IN THE COURT OF ____ SENIOR CIVIL JUDGE, AT

KARACHI (EAST)
Suit No. of 2022

1. Sohail Ahmed son of Abdullah Khatri,

Muslim, Adult, holding CNIC No. 41408-
4188948-7, resident of Flat No. 102, Shah
Arcade, 15th Street, Bihar Colony, E Road,
Lyari, Karachi.

2. Tehseen Abdullah son of Amanullah,

Muslim, Adult, holding NICOP No.42201-
5191887-5, resident of House No. B-97, Block
14, Gulistan-e-Johar, Karachi.
Through his Attorney, Shafqat Alim son of
Abdul Alim, Muslim, Adult, holding CNIC
No.42101-1585108-7, resident of House No.
R-785, Sector 15-A, Bufferzone, North
Karachi, Karachi.

3. Sabir son of Abdul Khaliq, Muslim, Adult,

holding CNIC No.42401-1871749-7, resident
of House No. 1726/2394A, Muhajir Camp,
Saeedabad, Karachi.

4. Iqra Sabir daughter of Sabir, Muslim, Minor,

resident of House No. 1726/2394A, Muhajir
Camp, Saeedabad, Karachi.
Through her father (natural guardian)
Mr.Sabir son of Abdul Khaliq, Muslim,
Adult, holding CNIC No.42401-1871749-7.

5. Murtaza Shah son of Mustafa Shah, Muslim

Adult, holding CNIC No. 42201-0538689-3,
resident of House No. 61, Street No. 18,
Jinnah Garden, Phase 1, Islamabad.
Through his Attorney, Muhamad Aslam son
of Late Rehmat Din, Muslim, Adult, holding
CNIC No. 42101-1120490-9, resident of House
No. R-76, Sector 14/A, Shadman Town,
North Karachi, Karachi.

6. Wajid Ali son of Muhammad Ali, Muslim,

Adult, holding CNIC No. 42201-3618191-5,
resident of House No. L-329, Hussain Hazara
Goth, Block 11, Gulshan-e-Iqbal, Karachi.

……….. Plaintiffs

Versus

1. Go Big Trade (Private) Limited,

 2

A Company registered under the Companies

Act, 2017, having its Principal/Head Office,
at Suite No. 507, 5th Floor, Business Center,
Main Shahra-e-Faisal, Karachi, through its
Managing Director, Zafar Iqbal son of Sher
Aslam, Muslim, Adult, holding CNIC No.
42201-6591226-7, resident of Plot No. 117/10,
Drigh Road, Cantt Bazar, Shahra-e-Faisal,
Karachi.

2. M/s Goat 2 Goats,

A partnership firm registered with the
Registrar of Firms having Registration
No.2018-19/0055, having its Principal Office
at Suite No. 704-A, 7th Floor, Mashrique
Center, Adjacent to Deputy Commissioner
(East) Office, Sir Shah Muhammad Suleman
Road, Karachi.
Also having farm on land measuring 75 acres
approx., situated at Research Farm Sindh-A,
Ghulamullah Road, Makli, Thatta.
Through its Partners:
(i) Sadaqat Hussain son of Barkat Ali
Awan, holding CNIC No. 42401-
1726715-5, resident of House No. R/277,
Block 9, Dastagir Colony, F. B. Area,
Karachi.
(ii) Muhammad Khalid Khan son of Abdul
Waheed Khan, resident of C-5, Block
No.1, F.B. Area, Karachi.
(iii) Mst. Tahira Sadaqat wife of Sadaqat
Hussain, holding CNIC No. 34601-
0759987-0, resident of House No. R/277,
Block 9, Dastagir Colony, F. B. Area,
Karachi.

3. Pakistan Goat Association

Having its Principal/Head Office, Office at
Suite No. 704-A, 7th Floor, Mashrique Center,
Adjacent to Deputy Commissioner (East)
Office, Sir Shah Muhammad Suleman Road,
Karachi. Through its Founder Chairman,
Sadaqat Hussain son of Barkat Ali Awan,
holding CNIC No.42401-1726715-5, resident
of House No.R/277, Block 9, Dastagir
Colony, F. B. Area, Karachi.

4. M/s Picrash Technologies,

Having its Principal/Head Office, at Office at
Suite No.704-A, 7th Floor, Mashrique Center,
Adjacent to Deputy Commissioner (East)
Office, Sir Shah Muhammad Suleman Road,
Karachi. Through Sadaqat Hussain son of
Barkat Ali Awan, holding CNIC No.42401-
1726715-5, resident of House No. R/277,
Block 9, Dastagir Colony, F. B. Area, Karachi.
 3

5. Sadaqat Hussain son of Barkat Ali Awan,

holding CNIC No.42401-1726715-5, resident
of House No. R/277, Block 9, Dastagir
Colony, F. B. Area, Karachi.

6. Mst. Tahira Sadaqat wife of Sadaqat

Hussain, holding CNIC No. 34601-0759987-0,
resident of House No. J-107, 2nd Floor,
Dawood Residency, Gulzar-e-Hijri, Karachi.

7. Mst. Rabia Sadaqat wife of Sadaqat Hussain,

holding CNIC No.42000-9781409-8, resident
of 3/12, 3rd Floor, Al-Ghafoor Duplex,
Gulshan-e-Iqbal, Block 19, Karachi.

8. Mst. Asfia Sadaqat wife of Sadaqat Hussain,

holding CNIC No.42000-6160433-2, resident
of resident of House No. R/277, Block 9,
Dastagir Colony, F. B. Area, Karachi.

9. Zafar Iqbal son of Sher Aslam, Muslim,

Adult, holding CNIC No. 42201-6591226-7,
resident of Plot No. 117/10, Drigh Road,
Cantt Bazar, Shahra-e-Faisal, Karachi.
General Secretary, Pakistan Goat Association.

10. Hafiz Muhammad Nadeem Ahmed son of

not known to Plaintiffs, Muslim, Adult,
having office at Suite No. 704-A, 7 th Floor,
Mashrique Center, Adjacent to Deputy
Commissioner (East) Office, Sir Shah
Muhammad Suleman Road, Karachi.
Senior Vice President Punjab, Pakistan Goat
Association.

11. Mazhar Ali Jakhar son of Ghulamullah

Jakhar, holding CNIC No. 41409-9389572-7,
resident of Nareja Village Makli, Thatta,
Sindh, Pakistan.

12. Ghazanfar Abbas Jatoi son of not known to

Plaintiffs, Muslim, Adult, having office at
Suite No. 704-A, 7th Floor, Mashrique Center,
Adjacent to Deputy Commissioner (East)
Office, Sir Shah Muhammad Suleman Road,
Karachi.
Senior Vice President Sindh, Pakistan Goat
Association.

13. Maqsood Ahmed son of Mukhtar Ahmed,

holding CNIC No. 33302-2283375-9, resident
of Plot No. G-118, Defence View Phase 2,
Karachi.
General Manager, Go Big Trade (Pvt.) Ltd.

……….. Defendants
 4

SUIT FOR RECOVERY, DAMAGES & PERMANENT

INJUNCTION

It is humbly submitted on behalf of the Plaintiffs abovenamed as

under:

1. That, the Plaintiffs are respectable and law abiding citizens of

Pakistan, who belong to various walks of life. The Defendants No. 1 to 4
are various businesses owned and operated by the Defendants No. 5 to 8
in collusion with various persons including the Defendants No. 9 to 13.

2. That, the instant Suit is being filed by the Plaintiffs against the
Defendants in order to claim recovery of the amounts invested by the
Plaintiffs along with the profits accumulated thereon, due to a fraud
committed and perpetrated by the Defendants upon the Plaintiffs as well
as on thousands of other members of public at large. This fraud has been
carried out by the Defendants in the nature of a Ponzi Scheme, whereby
the Defendants sought money from the Plaintiffs as an investment in their
business of purchase of goats and gave false assurances and commitments
that within a period of 18 months, the Defendants will pay out double the
amount invested by the Plaintiffs. The Plaintiffs including various other
members of public invested their hard earned money and savings with the
hope of receiving handsome returns on their investment. However, after
giving payouts of some nominal amounts to some investors, the
Defendants stopped making payments and most of the Defendants are
nowhere to be found. It is estimated that the total amount of investments
made by various members of public goes into billions of rupees. The
Plaintiffs submit that the Defendants have committed serious fraud on the
Plaintiffs as well as on the other members of the public, and they are liable
to return the amounts of investments made by the Plaintiffs along with
any and all the returns promised by the Defendants. Hence the instant
Suit for recovery of amounts is being filed.

COPIES OF VARIOUS DOCUMENTS PERTAINING TO

REGISTRATION, IDENTIFICATION, & THE FRAUD COMMITTED BY
THE DEFENDANTS ARE ANNEXED HEREWITH AND MARKED AS
“A” TO “A/21”.

3. That, the Defendants entered into written contracts with the

Plaintiffs. The contracts were of two categories i.e. Regular Contract and
Corporate Contract. These contracts were entered individually with each
of the Plaintiffs and such contracts are written contracts having original
 5

stamp of the Defendant No. 1 Company and signatures of concerned

employees/ representatives of the Defendant No.1 Company.

4. That, as per the contract, the amount invested by the Plaintiffs was
Rs. 35,000/- per unit or goat, and the Defendants gave false assurances
and commitments that Defendants will keep the goats for a period of 18
months and after 18 months period, the profit would be a pregnant goat
or its offspring, such that this pregnant goat will be treated as double of
goats and if such pregnant goat gives birth to more than one offspring,
such extra offspring would be counted as bonus, and the Plaintiffs would
receive their due share from such bonus also. As per the contract, after
expiry of the 18 months period, the Defendants would purchase the unit
or goat from the Plaintiff and pay the amount of capital invested and the
profit i.e. the price of offspring of the goat, and the bonus (if any). The
Defendants gave assurances that this arrangement or contract would yield
profits to an extent that it would double the amount invested within 18
months and would also pay bonus if the goat gives birth to more than one
offspring.

5. That, relying on the brochures, flyers, and various other

documentations shown and the registered nature of the businesses of the
Defendants, as well as a sham goat farms shown to the Plaintiffs
individually, the Plaintiffs signed/executed the contracts and made
payments required under such contracts. In the beginning, certain
nominal amounts were paid out by the Defendants as returns, in order to
attract more members of public.

6. That, however, after passage of nearly one year, the Defendants

stopped making payments, and the offices of the Defendants No. 1 to 4
businesses were closed. In or around February, 2022, the Plaintiffs sensing
a fraud, made various attempts to contact the Defendants No. 5 to 8 and
their employees, partners, & agents etc., and demanded their invested
amounts along with profits to be returned, but to no avail as the
Defendants could not be contacted. The said Defendants have stolen the
money invested by the Plaintiffs and other members of public, and are
presently nowhere to be found and have disappeared.

7. That, it has now become obvious that the Defendants created sham
companies and businesses in order to perpetrate such fraud. The goat
farms shown to some of the Plaintiffs were nothing but a sham and a
façade in order to lure more and more people into making investments.
 6

8. That, the Plaintiffs seriously apprehend that the Defendants No. 5

to 13 and their other accomplices, having gone into hiding, will certainly
leave the Country and/or shift the moneys stolen from the Plaintiffs and
other members of public, to abroad in order to misappropriate the same
and in order to defeat any lawful remedy for recovery of such amounts.

9. That, it is humbly submitted that the Defendants have perpetrated

serious organized fraud upon the Plaintiffs as well as on the other
members of public under a garb of registered businesses. It is submitted
that the Defendants have carried out such fraud in the nature of a Ponzi
Scheme and Pyramid Scheme similar to that of the infamous case of
Double Shah. The serious nature of this fraud could also be gauged from
the fact that thousands of members of the general public have been
defrauded and led to believe in the fraudulent businesses, and on such
basis, they have been deprived of their hard earned monies.

10. That, it is further submitted that some of the investors also lost their
lives and/or suffered great mental torture and trauma, after coming to
know that the Defendants have committed a fraud with them and that
they may not be able to recover their invested amounts. As such, the
Plaintiffs also claim damages on account of mental torture, stress and
agony.

11. That, it is therefore submitted that the Plaintiffs made payments to

the Defendants under several contracts signed with the Defendants. The
details of such payments are given in the table annexed herewith as
Annexure “B”. The Plaintiffs claim an amount of Rs. 11,684,632/- on
account of the amounts invested by Plaintiffs and the profits agreed &
accumulated.

A TABLE SHOWING DETAILS OF THE PAYMENTS MADE BY THE

PLAINTIFFS TO THE DEFENDANTS, THE AMOUNTS RECEIVED (IF
ANY), AND THE AMOUNT OF CLAIM OF EACH OF THE PLAINTIFFS,
IS ANNEXED HEREWITH AND MARKED AS “B”.

12. That, the Plaintiffs also have the contracts signed with the
Defendants, copies of which are annexed herewith. It is submitted that
even otherwise, the Defendants are liable to return the amounts paid by
the Plaintiffs under such contracts, along with any and all profits
accumulated thereon.
 7

TRUE COPIES OF THE CONTRACTS SIGNED BY EACH OF THE

PLAINTIFFS WITH THE DEFENDANTS & OTHER RELEVANT
DOCUMENTS REGARDING EACH DEFENDANT ARE ANNEXED
HEREWITH AND MARKED AS “C” TO “C/5”, RESPECTIVELY.

13. That, the Plaintiffs have also found various documents pertaining
to the Defendants No. 1 to 4 businesses and various other details of the
Defendants No. 5 to 8 involved in this organized fraud upon the public at
large. All such documents have been annexed here in above for this
Hon’ble Court’s record. In addition to these documents, the Plaintiffs also
pray that this Hon’ble Court may graciously be pleased to allow further
documents to be taken out from the record of various government
departments, in order to further ascertain other persons involved in
committing this large scale fraud on the Plaintiffs as well as other
members of the public.

14. That, the Plaintiffs further claim an amount of Rs. 1,000,000/- per
person, as damages on account of mental torture, stress, and agony. The
Plaintiffs also claim mark-up at the prevailing market rate on the amounts
claimed by the Plaintiffs from the date of investment till their realization.

15. That, it is further submitted that keeping in view the severity of the
fraud and the fraudulent actions of the Defendants, it is clear that the
Defendants have disappeared after misappropriating huge amounts of
money from the public at large including from the Plaintiffs.
Consequently, it is apparent that the Defendants will also attempt to
dispose of any and all properties and assets in their possession, in order to
defeat any Decree that could be passed by this Hon’ble Court. Therefore,
this Hon’ble Court may graciously be pleased to allow searches to be
carried out in order to ascertain the properties and assets in the name of
the Defendants, and then to appoint Receiver for the properties and assets
of the Defendants No. 1 to 4 businesses and of the personal properties and
assets of the Defendants No.5 to 13 and other accomplices involved in this
fraud. This will help in securing the Plaintiff’s claim and any decree that
may be passed by this Hon’ble Court.

16. That the cause of action for the present Suit arose in favor of the
Plaintiffs as against the Defendants, on several dates as stated in the
paragraphs herein above and in the documents annexed herewith, and
lastly arose on February 7, 2022, when some of the Plaintiffs went to visit
the offices of the Defendants and found the same closed and locked; and
thereafter the cause of action is continuing and arises on day to day basis
 8

till the date of filing of the instant Suit, and on each day thereafter as the
Plaintiffs have been deprived of their lawful savings;

17. That for the purposes of calculating the Court fees, the instant Suit
is valued at more than Rs.17,684,632/-, for which the maximum Court Fees
has been paid.

18. That, the Plaintiffs have duly signed/verified the Plaint in person
or through their respective duly constituted Special Attorney, copies of
respective Powers of Attorney are annexed herewith.

TRUE COPIES POWERS OF ATTORNEYS ARE ANNEXED

OF
HEREWITH AND MARKED AS “D” TO “D/1”, RESPECTIVELY.

19. That the head office of the Defendant No. 1 is situated within the
territorial limits of PS-Tipu Sultan, which police station is within the
jurisdiction of this Hon’ble Court. Hence this Hon’ble Court has
jurisdiction to adjudicate on this instant Suit.

PRAYER

That it is therefore prayed, that this Hon’ble Court on the facts and
circumstances of this case, be pleased to,

A. Declare that the Defendants have intentionally and knowingly

caused fraud on the Plaintiffs and other members of general public
through a Ponzi Scheme;

B. Pass a judgment and decree in favour of the Plaintiffs and against

the Defendants, for the sum of Rs. 11,684,632/- (Rupees Eleven
Million Six Hundred Eighty Four Thousand Six Hundred Thirty
Two) on account of the amounts payable by the Defendants to the
Plaintiffs as promised and agreed by the Defendants as per the
respective contracts signed with the Plaintiffs, details of the
amounts are given in Annexure B hereof;

C. Pass a judgment and decree in favour of the Plaintiffs as against the

Defendants, for the sum of amount of mark-up to be calculated at
the prevailing market rate on amounts claimed by each of the
Plaintiffs and decreed by this Hon’ble Court, such amount may be
calculated from the date of investment made by each of the
Plaintiffs till its realization;
 9

D. Pass a judgment and decree in favour of the Plaintiffs and against

the Defendants, for the sum of Rs.1,000,000/- (Rupees One Million)
per Plaintiff total of Rs.6,000,000/- (Rupees Six Million), on
account of damages for mental torture, stress, and agony suffered
by the Plaintiffs;

E. Grant permanent injunction against the Defendants, their agent or

agents, servant or servants, person or person working under them
restraining them from selling, encumbering, disposing of, or
creating any third party interest in any manner whatsoever on any
movable or immovable assets or properties of the Defendants No. 1
to 4 businesses;

F. Grant permanent injunction against the Defendants, their agent or

agents, servant or servants, person or person working under them
restraining them from selling, encumbering, disposing of, or
creating any third party interest in any manner whatsoever on any
movable or immovable assets or properties of the Defendants No. 5
to 13;

G. Appoint Receiver to takeover and manage the affairs of the

moveable and immovable properties of the Defendants No. 1 to 4,
till realization of the monies of Plaintiffs;

H. Grant costs of this Suit;

I. Any other further relief or reliefs that this Hon’ble Court may be
pleased to deem fit and proper in the facts and circumstances of the
case;

PLAINTIFF NO. 1 PLAINTIFF NO. 2 PLAINTIFFS NO. 3 &

4

PLAINTIFF NO. 5 PLAINTIFF NO. 6

ADVOCATE FOR THE PLAINTIFFS

Karachi:
Dated: May, 2022
 10

VERIFICATION

We,
(1) Sohail Ahmed son of Abdullah Khatri, Muslim, Adult, having CNIC
No. 41408-4188948-7, resident of Flat No. 102, Shah Arcade, 15th Street,
Bihar Colony, E Road, Lyari, Karachi, the Plaintiff No.1;
(2) Shafqat Alim son of Abdul Alim, Muslim, Adult, holding CNIC
No.42101-1585108-7, resident of House No. R-785, Sector 15-A, Bufferzone,
North Karachi, Karachi, the duly constituted attorney of Plaintiff No.2;
(3) Sabir son of Abdul Khaliq, Muslim, Adult, having CNIC No.42401-
1871749-7, resident of House No. 1726/2394A, Muhajir Camp, Saeedabad,
Karachi, the Plaintiff No.3 for self and as Natural Guardian of the
Plaintiff No.4;
(4) Muhammad Aslam son of Late Rehmat Din, Muslim, Adult, holding
CNIC No. 42101-1120490-9, resident of House No. R-76, Sector 14/A,
Shadman Town, North Karachi, Karachi, the duly constituted Attorney of
Plaintiff No.5;
(5) Wajid Ali son of son of Muhammad Ali, Muslim, Adult, holding CNIC
No. 42201-3618191-5, resident of House No. L-329, Hussain Hazara Goth,
Block 11, Gulshan-e-Iqbal, Karachi, the Plaintiff No. 6;

Do hereby state on Oath that the contents of the Plaint have been
read over to us in the language that we duly understand and we have
gone through the same and we fully understand the same, and whatever
stated herein above is true and correct to the best of our knowledge and
belief.

DEPONENT NO.1 DEPONENT NO.2

CNIC No. ________________ CNIC No. ________________
Cell No. ________________ Cell No. ________________

DEPONENT NO.3 DEPONENT NO.4

CNIC No. ________________ CNIC No. ________________
Cell No. ________________ Cell No. ________________

DEPONENT NO.5
CNIC No. ________________
Cell No. ________________
Karachi,
Dated: May, 2022
 11

DOCUMENTS FILED :

S.
No Description of documents Date Marked
.
Copies of various documents pertaining to “A” to
1. -
the Defendants “A/21”
A table showing details of the payments
made by the Plaintiffs to the Defendants
2. - “B”
the amounts received (if any), and the
amount of claim of each of the Plaintiffs.
True copies of the contracts signed by each “C” to
3. -
of the Plaintiffs with the Defendants “C/5”
True copies of Powers of Attorneys of “D” &
4. -
respective Plaintiffs “D/1”

DOCUMENTS RELIED UPON :

Originals of the above and all other documents / papers / correspondence

relating to this case, etc.

ADDRESS OF THE PLAINTIFFS:

As given at the title of the Plaint.

ADDRESS OF ADVOCATE FOR THE

PLAINTIFFS AND FOR SERVICE:

MUHAMMAD ALI TALPUR & CO.

Barristers & Legal Consultants,
Office No.2, Mezzanine Floor,
Plot No.44-C, Main 24th Commercial Street,
Phase 2 Extension, D.H.A,
Karachi.
Cell : 0300 9239094
Tel. : 021 3531 1168
E-mail : barrister.talpur@gmail.com

Drafted by

Barrister-at-Law