IN THE COURT OF SENIOR CIVIL JUDGE,

SHAHPUR.

Civil Suit No.___________/2020

Ghulam Sakina D/o Hafiz Allah Ditta, R/o, Faisal

Colony, Shahpur City, Tehsil Shahpur, District
Sargodha.

……Plaintiff

VERWSUS

1. Muhammad Aslam S/o Ali Muhammad R/o

Faisal Colony, Near Town Committee, Shahpur
City, District Sargodha.

……Defendant.

2. Muhammad Tahir Amin S/o Muhammad Munir

Malik. R/o, General Bus Stand, Shahpur City,
District Sargodha.
------Pro Forma
Defendant.
3. Rehan Aslam S/0 Muhammad Aslam R/o Faisal
Colony, Near Town Committee, Shahpur City,
District Sargodha.
4. Muhammad Abdullah S/0 Muhammad Aslam R/o
Faisal Colony, Near Town Committee, Shahpur
City, District Sargodha.
5. Shawez Aslam S/0 Muhammad Aslam R/o Faisal
Colony, Near Town Committee, Shahpur City,
District Sargodha. (Defendant
No. 3-5 through Real Father Muhammad Aslam R/o Bushra Shahid
W/o Shahid Farooq).
6. Tabeer Hussain S/o Muhammad Munir Malik R/o
Faisal Colony Shahpur City, District,
Sargodha).
(Defendant No. 6 through Real Mother Bushra Shahid W/o
Shahid Farooq).
AMENDED PLAINT U/O SUIT FOR PARTITION U/S
4 OF THE PARTITION ACT, 2012 AND SEPARATE
POSSESSION OF HOUSE MEASURING 7.5 MARLA
SITUTATED AT FAISAL COLONY SHAHPUR CITY,
DISTRICT SARGODHA.

Respectfully Sheweth:-

1. That the plaintiff and defendants are the joint

owners of the suit property measuring 7.5 Marlas

comprising of 2 Rooms, 1 Bathroom, 1 Kitchen, 2

Shops attached with water pump, 1 water tank, 1

electric domestic meter situated in Khewat no/ 292,

Khatooni No. 1017, Khasra No. 780, Faisal Colony

near workshops, Shahpur City, Tehsil Shahpur

District . Sargodha.

2. That the suit property is fully constructed 7.5

Marlas House, adjacent with 2 shops which was

initially owned by Mr. Muhammad Munir Malik.

3. That after the death of Mr. Muhammad Munir

Malik, the property was transfered through

Mutation No. 7320 to the legal heirs of Mr. Munir

Malik which include Ghulam Bushra Shahid

(Widow), Sawera Batool (Daughter), Touqeer Haider,

Muhammad Taseer Haider, Muhammad Tabeer

 Haider, Muhammad Tahir Amin (Sons) and

Ghulam Zainab (Real Mother).

4. That after the death of Mst. Ghulam Zainab (the

mother of Muhammad Munir Malik), the share of

property owned by Mst. Ghulam Zainab was

transferred vide Mutation No. 7615 to the legal heirs

namely, Sher Muhammad, Maqsoodan Bibi and

Ghulam Bushra Shahid (Widow), Sawera Batool

(Daughter), Touqeer Haider, Muhammad Taseer

Haider, Muhammad Tabeer Haider, Muhammad

Tahir Amin (Sons) being the legal heirs of

Muhammad Munir Malik.

5. That the Defendant No.1, 3-5 purchased share of

Ghulam Bushra Shahid (Widow), Sawera Batool

(Daughter) Touqeer Haider, Muhammad Taseer

Haider, and which is approximately 4 Marlas Tabeer

Haider is still owner of 1 Marla and 79 Sq.Ft of land

out of the total 7.5 Marlas of Land.

6. That the plaintiff purchased the share of land

owned by Sher Muhammad and Maqsoodan Bibi

through a registered sale deed No. 298-1 dated 29-

06-2019 which is divisible from other portion of

 land owned by the Defendent No-1, 2 and Defendent

No. 3-6.

7. That the pro-forma defendant no.2 is also owner of

1-Marla and 79 Sq-ft of land in the suit property,

which is also under the illegal possession of

Defendent No. 1.

8. That the cause of action firstly arose in favour of the

plaintiff and against the Defendant No-1 on 29-06-

2019 when the plaintiff became the owner of the

property and continued untill the institution of the

above titled suit, when the defendent refused to

handover the share of property owned by the

plaintiff and rejected the genuine and lawful

demand of plaintiff.

9. That the parties to the suit are residing in Shahpur

and the suit property is also situated in Tehsil

Shahpur, hence this Court has territorial

jurisdiction to adjudicate upon the matter in

dispute.

10. That the value of the suit for the purposes of court

fee and jurisdiction is fixed at Rs.200/- which is

exempted from levy of court fee.

PRAYER:
 Under the above mentioned circumstances, it is,

therefore, most humbly and respectfully prayed that a

decree for partition of the house situated in Khewat No.

292, Khatooni 1017 and Khasra No. 780 situated in

Faisal Colony, Shahpur City, Tehsil Shahpur, Distruct

Sargosha. measuring 7.5 Marlas comprising of 2 Rooms, 1

Bathroom, 1 Kitchen and 2 Shops attached with water

pump, 1 electric domestic meter, situated in the street near

Motor workshop along with separate possession may

kindly be passed in favour of the plaintiff and against the

defendant No.1.

Any other relief, which this Honourable Court deems

fit may also be also granted.

…Plaintiff
Through

MALIK MUHAMMAD RAMZAN

Advocate High Court.
Office Tehsil Courts, Shahpur
Saddar,District Sargodha.

VERIFICATION:

Verified on Oath at Lahore this 6th day of December,

2020, that the contents of the above paras No.1 to 7 are
true and correct to the best of my knowledge and rest of
paras No. 8 to 10 are true and correct to the best of my
information and belief.
IN THE COURT OF SENIOR CIVIL JUDGE,
SHAHPUR.

C.M.A__________________/2020

in

Civil Suit No.___________/2020

Ghulam Sakina

……Plaintiff.

VERSUS

Muhammad Aslam

..…Defendant.
(SUIT FOR PARTITION U/S 4 OF THE PARTITION ACT, 2012 AND SEPARATE POSSESSION OF HOUSE
MEASURING 7.5 MARLA SITUTATED AT FAISAL COLONY SHAHPUR CITY, DISTRICT SARGODHA).

APPLICATION UNDER RULE 1 & 2 READ WITH SECTION 151 C.P.C.

1908 FOR TEMPORARY INJUNCTION.

1. That the plaintiff filed accompanying suit in this Learned

Court today which has not been fixed so far.

2. That the contents of the accompanying suit may also be

read as an integral part of this application.

3. That the plaintiff has prima facie a good arguable

case.and the suit is likely to be decreed in favor of the

plaintiff.

4. That the defendent no.1 is trying to demolish, re-built and

modify the suit property in order to change the existing

structure of the property. Hence, the defendent no.1, if not

not restrained from selling, alienating and transferring the

possession of the property to anyone , the plaintiff shall in

all propability suffer from an irreparable loss and injury.

5. That the balance of convenience lies in favor of the

plaintiff.

PRAYER: It is, therefore, most respectfully prayed

that the defendent no.1 may very kindly be restrained from

alienating; selling/transferring the property in question

and also be restrained from demolishing, re-builting or

modifying the basic structure of the property.

Ad-interim injunctive order till the decision of this

application may also be passed.

…Plaintiff
Through

CH. SAMAR ABBAS MAKEN MALIK MUHAMMAD RAMZAN

Advocate High Court Advocate High Court.
Office Tehsil Courts, Shahpur
Saddar,District Sargodha.
IN THE COURT OF SENIOR CIVIL JUDGE,
SHAHPUR.

C.M.A__________________/2020

in

Civil Suit No.___________/2020

Ghulam Sakina

……Plaintiff.

VERSUS

Muhammad Aslam

..…Defendant.
(SUIT FOR PARTITION U/S 4 OF THE PARTITION ACT, 2012 AND SEPARATE POSSESSION OF HOUSE
MEASURING 7.5 MARLA SITUTATED AT FAISAL COLONY SHAHPUR CITY, DISTRICT SARGODHA).

APPLICATION UNDER SECTION 7 OF THE PARTITION ACT, 2012

READ WITH SECTION 151 C.P.C. 1908 FOR TEMPORARY

INJUNCTION.

1. That the plaintiff filed accompanying suit in this Learned

Court today which has not been fixed so far.

2. That the contents of the accompanying suit may also be

read as an integral part of this application.

 3. That the plaintiff has prima facie a good case and the suit

is likely to be decreed in favor of the plaintiff.

4. That the defendent no.1 is in illegal possession of the

share of the plaintiff and defendent No.2 for which he is

entitiled to deposit mesne profits u/s 7 of the Partition Act.

2012.

PRAYER: It is, therefore, most respectfully prayed

that the defendent no.1 may very kindly be directed to

deposit interim mesne profits in the court.

Ad-interim mesne profits till the decision of this application

may also be passed.

…Plaintiff
Through

CH. SAMAR ABBAS MAKEN MALIK MUHAMMAD RAMZAN

Advocate High Court Advocate High Court.
Office Tehsil Courts, Shahpur
Saddar,District Sargodha.