1

IN THE COURT OF SENIOR CIVIL JUDGE,LAHORE

Civil Suit No._______________/2011

MUHAMAMD SHAFIQUE son of Muhammad

Ibrahim, resident of Akbarabad Shahdrah Town,
Lahore.

……PLAINTIFF

VERSUS

1. SDO WAPDA, Sub Division Ravi Road, Shahdhra,

Lahore.

2. Chairman WAPDA, Lesco.

…DEFENDANTS
___________

SUIT FOR DECLARATION WITH RENDITION OF

THE ACCOUNT WITH PERMANENT INJUNCTION.
___________

Respectfully Sheweth:

1. That the father of the plaintiff install a electric

meter which the reference
No.19111310340700R and old account
No.19113103417003 and it was installed on
dated 28 December 1986, from the department
of Lesco, WAPDA and now the plaintiff is
utilizing the above said meter connection for
his personal use. Copy of the bill is attached
with this plaint.

2. That the plaintiff is regular customer of

WAPDA department and without any

cogent reason the plaintiff is paying monthly

bill to the office of the Lesco, WAPDA.

1
 2

3. That 14th December 2010 the department sent

the bill of Rs.9032 and the plaintiff with good
intention paid the aforementioned bill. Copy of
the bill is enclosed.

4. That a new bill of the month of January, 2011

the plaintiff maintenance his previous record
and show his good conduct without any hurdle
pay the bill Rs.22051/- and same the position
was in the month of February 2011. Copies of
the January and February 2011 bills are
attached.

5. That in the month of March 2011 a new bill of

Rs.30546/- including the remaining/arrears
charges was sent to the plaintiff but the
plaintiff had already paid the previous bill to
the relevant department but with the malafide
intention the official of the department
demanded a huge amount from the plaintiff
but the plaintiff is poor person and cannot
afford the paid amount again and again.

6. That the plaintiff approached to the Sub

Divisional Officer from the correcting the bill of
March 2011 but the SDO refused the genuine
request of the plaintiff and said that the
plaintiff did not pay a single penny the month
of January 2011.

7. That a week ago when a WAPDA team with the

joining hand of defendant No.1 approached to
the plaintiff’s electric meter but the timely
intervention of the plaintiff and the people of
the locality, they restrained the defendant No.1
not to disconnect the meter of the plaintiff.

8. That the cause of action arose firstly one

month ago when the defendants sent a illegal,
unlawful and false bill to the plaintiff, secondly
a week ago when the defendants tried their
best to disconnect the meter of the plaintiff
and the same is still continuing and the
parties are also residing at Lahore, so this
Honourable Court has the power to adjudicate
the above said matter.

2
 3

9. The court fee has been affixed according to

law.

PRAYER

It is therefore most respectfully prayed that

this plaint may kindly be accepted and also
order to the defendants not to disconnect the
electric meter of the plaintiff till the final
decision of the case.

It is further prayed that an order be

passed to the defendants that the defendants
would deduct/remove the disputed amount
Rs.22051/- from the currently bill because the
plaintiff had already paid it.

PLAINTIFF

Through

MIAN MUHAMMAD AZAM

Advocate High Court
BURHAN MOZZAM LAWYERS CONSTELLATIONS
30-Mclagon Road, Lahore.

3
 4

IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

Civil Suit No.____________/2011

In re:

MUHAMAMD SHAFIQUE
Versus
SDO WAPDA etc
(SUIT FOR DECLARATION WITH RENDITION OF ACCOUNT)
___________

AFFIDAVIT of Muhamamd Shafique son of Muhammad

Ibrahim, resident of Akbarabad Shahdrah
Town, Lahore.
___________

I, the above named deponent do hereby solemnly

affirm and declare as under:-

That the contents of the accompanying

application are true and correct to the
best of my knowledge and belief and
nothing material has been suppressed
from Honourable Court.

DEPONENT
VERIFICATION:
Verified on oath at Lahore, this the 25 th day of
March, 2011 that contents of the above affidavit are
true and correct to the best of my knowledge and
belief.

DEPONENT

4
 5

IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

Civil Suit No.________/2011

MUHAMAMD SHAFIQUE
Versus
SDO WAPDA etc
__________

APPLICATION under Order 39 Rules 1 & 2 read

with Section 151 CPC for grant of Interim Relief.
________

RESPECTFULLY SHEWETH:

1. That contents of the suit may kindly be read as

integral part of this application on the basis
whereof the petitioner has a very good prima facie
case to succeed before this Honourable Court.

2. That respondents directed not to disconnect the

petitioner’s electric meter in any manner
whatsoever, other wise the petitioner will suffer
an irreparable loss and injury.

PRAYER

It is therefore most respectfully prayed that

this plaint may kindly be accepted and also
order to the defendants not to disconnect the
electric meter of the plaintiff till the final
decision of the case.

It is further prayed that an order be passed

to the defendants that the defendants would
deduct/remove the disputed amount
Rs.22051/- from the currently bill because the
plaintiff had already paid it.

PETITIONER
Through

COUNSEL
Dated: 25.03.2011