IN THE COURT OF SENIOR CIVIL JUDGE-I ZHOB.

Sardar Sardar Khan & others ……. Plaintiffs

VERSUS

Tahir Rasheed (CEO) BRSP and Others …………... Defendants

SUIT FOR REMOVING ILLEGAL POSSESSION, MANDATORY,

PREVENTIVE AND PERMANENT INJUNCTION.

REJOINDER TO THE APPLICATION UNDER ORDER 39

RULE 1& 2 CPC ON BEHALF OF RESPONDENTS NO. 1 to 10.

The respondents No. 1 to 10 respectfully submit as under:

PRELIMINARY LEGAL OBJECTIONS:
A- That the application under reply is filed beyond the scope of
Order 39 Rule 1 and 2 CPC, therefore, the same is liable to be
dismissed.

B- That the application under reply is totally misconceived,

baseless and not maintainable according to law, therefore, the
same is liable to be dismissed.
C- That the plaintiffs superseded the material facts from this
Hon’ble court and approached with unclean hands to this
Hon’ble court as such the plaintiffs are not entitled for any kind
of relief, therefore, the application under reply is liable to be
dismissed.

D- That for the sake of brevity the PLOs raised in the written
statement may kindly be treated as part and parcel of the instant
rejoinder.
E- That the applicants are no entitlement or interest in the
properties in question, therefore, the application under reply is
liable to be dismissed.
 ON MERITS
1. That the contents of para No.1 are admitted.
2. That the contents of para No.2 are denied and vehemently
contested with further clarification that the applicants/plaintiffs
have no legal character or right in the property in question as
such no prima facia case is made out from the plain reading of
the plaint and there is every likelihood of the same being
dismissed.

3. That with regard to the contents of para No.3 it is submitted that

to avoid the repetition, the contents of main written statement
may kindly be treated as a part and parcel of this rejoinder.
4. That the contents of para No.4 are denied and vehemently
contested with further clarification that the applicants/plaintiffs
have failed to make out prima facia case and balance of
convenience also lies in favor of respondents and if the
restraining order in any manner of whatsoever is passed with
regard to the properties in question, the irreparable loss would
be caused to the answering respondents.
It is, therefore, respectfully prayed that keeping in
view of the above submissions the application under reply
being misconceived, baseless and not maintainable according to
law my kindly be dismissed in the interest of justice, equity and
fair play.

Date : 30-09-2023 Respondents No. 1 to 10

Through Attorney

AFFIDAVIT

I, S/o ,
resident of , , do hereby
solemnly affirm and state on oath that the contents of the
rejoinder are true and correct to the best of my knowledge and
belief and nothing relevant has been concealed therefrom.
Date:30-09-2023.
Deponent