IN THE COURT OF ADDITIONAL DEPUTY COMMISSIONER / DISTRICT

COLLECTOR, DISTRICT KASUR.

APPEAL No.______________/ 2023.

1. Rao Muhammad Aslam Khan S/O Rao Muhammad Amin Khan,
Caste, Rajput, Resident of Meer Sahib Road Mohalah Rajput Tehsil
Kot Radha Kishen, District Kasur.

2. Najama bibi daughter of Sughran bibi(late),

3. Mehwish bib daughter of Sughran bibi(late),

4. Smina bibi daughter of Sughran bibi(late),

Caste misteri, Resident of presentaly Meer Sahib Tehsil Kot Radha

Kishen, District Kasur ….........................Appellants.

Versus

1. Muhammad Akaram S/O Sugharan bibi( late)Caste misteri, Resident

of Meer Sahib Tehsil Kot Radha Kishen, District
kasure............................................................…Respondent.

APPEAL UNDER PARENTS PROTECTION ACT 2021 FOR

PROTECTION OF PARENTS FROM ILLEGAL DISPOSSESSION FROM
THE OWNED PROPERTY/HOUSE

Respectfully Sheweth,

1. That the Respondent is step son of the petitioner no 1 and also the
brother of petitioner no 2 and 4, in which the petitioners are onwner
and in possession of land measuring 7 marla bearing Intqaal no
793.through salam khata 2250/208, 4625K-
16M.qitaat,638.situatedTehsil Kot Radha Kishen, District Kasur at
 moza Kot Muhammad Meer according to the record of rights for year
2019-20copy of fard of record of rights is attached.
2. That the petitioners and respondents becomes owner in the property
in dispute through inheritance of deceased Sughran bibi(late), and
after the death of mother/wife of petitioners and respondents all are
joint owners in the property in question without petition from any court
of competent revenue authority/court.
3. That it is pertinent to mention here that the petitioner no 2 and 4 are
married and living in their husbands house whereas the petitioner no
1 is residing in the same house along with the respondent, the
respondent is also married one.
4. That the respondent is owner of his specific portion and have no right
to disposes any other resident there illegally and unlawfully but the
respondent without any justification and logic kicked out th petitioner
no 1 from his house and interested to grab the whole portion of the
property in question.
5. That the petitioner no 1 is old person and have no any other property
for residence except the property mentioned above, it is further
important to mention here that the petitioner no 1 making the whole
construction over the above said property and paid the huge amount
in construction process but the respondent without any lawful accuse
expel the present petitioners and others from the property in question.
6. That the petitioner through respectable approached the respondent
and requested him to vacate their portion as settled between the
petitioners and respondent and also grant permission to petitioners to
reside there but the respondent clearly refuse and also threatened
the petitioners for dare consequences.
7. That now it comes into the knowledge of petitioner the respondent
planned to further alienate the property in question to some one else
and aslo interested to hand over the possession to someone else
which is completely against the rights of petitioners being lawful
owners in property in question.
8. That the petitioner is step father of respondent and exclusion of the
petitioner from property in question fall under the ambit of parents
protection act 2021.
9. That if the application in hand not accepted and proceedings under
 parents protection act 2021 not to be initiated against the present
petitioner, the petitioners will suffer irreparable loss and damages.

PRAYER

In view of the above facts and submissions, it is most respectfully

prayed that this application in hand may kindly be accepted and criminal
proceeding may kindly be accepted under parents protection Act-2021
and also directed the concern law enforcement agencies to take the
appropriate action for vacation of property in question for the interest of
justice and equity. I

It is also further prayed that the respond may kindly be restrained

from alienation, any illegal act or cause any damage to the person and
property of petitioners till the final decision of the application in hand.
Any other relief which this Honorable Court may deem fit and
appropriate under the given circumstances may also be awarded to
meet the ends of justice.
APPELLANTs
1. Rao Muhammad Aslam Khan S/O Rao Muhammad Amin
2. Najama bibi daughter of Sughran bibi(late),

1. Mehwish bib daughter of Sughran bibi(late),

2. Smina bibi daughter of Sughran bibi(late).

Through,

CH. IJAZ AHMAD RAJPOOT

ADVOCATE HIGH COURT...
CERTIFICATE:

Certified that as per instructions this is first application being filed on

the subject matter before this Honorable Court.
IN THE COURT OF ADDITIONAL DEPUTY COMMISSIONER / DISTRICT
COLLECTOR, DISTRICT KASUR.

APPEAL No.______________/ 2023

Rao Muhammad Aslam Khan.
Versus
Muhammad Akaram

APPEAL UNDER PARENTS PROTECTION ACT 2021 FOR

PROTECTION OF PARENTS FROM ILLEGAL DISPOSSESSION FROM
THE OWNED PROPERTY/HOUSE

1. AFFIDAVIT OF Rao Muhammad Aslam Khan S/O Rao Muhammad

Amin Khan, Caste, Rajput, Resident of Meer Sahib Road Mohalah
Rajput Tehsil Kot Radha Kishen, District Kasur.
I, the above named deponent do hereby solemnly affirm and declare
as under:-
That the facts stated in the accompanying appeal are true and correct
to the best of my knowledge and belief, which may kindly be
considered as a part of this affidavit.
 DEPONENT
VERIFICATION
Verified on oath at Kasur that the contents of above
affidavit are true and correct to the best of my knowledge and
belief.

DEPONENT