

Lahore, reflect that he has made up his mind to
dismiss/discharge the appeal of the Petitioner without
merits;

5. That it has been clearly informed to the Hon’ble Commissioner that there
are three FIRs registered against Rasheed Ahmad (Respondent No.4) but
he takes it very light and immaterial against the said respondent;

6. That the Commissioner, Lahore Division, Lahore, has become

prejudice and the petitioner has lost confidence as he seems
to do favour the Respondent under some influence and
intends to dismiss the appeal of the Petitioner without going
into the merits of the case;

7. That the Petitioner has no hope of justice to be done by the

Commissioner, Lahore Division, Lahore, in this case titled
 above because he is in hurry to dispose of the appeal of the
Petitioner without hearing the arguments of his council;

8. That if the above titled appeal is not transferred to any

other court of law, the Petitioner shall suffer an irreparable
loss and injury.

PRAYER

In view of the circumstances explained above, it is

humbly and respectfully prayed that the instant petition may
graciously be accepted and the above titled appeal of the Petitioner
may kindly be transferred from the court of Commissioner, Lahore
Division, Lahore and entrusted to any other Commissioner, in the
Punjab, in the best interest of justice and fair play.

It is further prayed that the Respondents No.1 and 2 may

please be directed not to interfere into the peaceful possession of
the petitioner over the land in question till the disposal of the
appeal by the appellate authority.

PETITIONER
THROUGH COUNCIL:

CH. BASHIR AHMAD GUJJAR

ADVOCATE
 ANEES-UR-REHMAN
ADVOCATE HIGH COURT
ROOM NO.108, FARID TOWER,
TEMPLE ROAD, LAHORE.

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

Hafiz Abdul Kareem s/o Qadir Bakhash, Cast Korai

R/O Mauza Kotla Sakhani Gharbi,Tehsil and District Dera Ghazi
Khan, through Mukhtar-e-Khas Muhammad Imran s/o
Muhammad Akbar, Caste Dareshak, R/O Mauza Rasulpur, Chak
Hafizabad, Post Office, Rajanpur.

PETITIONER
Versus

1. Commissioner, Dera Ghazi Khan Division, D.G.Khan;

2. Assistant Commissioner (Sadar), Dera Ghazi Khan;
3. Muhammad Shah Nawaz Sajid s/o Abdul Raheem Khan,
Caste Saddozai, R/O Khanewal Road, Khad Factory, Mauza
Jahangir Abad, Nazam Abad Colony, Multan;
4. Mahar Bhakhash,
5. Ghulam Mustafa, sons of Gul Muhammad;
6. Mushtaq Ahmad,
7. Ishaque Ahmad,
8. Ilyas Ahmad, sons of Allah Wasaya,
All Caste Bhatti, Residents of Mauza Kotla Sakhani
Gharbi,Tehsil and District Dera Ghazi Khan;
9. Ibrahim s/o Umer, Caste Korai, R/O Mauza Kotla Sakhan
Gharbi,Tehsil and District Dera Ghazi Khan,
 RESPONDENTS

REVISION PETITION UNDER SECTION 164 OF THE LAND REVENUE

ACT, 1967, AGAINST ORDER DATE 26-01-2021 PASSED BY
COMMISIONER, DERA GHAZI KHAN DIVISION, (RESPONDENT
NO.1) AND ORDER DATED 22-05-2019 PASSED BY ASSISTANT
COMMISSIONER (SADAR), DERA GHAZI KHAN (RESPONDENT
NO.2).

Respectfully Sheweth:-

The brief facts leading to file the instant revision petition are
respectfully submitted as under: -
9. That during the year, 1995, Mr. Abdul Raheem Khan, Caste
Saddozai, transferred 20-Kanals land situated in Mauza Mauza Kotla
Sakhani Gharbi,Tehsil and District Dera Ghazi Khan to his son
Muhammad Shahnawaz Sajid, through gift (takleek) mutation bearing no.
1160, dated 14-08-1995;

10. That afterward Mr. Abdul Raheem Khan, being natural guardian
of his son Muhammad Shah Nawaz Sajid sold the said land measuring
20-Kanals, situated in Mauza Mauza Kotla Sakhani Gharbi, in Khata No.
221 of Register Haqdaran-e-Zamin for the year, 1995-96, to present
Respondents No. 4 to 9, through Mutation No.1309, dated 06-03-1996,
because Muhammad Shah Nawaz Sajid was minor at that time;

11. That the present Respondents No. 4 to 9, further sold their land to
Ibrahim s/o Muhammad Umer (Respondents No.9) and Hafiz Abdul
Kareem (Petitioner) through Mutation No. 3445, dated 10-08-2005.
Subsequently, Ibrahim s/o Muhammad Umer (Respondents No.9) also
 sold his share equal to 20-Kanal 01-Marla to Hafiz Abdul Kareem
(Petitioner) through Mutation No. 5720, dated 30-06-2009;

12. That Muhammad Shah Nawaz Sajid filed a time barred appeal on 20-
06-2016, before the Assistant Commissioner (Sadar) Dera Ghazi Khan
(Respondent No.2), against the order passed on Mutation No. 1309, dated
06-03-1996, Mauza Mauza Kotla Sakhani Gharbi,Tehsil and District
Dera Ghazi Khan;

13. That the Assistant Commissioner (Sadar) Dera Ghazi Khan

(Respondent No.2), accepted the time barred appeal of Muhammad Shah
Nawaz Sajid and declared the sale to the extent share of Muhammad
Shah Nawaz Sajid transferred through Mutation No. 1309, dated 06-03-
1996, invalid and directed to delete his share from the sale mutation vide
his impugned order dated 22-05-2019;

14. That Hafiz Abdul Kareem (Petitioner) filed a revision petition bearing
No.78/2019, before the Commissioner, Dera Ghazi Division (Respondent
No.1) against the order dated 22-05-2019, passed by the Assistant
Commissioner (Sadar) Dera Ghazi Khan (Respondent No.2);

15. That the Commissioner, Dera Ghazi Division (Respondent No.1) has
dismissed the revision petition vide impugned order dated 26-01-2021
and upheld the impugned order dated 22-05-2019 passed by the Assistant
Commissioner (Sadar) Dera Ghazi Khan (Respondent No.2);
16. That the impugned orders dated 22-05-2019, passed by the Assistant
Commissioner (Sadar) Dera Ghazi Khan (Respondent No.2) and dated
26-01-2021 passed by the Commissioner, Dera Ghazi Division
(Respondent No.1) are unlawful, untenable and against the law/rules as
well as without application of judicious mind, hence, the same are liable
to be cancelled and set aside, inter-alia on the following and other: -

GROUNDS

a. That the basic impugned orders dated 22-05-2019, of the Assistant

Commissioner (Sadar) Dera Ghazi Khan (Respondent No.2) and dated
26-01-2021, of the Commissioner, Dera Ghazi Division (Respondent
No.1) have been passed without application of judicious mind, which
are void, unlawful, untenable and against the law/rules, hence the
same are liable to be cancelled and set aside;
b. That the above said impugned orders are baseless,
against the real and actual facts of the case, therefore
these orders are not sustainable in the eye of law;
c. That the impugned orders passed by the learned lower
courts are also without justification, fairness and
disgracing of the natural justice;
d. That while passing the impugned orders the learned
lower courts have not applied the judicious mind and
passed the sketchy orders on technical grounds, but the
law requires that the adjudication should be on
meritorious grounds by avoiding technicalities. The
impugned orders are also in violation of the provisions
 contained in section 24-A of the General Clauses Act,
1897;
e. That the appeal filed by Muhammad Shah Nawaz Sajid
(Respondent No.3) against the Mutation No.1309, dated
-8-03-1996, was badly time barred because he born on
04-03-19983 and became major on 04-03-2001.
Therefore, the appeal was time barred and he was
required to explain the reasons of delay of each day,
before the lower court of Assistant Commissioner (Sadar),
D.G.Khan (Respondent No.2), but the lower court
accepted the time barred appeal illegally, unlawfully and
without any proper justification;
f. That under the law presumption of truth does attach to
the long-standing entries of the revenue record, which
could be deleted by filing appeal under section 53 of the
Land Revenue Act, 1967, before the Civil Court for
declaration of right under section 42 of the Specific Relief
Act;
g. That the father of the minor child, being natural
guardian, can sale the property of minor. Reliance is
placed on PLD-2017-Lahore/590 in Civil Revision
No.2822 of 2013, heard on 2nd March 2017, titled Adeel
Sultan Versus Khalid Rasheed, Muhammad Saleem v.
Syed Noor Muhammad Hussaini PLD 1968 Kar. 163
and Barkat Ali v. Aftab Ahmad 1992 CLC 1490.
 (a) Contract Act (IX of1872) … S.11…
Competency to enter into a contract…Scope….
Property belonging to a minor sold by his
father or natural guardian …Legality….
Section 11 of the Contract Act, 1872, provided
that competency of father to contract on behalf
of minor could not be questioned until and
unless the same was found against the interest
of the minor.
h. That the disputed property had been transferred
two/three times and the market value of the property in
question has been increased now, due to which the
Respondent No.3 is blackmailing and harassing just to
cause loss to the Petitioner;

PRAYER

In view of the above narrated facts, it is humbly prayed that the instant

revision petition may very kindly be accepted in the supreme interest of justice and

the impugned orders passed in slipshod manners, dated 22-05-2019, passed by the

Assistant Commissioner (Sadar) Dera Ghazi Khan (Respondent No.2) and dated

26-01-2021 passed by the Commissioner, Dera Ghazi Division (Respondent No.1)

may graciously be cancelled and set aside with the direction not to disturb the

possession of the Petitioner from the disputed land.

 A restraining order not to disturb the possession of the Petitioner and

to maintain the status-quo position may also kindly be issued to save the Petitioner

from an irreparable loss, till the disposal of the instant revision petition.

Any other relief which this honourable Court deems proper may also

be granted.

PETITIONER

THROUGH COUNCILS:

LIAQAT ALI BHATTI CH. BASHIR AHMAD GUJJAR

ADVOCATE ADVOCATE

ANEES-UR-REHMAN
ADVOCATE HIGH COURT
ROOM NO.108, FARID TOWER,
TEMPLE ROAD, LAHORE.

NOTE
As per instructions of the client this is the first Review
Petition on the subject matter.

Advocate.
 BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,
PUNJAB, LAHORE.

IN RE:

Hafiz Abdul Kareem s/o Qadir Bakhash,

PETITIONER

Versus

Muhammad Shah Nawaz Sajid, etc.

RESPONDENTS

AFFIDAVIT OF HAFIZ ABDUL KAREEM S/O QADIR BAKHASH, R/O MAUZA KOTLA
SAKHANI GHARBI, TEHSIL AND DISTRICT DERA GHAZI KHAN, THROUGH
MUKHTAR-E-KHAS MUHAMMAD IMRAN S/O MUHAMMAD AKBAR, CASTE
DARESHAK, R/O MAUZA RASULPUR, CHAK HAFIZABAD, POST OFFICE,
RAJANPUR.

I, the above named deponent does hereby solemnly affirm and declare as
under:

17. That the contents of the accompanying Revision Petition may be

treated as integral part of this affidavit.

18. That the contents of the affidavit are correct and true to the best of my
knowledge and belief.

DEPONENT

VERIFICATION

Verified on oath at Lahore, this day of February, 2021, that the contents of
the above affidavit are correct and true to the best of my knowledge and belief.
 DEPONENT

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE.

Hafiz Abdul Kareem s/o Qadir Bakhash,

PETITIONER

Versus

Muhammad Shah Nawaz Sajid, etc.

RESPONDENTS

PETITION UNDER ORDER 39 RULE 1 AND 2 READ WITH SECTION 151 CPC, FOR
GRANT OF STAY ORDER

Respectfully Sheweth:-
1. That the Petitioner has filed the revision petition before this honorable
Court in which no date of hearing has yet been fixed;
2. That the balance of convenience lies in favour of the petitioner;
3. That there is a good prima-facie and arguable case in favour of the
petitioner;
4. That if the stay order is not granted the petitioner will suffer an
irreparable loss.
PRAYER

Under the circumstances explained above, it is humbly prayed that the

status quo order may very kindly be passed in favour of the petitioner pertaining to

the disputed land during pendency of the said revision petition.

PETITIONER
THROUGH COUNCILS:

LIAQAT ALI BHATTI CH. BASHIR AHMAD GUJJAR

ADVOCATE ADVOCATE

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE:

Hafiz Abdul Kareem s/o Qadir Bakhash,

PETITIONER
 Versus

Muhammad Shah Nawaz Sajid, etc.

RESPONDENTS

AFFIDAVIT OF HAFIZ ABDUL KAREEM S/O QADIR BAKHASH, R/O MAUZA KOTLA
SAKHANI GHARBI, TEHSIL AND DISTRICT DERA GHAZI KHAN, THROUGH
MUKHTAR-E-KHAS MUHAMMAD IMRAN S/O MUHAMMAD AKBAR, CASTE
DARESHAK, R/O MAUZA RASULPUR, CHAK HAFIZABAD, POST OFFICE,
RAJANPUR IN PETITION UNDER ORDER 39 RULE 1 AND 2 READ WITH SECTION
151 CPC, FOR GRANT OF STAY ORDER

AFFIDAVIT OF MALIK NAVEED KHAWAR MUSLIM

I, the above named deponent does hereby solemnly affirm and declare as
under:

1. That the contents of the accompanying Petition for grant of stay

order may be treated as integral part of this affidavit.

2. That the contents of the affidavit are correct and true to the best of
my knowledge and belief.

DEPONENT

VERIFICATION

Verified on oath at Lahore, this day of February, 2021, that the contents of
the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT
 BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,
PUNJAB, LAHORE.

IN RE.

Hafiz Abdul Kareem s/o Qadir Bakhash,

PETITIONER

Versus

Muhammad Shah Nawaz Sajid, etc.

RESPONDENTS

Application to dispense with the attested copies of the documents.

Respectfully Sheweth:-

The petitioner respectfully submits as under: -

1. That the petitioner has filed the revision petition before this
honorable Court in which no date of hearing has yet been fixed;
2. That there is a good prima-facie and arguable case in favour of the
petitioner;
3. That the petitioner has applied for attested copies of the documents
which have not yet been provided to the petitioner;
4. That the attested copies of the documents shall be provided as soon
as the same are received from the concerned authorities/offices;
5. That the attested copies of the documents may very kindly be
dispensed with and request to admit the instant revision petition
may very kindly be accepted.

PETITIONER

THROUGH COUNCIL:
 LIAQAT ALI BHATTI CH. BASHIR AHMAD GUJJAR
ADVOCATE ADVOCATE

IN THE COURT OF MR. ASAD ISLAM MAHNI, MEMBER

(CONSOLIDATION), BOARD OF REVENUE, PUNJAB, LAHORE.

Muhammad Hussain s/o Ahmad Din, through general

attorney Aftab Ahmad, R/o H.No.36, Kausar Road,
Karishan Naghar Islampura, Canal, Lahore.

Petitioner
Versus

5. Muhammad Akram s/o Barkat Ali,

R/o Ali Street No.1 PECO Road, Hajvery Town,
Mondy Stop, Multan Road, Lahore;
6. Consolidation Officer, Niazbaig, Lahore;
7. Tehsildar, Niazbaig, Lahore;
8. Halqa Patwari, Niazbaig, Lahore.

Respondents
 REVIEW PETITION U/S 8 OF THE PUNJAB BOARD OF
REVENUE ACT, 1957, IN ROR NO.1789/2019, TO
REVIEW THE ORDER DATED 24-09-2020, PASSED BY
THE MEMBER (CONSOLIDATION) BOARD OF
REVVENUE, PUNJAB.

CLAIM IN REVIEW PETITION: By accepting review petition the

18.08,2020, passed by the Additional Commissioner
Consolidation), Lahore Division, Lahore, may be restored to the
extent of Petitioner.

Respectfully Sheweth-

The Petitioner respectfully submits as under: -

19. That the present Petitioner purchased the land

measuring 03K-07M by way of registered deed during the

year, 1979 and mutation No.20544, dated 04-12-1984

pertaining to Khasra Nos. 11495/1 and 11613/1 was

sanctioned;

20. That subsequently, the said sanctioned mutation in

favour of present petitioner was cancelled by way of ex-

parte proceedings initiated on the instance of vendees on

the basis of registered sale deed No.1810, dated

20/10.1950, by the order of Collector Consolidation;

21. That the present Petitioner filed an appeal before the

Additional Commissioner (Consolidation), Lahore Division,

Lahore, who accepted the appeal vide order dated

18.08.2015, to the extent of the claim of present petitioner

and restored the mutation No.20544, dated 04.12.1984,

sanctioned by way of registered sale deed No.7901, dated

28-03-1979 and cancelled the mutation No.41196, dated

16-01-1996, with the direction that the beneficiaries of

mutation No.41196 may approach civil court for redressal

of their grievances if they so desired;

22. That the Respondent No.1, filed a ROR No.1018/2020,

before this honourable Court, after five years, against the

order dated 18.08.2015, passed by the Additional

Commissioner (Consolidation), Lahore Division, Lahore;

23. That this honourable Court has accepted the revision

petition and set aside the order dated18.08.2015, passed by

the Additional Commissioner (Consolidation), Lahore

Division, Lahore;
24. That the order dated18.08.2015, passed by the

Additional Commissioner (Consolidation), Lahore Division,

Lahore, is well reasoned and legally justified which does not

warrant interference by this honourable court;

25. That the order dated 24-09-2020 passed by this

honourable Court is liable to be reviewed on the following

and inter alia other:

GROUNDS

s) That the order dated 18.08.2015, passed by the

Additional Commissioner (Consolidation), Lahore
Division, Lahore, is well reasoned and legally justified
which does not warrant interference by this
honourable court;
t) That the impugned proceedings carried by Collector
Consolidation, Lahore, and his order dated 31-101996
is baseless and against the real/actual facts of the
case, hence, it is not sustainable in the eye of law;
u) That the Additional Commissioner (Consolidation),
Lahore Division, Lahore, rightly set aside the
proceedings of the Collector Consolidation which were
carried out at the back of present respondent No.1;
v) That the mutation No.20544, dated 04-12-1984, was
sanctioned on the basis of registered sale deed
executed in the year, 1979, which is still intact and
holds the field;
w) That the mutation sanctioned on the basis of
registered sale deed could not be cancelled till
existence of registered sale deed;
x) That the dictum laid down in judgments of superior
courts reported as 2013 CLC 1054, 2001 CLC1880
and 1992 CLC 1349 is fully applicable in this case in
which it was held that mutations based upon
registered sale deeds cannot be cancelled till existence
of sale deed;
y) That the dictum laid down in judgments of superior
courts reported as PLD 2008 SC 412, PLJ 2005 Lah
138 and PLD 2011 Pesh 47 is also fully applicable in
this case;
z) That the sale deed No.1810, dated 25-10-1950 is a
bogus document which has been admitted illegally and
unlawfully and mutation of the present petitioner has
been cancelled without scrutiny of the relevant record;
aa) That cancellation of registered sale deed is the
subject matter of civil court which is the court of
ultimate jurisdiction;
bb) That the claim of the vendees of sale deed No.1810
was only of 18-Kanals 11-Marlas and their vendor was
 owner of 21-Kanals 18-Marlas. The mutation of the
present petitioner which was 03-Kanals 07-Marlas was
wrongly cancelled by the Consolidation authorities,
Niazbaig, Lahore;
cc) That the mutation No.20544, pertaining to land of
the present petitioner, was cancelled by the
consolidation staff conducting ex-parte proceedings
without summoning and hearing the present
petitioner;
dd) That consolidation staff cancelled the said mutation
relying upon a sale deed dated 25-10-1950 which was
presented in the year, 1996, with the delay of 46 years,
which is very strange and astonishing;
ee) That the present petitioner was neither summoned
nor heard before cancellation of mutation. The
adjudication should be on meritorious grounds. The
consolidation staff violated the golden principle of
natural justice;
ff) That the mutation No.41196, dated 16-01-1996, has
no legal value against the valuable rights of the
present petitioner and is liable to be set aside to that
extent;
gg) That the impugned proceedings carried by Collector
Consolidation, Lahore, and his order dated 31-101996
is also without justification, fairness and disgracing of
the natural justice as well as in violation of the
 provisions contained in section 24-A of the General
Clauses Act, 1897;
hh) That while conducting the impugned proceedings,
the consolidation staff did not apply judicious mind
and passed a sketchy order dated 31-10-1996, which
is liable to be cancelled and set aside under the law;
ii) That the Revision Petition was filed before this
honourable Court after four years which was badly
time bared under the Limitation Act;
jj) That the land in question had been acquired by the
Lahore Development Authority for residential scheme
namely Muhammad Ali Johar Town, Lahore. The
registered sale deed of the present Petitioner is still
intact which has not been cancelled. It is pertinent to
mention here that the present Petitioner purchased
the said land from the legal heirs of Moula Bakhsh,
Rehmat Ali, etc.

PRAYER

8. In view of the above narrated facts and grounds, it is

humbly prayed that the request to review the order dated 24-09-

2020 passed in above mentioned ROR bearing No.1789/2019 may

very kindly be accepted in the best interest of justice and fair play

and the impugned order dated 18.08.2015, passed by the

Additional Commissioner (Consolidation), Lahore Division,

Gujranwala, may very kindly be restored declaring the proceedings

of consolidation authorities as illegal, void ab-initio, arbitrary and

not sustainable in the eye of law.

9. In the meantime, status quo may kindly be maintained

till the disposal of Review Petition.

10. Any other relief may kindly also be granted which this

honorable court deems fit for the Petitioner.

PETITIONER
THROUGH COUNCILS:

Bashir Ahmad Gujjar

Advocate
Room No.108, Farid Tower,
Temple Road, Lahore.

Anees-ur-Rehman
Advocate High Court
Room No.108, Farid Tower,
Temple Road, Lahore.

NOTE
As per instructions of the client this is the first Review Petition on
the subject matter.
 Advocate.

BEFORE THE COURT OF ASAD ISLAM MAHNI, MEMBER

(CONSOLIDATION), BOARD OF REVENUE, PUNJAB, LAHORE.

Review Petition No._________/2020.

Muhammad Hussain v/s Muhammad Akram, etc.

APPLICATION UNDER SECTIONS 5 & 18 OF THE LIMITATION ACT, 1908, FOR

CONDONATION OF DELAY IN FILING THE APPEAL

Respectfully Sheweth:-

I the above-named appellant submits as under:-

1. That the appellant has filed the appeal before this honorable Court in
which no date of hearing has yet been fixed;

2. That the balance of convenience lies in favour of the appellant;

3. That there is a good prima-facie and arguable case in favour of the

appellant;
 4. That no delay has been occurred due to any willful act or omission of
the appellant. The delay caused was due to ignorance of the facts,
which is beyond the power and control of the appellant, thus the delay
is condonable;

5. That if the delay is not condoned and review is not treated as in time
and heard on merits, the appellant will suffer an irreparable loss and
injury.

PRAYER
It is, therefore, humbly prayed that the delay in filing the review

petition may kindly be condoned and the same may be heard on merits, treating the

same as in time.

APPELLANT

Through Councils:

ANIS UR REHMAN GUJJAR

Advocate High Court

CH. BASHIR AHMAD GUJJAR

Advocate
Office No.108, Farid Tower
Temple Road, Lahore
 BEFORE THE COURT OF ASAD ISLAM MAHNI, MEMBER
(CONSOLIDATION), BOARD OF REVENUE, PUNJAB, LAHORE.

Review Petition No._________/2020.

Muhammad Hussain v/s Muhammad Akram, etc.

AFFIDAVIT OF MUHAMMAD HUSAIN S/O AHMAD DIN APPLICATION UNDER

SECTIONS 5 & 18 OF THE LIMITATION ACT, 1908, FOR CONDONATION OF DELAY
IN FILING THE APPEAL

I the above named deponent do hereby solemnly affirm and declare as

under:

26. That the contents of the accompanying Review Petition may be

treated as integral part of this affidavit.

27. That the contents of the affidavit are correct and true to the best of my
knowledge and belief.

DEPONENT

VERIFICATION
Verified on oath at Lahore, this day of December, 2020, that the contents
of the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT

BEFORE THE COURT OF MR. ASAD ISLAM MAHNI, MEMBER

(CONSOLIDATION), BOARD OF REVENUE, PUNJAB, LAHORE.

1. Abdul Rehman son of Umer Din,

2. Irfan Bashir son of Ch. Muhammad Bashir,
Caste Gujjar, resident of Tarkhanawala,
Tehsil Noshera Virkan, District Gujranwala.

Petitioners
Versus

Mst. Ghafooran Bibi wife of Abdul Hameed, etc.

resident of Tarkhanawala, Tehsil Noshera Virkan,
District Gujranwala.

Respondents

REVIEW PETITION U/S 8 OF THE PUNJAB BOARD OF

REVENUE ACT, 1957, IN ROR NO.1018/2020,
AGAINST THE IMPUGNED ORDER DATED 14-09-
2020, PASSED BY THE ADDITIONAL COMMISSIONER
(REVENUE), GUJRANWALA DIVISION, GUJRANWALA.

Repectfully Sheweth-

The Petitioners respectfully submit as under: -

a) That the petitioners filed ROR No.1018/2020, before this

honourable Court, against the impugned order dated

14.09.2020, passed by the Additional Commissioner

(Revenue), Gujranwala Division, Gujranwala, with the

prayer to declare the same as illegal, unlawful, ultra vires

and not sustainable in the eye of law being liable to be set-

aside;

b) That this honourable Court has dismissed the said ROR in

limine vide order dated 07.10.2020, on the ground that the

order passed by the Addl. Commissioner (Revenue),

Gujranwala Division, dated 14.09.2020 is well reasoned and

legally justified which does not warrant interference by this

court; hence the revision petition is dismissed in limine;

c) That the order dated 07.10.2020 passed by this honourable

Court is liable to be reviewed on the following and inter alia

other:
 GROUNDS

a) That the impugned order dated 14.09.2020, passed by

the Addl. Commissioner (Rev) Gujranwala, is baseless,
against the real and actual facts of the case, hence is
not sustainable in the eye of law;

b) That the adjudication should be on meritorious

grounds by avoiding technicalities;

c) That the impugned order dated 14.09.2020, passed by

the Addl. Commissioner (Rev) Gujranwala, is also in
violation of the provisions contained in section 24-A of
the General Clauses Act, 1897;

d) That the impugned orders passed by the learned lower

courts are also without justification, fairness and
disgracing of the natural justice;

e) That while passing the impugned order the learned

lower court has not applied the judicious mind and
passed a sketchy order on technical grounds;
 f) That the petitioners are not the party in the writ
petition No.78298/2019 titled Shakeel Ahmad Vs.
Chief Settlement Commissioner, Punjab, etc.;

g) That the said writ petition No.78298/2019, had once

been dismissed for non-prosecution vide order dated
05-03-2020, passed by the honourable Judge of the
Lahore High Court, Lahore;

h) That the other grounds are narrated in the ROR in

question which is required to be reviewed for disposal
on merits.

PRAYER

4. In view of the above narrated facts and grounds, it is

humbly prayed that the request to review the order dated

07.10.2020 passed in above mentioned ROR bearing No.1018/2020

may very kindly be accepted in the best interest of justice and fair

play and the impugned order dated 14.09.2020, passed by the

Additional Commissioner (Revenue), Gujranwala Division,

Gujranwala, may very kindly be set-aside declaring the same as

illegal, void ab-initio, arbitrary and not sustainable in the eye of

law.
5. In the meantime, status quo may kindly be maintained

till the disposal of Review Petition/Revision Petition.

6. Any other relief may kindly also be granted which this

honorable court seems fit for the Petitioner.

PETITIONERS

THROUGH COUNCILS:

Liaqat Ali Bhatti Bashir Ahmad Gujjar

Advocate Advocate
Room No.108, Farid Tower, Room No.108, Farid Tower,
Temple Road, Lahore. Temple Road, Lahore.

Anees-ur-Rehman
Advocate High Court
Room No.108, Farid Tower,
Temple Road, Lahore.

NOTE
As per instructions of the client this is the first Review Petition on
the subject matter.

Advocate.
 BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,
PUNJAB, LAHORE.

Malik Naveed Khawar Muslim s/o Malik Muhammad Muslim,

Resident of House No.3, Businessman Colony, Tehsil and
District Rahim yar Khan

PETITIONER
Versus

4. Additional Commissioner (Revenue), Bahawalpur Division,

Bahawalpur;
5. Assistant Commissioner, Rahim-yar-Khan;
6. Tehsildar, Tehsil Rahim-yar-Khan;
7. Kanungo/Girdawar halqa Kot Kamoon;
8. Patwar halqa Kot Kamoon;
9. Mst. Arooj Manzar wife of Iqbal Hussain Abbasi, R/o of
H.No.4/D, Businessman Colony, Tehsil and District Rahim-
yar-Khan.

RESPONDENTS

REVISION PETITION UNDER SECTION 164 OF THE LAND REVENUE

ACT, 1967, AGAINST ORDER DATE D17-09-2020 PASSED BY
ADDITIONAL COMMISIONER (REV), BAHAWALPUR DIVISION,
BAHAWALPUR (RESPONDENT NO.1), AND ORDER DATED 18-08-2015
PASSED BY ASSISTANT COMMISSIONER, RAHIM-YAR-KHAN
(RESPONDENT NO.2).

Respectfully Sheweth:-

The brief facts leading to file instant revision are respectfully submitted as
under:

1. That Mst. Arooj Manzar wife of Iqbal Hussain Abbasi, resident of

H.No.4/D, Businessman Colony, Tehsil and District Rahim-yar-Khan
(Respondent No.6) submitted an application to provide her copies of Khasra
 Girdawari, for the years 2008 to 2015, pertaining to Khara No.148/149,
Khatauni No.404, Rectangular No.408/2, Khasra No.3/A measuring 4-K,
Khasra No.4 measuring 7-K 19-Marlas, Khasra No.5 measuring 3-Kanal,
Khasra No.6 measuring 5-Kanal 17-Marla, Khasra No.7 measuring 3-Kanal
12Marla, Khasra No.8 measuring 4-Kanal, Rectangular No.408/16, Khasra
No.1 measuring 5-Kanal 12-Marla, Khasra No.10 measuring 2-Kanal, total
measuring 36-Kanals, situated in Mouza Kamoon Shah, Tehsil and District
Rahim-yar-Khan.

2. That the Assistant Commissioner, Rahim-yar-Khan (Respondent No.2)

obtained a report from revenue field staff.

3. That the Girdawar halqa (Respondent No.4) submitted a report on

13.07.2015 in which it was clearly mentioned that there is no possession of

Mst. Arooj Manzar (Respondent No.6) and his sister Asma Hassan in the
disputed land.

4. That it was clearly mentioned in the said report that the Petitioner is in

possession of disputed land through his sons Muhammad Abdul Jamil and
Muhammad Abdul Waheed.

5. That it was also clearly mentioned in the above mentioned report submitted

by Kanungo/Girdawar halqa that the land pertaining to Rectagular

No.408/12, Khasra No.6, measuring 5-K 17-Marlas and Rectagular
No.408/16, Khasra No.10, measuring 4-K is under the possession of M/s
Muhammad Abdul Jamil and Muhammad Abdul Waheed. The owners are in
possession upon the remaining land pertaining to Rectagular No.408/12,
 Khasra No.3/A, measuring 4-K, Khasra No.4 measuring 7-K 19-Marlas,
Khasra No.5 measuring 3-K, Khasra No.7 measuring 3-K 12-Marlas, Khasra
No.8 measuring 4-K and Rectagular No.408/16, Khasra No.1 measuring 5-K
12-Marla, vide Girdawari of Crop Kharif 2013 to Rabi 2015.

6. That the Assistant Commissioner, Rahim-yar-Khan (Respondent No.2) just

upon the statement of Respondent No.6, changed the khasra grdawari of

Crops Kharif 2014 to Rabi 2015 and Kharif 2015 in favour of Mst. Arooj
Manzar (Respondent No.6) in spite of the fact that civil litigation is pending
in the hon’ble civil courts.

7. That the Assistant Commissioner, Rahim-yar-Khan (Respondent No.2)

illegally and unlawfully changed the girdawari pertaining to disputed land

Rectagular No.408/12, Khasra No.6, measuring 5-K 17-Marlas and
Rectagular No.408/16, Khasra No.10, measuring 2-K in favour of Mst.
Arooj Manzar (Respondent No.6) on her miscellaneous application and
conducting ex-parte proceedings vide impugned order dated 18-08-2015.

8. That the Petitioner filed an appeal before the Additional Commissioner

(Revenue), Bahawalpur, who accepted the appeal of the Petitioner and set
aside the order dated 18.08.2015, passed by the Assistant Commissioner,
Rahim-yar-Khan (Respondent No.2) vide order dated 13-07-2017. However,
he instead of referring the matter to the Deputy Commissioner/District
Collector, Rahim-yar-Khan, who was the competent authority to correct the
entries contained in the register khasra girdawari, remanded the matter again
to the Assistant Commissioner, Rahim-yar-Khan (Respondent No.2) with
 the direction to pass the fresh order after hearing the parties and keeping in
view the revision pending before the hon’ble Lahore High Court.

9. That the Assistant Commissioner, Rahim-yar-Khan (Respondent No.2),

having observed the defects/errors, cancelled the previous impugned order
dated 18.08.2015 passed by his predecessor and restored the khasra
girdawari of Crops Kharif 2014 to Rabi 2015 and Kharif 2015 on its
previous position vide order dated 06-11-2019.

10.That Mst. Arooj Manzar (Respondent No.6) through her general attorney
Malik Zeeshan Manzar filed an appeal before the Additional Commissioner
(Revenue), Bahawalpur (Respondent No.1) against the order dated 06-11-
2019, which was rightly and justly passed by the Assistant Commissioner,
Rahim-yar-Khan (Respondent No.2).

11.That Additional Commissioner (Revenue), Bahawalpur, accepted the appeal

of Mst. Arooj Manzar (Respondent No.6) and set aside the order dated 06-
11-2019 passed by the Assistant Commissioner, Rahim-yar-Khan
(Respondent No.2) vide impugned order dated 17-09-2020.

12.That the impugned order dated 18-08-2015, passed by the Assistant

Commissioner, Rahim-yar-Khan (Respondent No.2) and impugned order
dated 17-09-2020 passed by the Additional Commissioner (Revenue),
Bahawalpur Division, Bahawalpur (Respondent No.1) are unlawful,
untenable and against the law/rules as well as without application of
judicious mind, hence, the Petitioner pray to this honourable Court to set
aside the said impugned orders, inter-alia on the following and other:-
 GROUNDS

i. That the basic impugned orders, dated 18-08-2015 passed by the

Assistant Commissioner, Rahim-yar-Khan (Respondent No.2) and
dated 17-09-2020 passed by the Additional Commissioner (Revenue),
Bahawalpur Division, Bahawalpur (Respondent No.1), are void,
unlawful, untenable and liable to bet to set aside;

j. That the order dated 18-08-2015, was passed by the Assistant

Commissioner, Rahim-yar-Khan (Respondent No.2) conducting one
sided ex-parte proceedings in the absence of the petitioner, hence is
liable to be cancelled and set aside being not maintainable;

k. That the learned Courts below have had ignored the law and facts of
the case, despite of the facts that the Petitioner is in possession of the
disputed land;

l. That the lower Courts below have failed to take into consideration the
true perspective of the matter and contentions of the Petitioner, while
exercising of the powers in fanciful and colorable manners;

m. That Mst. Arooj Manzar (Respondent No.6) initially submitted

application for issuance of copies of khasra girdawari but later on
tampering the last line, the words ‘correction of girdawari’ were
written in the application and the Assistant Commissioner, Rahim-
 yar-Khan (Respondent No.2) illegally allowed correction of khasra
girdawari;

n. That all proceedings of correction of khasra girdawari were carried

out one sided and ex-parte after obtaining the report from halqa
Girdawar and Patwari, whereas the Khata of the disputed land was
combined and in the combined khata report of girdawari of specific
khasra numbers cannot be made;

o. That the present Respondent No.6 first of all should have got
partitioned of her Khata then apply for issuance or correction of
khasra girdawari. Before partition of land and making separate
wandajat, neither proceedings of correction of khasra girdawari of
specific khasra numbers can be conducted nor copies of khasra
girdawari of any specific khasra number can be issued under the law
and rules;

p. That the learned Assistant Commissioner, Rahim-yar-Khan

(Respondent No.2) conducted all the proceedings ex-parte with the
connivance of the present Respondent No.6 and passed the illegal
order dated 18-08-2015;

q. That the learned Assistant Commissioner, Rahim-yar-Khan

(Respondent No.2) was not competent to pass any order for correction
of khasra girdawari. The Deputy Commissioner/District Collector is
the competent authority to pass such orders for correction of revenue
record or khasra girdawari, etc.
r. That Mst. Arooj Manzar (Respondent No.6) is living abroad due to
which she taking benefit of overseas Pakistani, got conducted ex-parte
proceedings by the Assistant Commissioner, Rahim-yar-Khan
(Respondent No.2);

s. That the learned Assistant Commissioner, Rahim-yar-Khan

(Respondent No.2) passed the illegal order dated 18-08-2015
referring para 9.9 of the Land Records Manual, whereas the said
paragraph does not confer any power on Assistant Commissioner to
correct or change the khasra girdawari, rather a procedure for
preventing errors in the khasra (Register girdawari) is laid down in
this paragraph. Furthermore, under this paragraph a Register
Taghayyurat Qabza Kasht-wa-Laghan is required to be maintained by
the Patwari of each revenue estate;

t. That as and when it came into the knowledge of the Petitioner, he

filed the appeal before the learned Additional Commissioner
(Revenue), Bahawalpur Division, Bahawalpur (Respondent No.1)
who rightly set aside the order dated 18-08-2015 and restored the
previous position of khasra girdawari, vide order dated 13-07-2017,
directing the Assistant Commissioner, Rahim-yar-Khan (Respondent
No.2) to pass the fresh order after hearing all the concerned parties;

u. That the Assistant Commissioner, Rahim-yar-Khan (Respondent

No.2) passed the fresh order dated 06-11-2019, after hearing all the
concerned parties and he also restored the previous position of khasra
 girdawari and cancelled the order dated 18-08-2015 of his predecessor
as per law/rules;

v. That if both the impugned orders dated 18-08-2015 passed by the

Assistant Commissioner, Rahim-yar-Khan and 17-09-2020 passed by
the Additional Commissioner (Revenue) Bahawalpur Division, are not
cancelled/set aside and the order to maintain the status-quo position is
not issued, the petitioner will sustain an irreparable loss.

PRAYER

In view of the above facts, it is humbly prayed that the instant revision

petition may very kindly be accepted in the supreme interest of justice and the

impugned orders passed in slipshod manners, dated 18-08-2015, of the Assistant

Commissioner, Rahim-yar-Khan (Respondent No.2) and dated 17-09-2020 of the

Additional Commissioner (Revenue), Bahawalpur Division, Bahawalpur

(Respondent No.1) may graciously be cancelled and set aside with the direction not

to disturb the possession of the Petitioner from the disputed land.

2. A restraining order not to disturb the possession of the Petitioner and

to maintain the status-quo position may also kindly be issued to save the Petitioner

from an irreparable loss, till the disposal of the instant revision petition.

3. Any other relief which this honourable Court deems appropriate may

also be granted.
 PETITIONER

THROUGH COUNCILS:

LIAQAT ALI BHATTI CH. BASHIR AHMAD GUJJAR

ADVOCATE ADVOCATE

ANEES-UR-REHMAN
ADVOCATE HIGH COURT
ROOM NO.108, FARID TOWER,
TEMPLE ROAD, LAHORE.

NOTE
As per instructions of the client this is the first Review
Petition on the subject matter.

Advocate.

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE:

Malik Naveed Khawar Muslim s/o Malik Muhammad Muslim

PETITIONER

Versus

Additional Commissioner (Revenue), Bahawalpur, etc.

 RESPONDENTS

Affidavit of Malik Naveed Khawar Muslim s/o Malik Muhammad Muslim,

R/o H.No.3, Businessman Colony, Tehsil and District Rahim-yar- Khan.

I, the above named deponent do hereby solemnly affirm and declare as

under:

1. That the contents of the accompanying RevisionPetition may be

treated as integral part of this affidavit.

2. That the contents of the affidavit are correct and true to the best of
my knowledge and belief.

DEPONENT

VERIFICATION

Verified on oath at Lahore, this day of November, 2020, that the contents
of the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE.

Malik Naveed Khawar Muslim s/o Malik Muhammad Muslim

PETITIONER
 Versus

Additional Commissioner (Revenue), Bahawalpur, etc.

RESPONDENTS

PETITION UNDER ORDER 39 RULE 1 AND 2 READ WITH SECTION 151 CPC, FOR
GRANT OF STAY ORDER

Respectfully Sheweth:-
1. That the Petitioner has filed the revision petition before this honorable
Court in which no date of hearing has yet been fixed;
2. That the balance of convenience lies in favour of the petitioner;
3. That there is a good prima-facie and arguable case in favour of the
petitioner;
4. That if the stay order is not granted the petitioner will suffer an
irreparable loss.
PRAYER

Under the situation explained above, it is humbly prayed that the

status quo order may very kindly be passed in favour of the petitioner pertaining to

the disputed land during pendency of the said revision petition.

PETITIONER
THROUGH COUNCILS:

LIAQAT ALI BHATTI CH. BASHIR AHMAD GUJJAR

ADVOCATE ADVOCATE
 BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,
PUNJAB, LAHORE.

IN RE:

Malik Naveed Khawar Muslim s/o Malik Muhammad Muslim

PETITIONER

Versus

Additional Commissioner (Revenue), Bahawalpur, etc.

RESPONDENTS

AFFIDAVIT OF MALIK NAVEED KHAWAR MUSLIM IN PETITION UNDER ORDER

39 RULE 1 AND 2 READ WITH SECTION 151 CPC, FOR GRANT OF STAY ORDER

I, the above named deponent do hereby solemnly affirm and declare as

under:

1. That the contents of the accompanying Petition for grant of stay

order may be treated as integral part of this affidavit.

2. That the contents of the affidavit are correct and true to the best of
my knowledge and belief.

DEPONENT

VERIFICATION

Verified on oath at Lahore, this day of November, 2020, that the contents
of the above affidavit are correct and true to the best of my knowledge and belief.
 DEPONENT

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE.

Malik Naveed Khawar Muslim s/o Malik Muhammad Muslim

PETITIONER

Versus

Additional Commissioner (Revenue), Bahawalpur, etc.

RESPONDENTS

Application to dispense with the attested copies of the documents.

Respectfully Sheweth:-

The petitioner respectfully submits as under:-

6. That the petitioner has filed the revision petition before this
honorable Court in which no date of hearing has yet been fixed;
7. That there is a good prima-facie and arguable case in favour of the
petitioner;
8. That the petitioner has applied for attested copies of the documents
which have not yet been provided to the petitioners;
9. That the attested copies of the documents shall be provided as soon
as the same are received from the concerned authorities/offices;
10. That the attested copies of the documents may very kindly be
dispensed with and request to admit the instant revision petition
may very kindly be accepted.
 PETITIONER

THROUGH COUNCIL:

CH. BASHIR AHMAD GUJJAR

ADVOCAT

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE:

Malik Naveed Khawar Muslim s/o Malik Muhammad Muslim

PETITIONER

Versus

Additional Commissioner (Revenue), Bahawalpur, etc.

RESPONDENTS

Affidavit of Malik Naveed Khawar Muslim on application to dispense with

the attested copies of the documents.

I, the above named deponent do hereby solemnly affirm and declare as

under:

1. That the contents of the accompanying application to dispense with the

attested copies of the documents in Revision Petition may be treated as
integral part of this affidavit.
2. That the contents of the affidavit are correct and true to the best of my
knowledge and belief.
 DEPONENT

VERIFICATION

Verified on oath at Lahore, this day of November, 2020, that the contents
of the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE, PUNJAB,

LAHORE.

1. Zia-ul-Haq;
2. Ikram-ul-Haq;
3. Irshad-ul-Haq.
Sons of Muhammad Younas, Caste Arain,
Residents of Chak No. I/P, Tehsil Khanpur,
District Rahimyarkhan.

PETITIONERS
Versus

1. Additional Commissioner (Revenue), Bahawalpur Division,

Bahawalpur;
2. Additional Deputy Commissioner (Rev)/Collector,
Rahim-yar-Khan;
3. Assistant Commissioner, Khanpur, district Rahim-yar-Khan;

RESPONDENTS

REVISION UNDER SECTION 164 OF THE LAND REVENUE ACT, 1967,

AGAINST ORDER DATED 03.02.2020 PASSED BY ADDITIONAL
COMMISIONER (REV), BAHAWALPUR DIVISION, BAHAWALPUR
(RESPONDENT NO.1), AND ORDER DATED 12-02-2019 PASSED BY
 ASSISTANT COMMISSIONER, KHANPUR, DISTRICT RAHIM-YAR-
KHAN (RESPONDENT NO.3).

Respectfully Sheweth:-
The Petitioners respectfully submit as under:
2. That according to village map prepared by halqa Patwari, Chak No.I/P,
Khanpur, district Rahim-yar-Khan, is comprising 84 Ahatas (Annexure-A);

3. That according to Fard Taqseem, Ahatajat Nos. 69-70, Chak No.I/P,

Khanpur, were not allotted under any scheme (Annexure-B);

4. That Ahata No. 69 is comprising 20 Marlas and Ahata No.70 is also

comprising 20 Marlas, hence its total area is 40 Marlas, out of which the
petitioners are under possession of 12-marlas, i.e. 2-marlas in Ahata No.
69/1 and 10-marla in Ahata No. 70/1, and residing since last 40 years in
constructed houses, whereas the remaining area of 28-marlas is under the
occupation of other peoples and no area is vacant in Ahatajat Nos. 69-70,
Chak No.I/P, Khanpur;

5. That vide order dated 22-06-2018, the Additional Deputy Commissioner

Revenue, Rahim-yar-Khan, held that Ahatajat Nos. 69 to 82 are reserved for
Kamiyan/Means, whereas Ahata No. 74, area measuring 1-Kanal, is allotted
to Zahid Parveen, Ahata No. 73, area measuring 1-Kanal is allotted to
Muhammad Ali s/o Allah Bukhsh, Ahata No. 81, area measuring 1-Kanal is
allotted to Ali Muhammed s/o Ghaus Bukhsh, Ahata No. 82, area
measuring 1-Kanal is allotted to Khushi Muhammed s/o Ghaus Muhammad
(Annexure-C);

6. That the Petitioners submitted applications for allotment of land under their
possession in the year, 1998, and as per reports called upon their
applications, the possession and residence/abode of the petitioners were
admitted/verified but due to some political pressure, the matter was deferred
(Annexure-D);
7. That the Petitioners again submitted application on 20-10-2016, to the
Assistant Commissioner, Khanpur, for allotment of land in question on
current market price, which was marked to Colony Clerk (Annexure-E);

8. That the Petitioner filed a writ petition No. 8175/16/BWP, titled Zia-ul-Haq,
etc., versus Commissioner, Bahawalpur, etc., in which the following
direction was passed vide order dated 27-10-2016 (Annexure-F):-

9. That the District Coordination Officer, Rahim-yar-Khan did not pass any
order rather the Additional Deputy Commissioner (Revenue), Rahim-yar-
Khan, referring the order of honourable Lahore High Court, rejected the
application of the Petitioners vide order dated 04-01-2017, who was not
empowered to do so because the direction was passed for the DCO,
R.Y.Khan;
“With concurrence of the Parties, let a copy of this writ petition
alongwith its annexure including copy of application of the petitioners
placed alongwith this writ petition as annexure-B at page-9, be
transmitted to the respondent No.2/District Coordination Officer,
Rahim-yar-Khan with a direction to decide the same, if pending
strictly in accordance with law through a speaking order and after
hearing all concerned if required preferably within a period of eight
weeks from the date of receipt of order of this Court. If at all,
petitioners intend to obtain any injunctive order, they may file an
application before the said respondent and in that eventuality, it is
expected that respondent No.2 will respond to the said application at
the earliest strictly in accordance with law.”
10.That the Additional Deputy Commissioner (Revenue), Rahim-yar-Khan,
held in his order dated 04-01-2017 that the Ahatajat Nos. 69-70 are reserved
for ponds/reservoirs and the petitioners damaged the ponds and caused loss
to the Government. He did not verify that when the ponds were constructed
and wherefrom the funds were granted. There is no such entry in the record
and it was all on hypothesis. Actually, water-supply is installed in Ahatajat
Nos. 60-61. Copy of record of rights is attached at (Annexure-G);

11.That according to letter No. 565-2002/310-CL-IV, dated 13-03-2002, issued

by the Government of the Punjab, Colonies Department, Board of Revenue,
Punjab, the land can be allotted to the illegal occupants at current market
price with 50% penalty and 10% surcharges. Copy of letter is placed at
 (Annexure-H). However, the Petitioners are being treated discriminately as
they only are being ejected from their occupied land since long, whereas the
other peoples who are also illegal occupant/without any allotment are not
being disturbed at all;

12.That the Petitioners being aggrieved by order dated 04-01-2017 passed by

the Additional Deputy Commissioner (Revenue), Rahim-yar-Khan, filled
another writ petitioner No. 877/17/BWP, before the honourable Lahore High
Court, which was disposed of vide order dated 08-02-2017 (Annexure-I) and
forwarded to the Additional Commissioner (Revenue), Bahawalpur, with the
following observations:-
“The request being genuine is acceded to. Let a copy of this writ
petition along with all its annexures be remitted to Additional
Commissioner (Revenue), Bahawalpur Division, Bahawalpur, who
will treat it as an appeal and ensure its decision on merits, strictly in
accordance with law by passing a speaking order after affording fair
opportunity of hearing to the petitioner and all other concerned
preferably within a period of 90-days commencing from the date of
receipt of certified copy of this order. Till entertainment of appeal by
the Additional Commissioner (Revenue), Bahawalpur Division,
Bahawalpur, if the petitioners are in possession of disputed Ahatas
their possession shall not be disturbed. On entertainment of appeal by
the Additional Commissioner (Revenue), the interim injunction will
be regulated by the order of that Court. With this direction, this writ
petition stands disposed of”

13.That Mr. Maqbool Ahmad Majoka, Additional Commissioner (Revenue),

Bahawalpur Division, Bahawalpur, disposed of the appeal of the Petitioners
vide order dated 10-05-2017, with the direction to the Additional Deputy
Commissioner (Revenue), Rahim-yar-Khan, to decide the matter according
to the Policy of 2002 (Annexure-J);

14.That the Additional Deputy Commissioner (Revenue), Rahim-yar-Khan,

instead of deciding the matter himself, according to Policy of 2002,
remanded the matter to the Assistant Commissioner, Khanpur, vide order
dated 22-06-2018, in violation of order dated 10-05-2017 passed by the
 Additional Commissioner (Revenue), Bahawalpur Division, Bahawalpur,
(Annexure-K);

15.That the Assistant Commissioner, Khanpur, rejected the application of the

Petitioners, vide impugned order dated 12-02-2019, on the analogy that the
Ahatajat are reserved for the Kamiyan/Means, which cannot be allotted
without change of category and power to change the category of any state
land rests with the Collector of the district;

16.That firstly the Additional Deputy Commissioner (Revenue), Rahim-yar-

Khan, did not decide the matter himself and remand the matter to the
Assistant Commissioner, Khanpur, in violation of order dated 10-05-2017
passed by the Additional Commissioner (Revenue), Bahawalpur and
secondly the Assistant Commissioner, Khanpur, rejected the application of
the Petitioner instead of referring the matter to the Collector of the district
for appropriate orders to change the category of the disputed land;

17.That the Petitioners filed an appeal before the Additional Commissioner

(Revenue), Bahawalpur Division, Bahawalpur, against the order dated 12-
02-2019 passed by the Assistant Commissioner, Khanpur (Respondent
No.3);

18.That the Additional Commissioner (Revenue), Bahawalpur Division,

Bahawalpur, has also dismissed the appeal of the petitioners vide his order
dated 03-02-2020, without perusing the revenue record;

19.That the impugned order dated 12-02-2019, passed by the Assistant

Commissioner, Khanpur (Respondent No.3), and order dated 03-02-2020
passed by the Additional Commissioner (Revenue), Bahawalpur Division,
Bahawalpur (Respondent No.1), are unlawful, untenable and against the
law/rules as well as passed without application of judicious mind, hence,
the Petitioners pray to this honourable Court to set aside the said impugned
orders, inter-alia on the following:-

GROUNDS
a. That the learned Courts below had ignored the law and facts of the
case, despite the facts that the Petitioners are in possession of land in
question and residing their constructed houses since last 42/45 years;

b. That the Petitioners applied for allotment of the said land initially in
the year, 1998 and then in the year, 2016, on the current market price
as per law and rules notified by the Government of the Punjab,
Colonies Department, during the year, 2002;

c. That the prayers of the petitioners have been declined due to political
pressure without any justification, whereas the petitioners are inclined
to purchase the land in question on current market price and are ready
to pay the dues of the government;

d. That the petitioners are being treated discriminately, because the other
peoples are also living in the same Ahatajat without any allotment and
legal right;

e. That the lower Courts gave the weightage to the statement of Riaz-
ul-Hq, Numberdar, who has the political revenge/enmity with the
petitioners rather to listen the other Numberdar/Chairman Union
Council;

f. That the order dated 04-01-2017 was passed by the Additional Deputy
Commissioner (Revenue), Rahim-yar-Khan, in the absence of the
petitioners and patwari halqa, just within two days after the receipt of
order passed in writ petition No.8175/2016/BWP, which was received
on 02-01-2017;

g. That the Assistant Commissioner, Khanpur/Respondent No.3, passed

one-sided order dated 29-07-20016 which has not been implemented
as it is liable to be cancelled and set aside being not maintainable;

h. That the lower Courts sometime treated the said Ahatajat as

Pond/Rafai-Aama and now have stated as reserved for
Kamiyan/Means, as such, the petitioners had been made
unnecessarily rolling stone in this case;
 i. That the lower Courts have failed to comply with the directions
passed by honourable Lahore High Court in the above cited writ
petitions filed by the Petitioners;

j. That the lowers Courts do not bother to consider the policy announced
by the Government, in the year 2002, pertaining to allotment of land
to the illegal occupants, on current market price along with
penalty/surcharge, etc. Moreover, the learned Courts below have
failed to take into consideration the true perspective of the matter and
while exercising of the powers in fanciful and colorable manners,
declined the prayers of the petitioners;

k. That all the basic orders passed by the lower Courts, particularly last
two impugned orders dated 03-02-2020, passed by the Additional
Commissioner (Revenue), Bahawalpur/Respondent No.1, and order
dated 12-02-2019, passed by the Assistant Commissioner,
Khanpur/Respondent No.3, are void, unlawful, untenable and liable to
bet to set aside;

l. That if the said orders are not cancelled/set aside the restraining order
to the respondents not to eject/disturb the petitioners, are not issued,
the petitioners will sustain irreparable loss.

PRAYER
In view of the above facts, it is humbly prayed that the impugned

orders passed in slipshod manners, dated 03-02-2020 by the learned of the

Additional Commissioner (Revenue), Bahawalpur/Respondent No.1, and order

dated 12-02-2019 by the Assistant Commissioner, Khanpur/Respondent No.3, may

graciously be cancelled/set aside with the direction not to disturb/eject the

Petitioners from the disputed land and the instant revision may very kindly be

accepted in the supreme interest of justice.

2. Any other relief which this honourable Court deem appropriate may

also be given.

PETITIONERS

THROUGH COUNCILS:

LIAQAT ALI BHATTI CH. BASHIR AHMAD GUJJAR

ADVOCATE ADVOCATE

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE.
Zia-ul-Haq, etc., reesidents of Chak No. I/P, Tehsil Khanpur,
 PETITIONERS

Versus

Additional Commissioner (Revenue), Bahawalpur Division,

Bahawalpur, etc.
RESPONDENTS

PETITION UNDER ORDER 39 RULE 1 AND 2 READ WITH SECTION 151 CPC, FOR
GRANT OF STAY ORDER

Respectfully Sheweth:-
1. That the Petitioners have filed the revision before this honorable Court
in which no date of hearing has yet been fixed;
2. That the balance of convenience lies in favour of the petitioners;
3. That there is a good prima-facie and arguable case in favour of the
petitioners;
4. That if the stay order is not granted the petitioners will suffer an
irreparable loss.
PRAYER

Under the situation explained above, it is humbly prayed that the

status quo order may very kindly be passed in favour of the petitioners pertaining

to the disputed land during pendency of the said revision.

PETITIONERS
THROUGH COUNCILS:

LIAQAT ALI BHATTI CH. BASHIR AHMAD GUJJAR

ADVOCATE ADVOCATE
 BEFORE THE LEARNED SENIOR MEMBER, BOARD OF EVENUE,
PUNJAB, LAHORE.

IN RE.
Zia-ul-Haq, etc., reesidents of Chak No. I/P, Tehsil Khanpur,
PETITIONERS

Versus

Additional Commissioner (Revenue), Bahawalpur Division,

Bahawalpur, etc.
RESPONDENTS

AFFIDAVIT OF ZIA-UL-HAQ S/O MUHAMMAD YOUNAS, CASTE ARAIN, R/O

CHAK NO.I/P, TEHSIL KHANPJUR, DISTRICT RAHIM-YAR-KHAN.

Respectfully Sheweth:-

I the above-named deponent do hereby solemnly affirm and declare as

under:-
1. That the Petitioners have filed the revision before this honorable Court

in which no date of hearing has yet been fixed;

2. That the balance of convenience lies in favour of the petitioners;

3. That there is a good prima-facie and arguable case in favour of the

petitioners;

4. That if the status quo is not, the petitioners shall suffer an irreparable

loss as the needful could be done by verifying the continuous

possession of the petitioners over the land in question.

DEPONENTS
VERIFICATION:-
Verified on oath at Lahore on this day of July, 2020,
that the contents of this affidavit are true and correct to the best
of my knowledge and belief.
DEPONENTS

BEFORE THE LEARNED SENIOR MEMBER, BOARD OF REVENUE,

PUNJAB, LAHORE.

IN RE.
Zia-ul-Haq, etc., reesidents of Chak No. I/P, Tehsil Khanpur,
PETITIONERS

Versus

Additional Commissioner (Revenue), Bahawalpur Division,

Bahawalpur, etc.
RESPONDENTS

Application to dispense with the attested copies of the documents.

Respectfully Sheweth:-

The petitioners submits as under:-

11. That the petitioners have filed the revision before this honorable
Court in which no date of hearing has yet been fixed;
12. That there is a good prima-facie and arguable case in favour of the
petitioners;
13. That the petitioners have applied for attested copies of the
documents which have not yet been provided to the petitioners;
14. That the attested copies of the documents shall be provided as soon
as the same are received from the concerned authorities/offices;
15. That the attested copies of the documents may very kindly be
dispense with and request to admit the instant revision may very
kindly be accepted.

APPELLANT
THROUGH COUNCIL:
CH. BASHIR AHMAD GUJJAR
ADVOCAT