IN THE COURT OF MUHAMMAD KHALIL CHAUDHARY,

JUDGE BANKING COURT NO-II, MULTAN.

In re:
Muhammad Alam etc. Vs. Small Business
Finance Corporation
Vehari etc.

Suit for Rendition of Account

Application for Grant of Permission

to defend the titled Suit.

Respectfully Sheweth:-

1. That the above titled suit is pending adjudication before this

Hon’ble Court and is fixed for 31.8.99.
2. That the summons issued by this Hon’ble Court were received
by the Respondents on 5.8.99, as such application for leave to
defend is well within time.
3. That the plaintiff has filed the suit without any cogent and
convincing reasons, moreover as filed the titled suit only with
the object to usurp the loan amount obtained from the
Respondents. As such the suit is based on malafide and ulterior
motive because there are Rs. 178,656/- outstanding against the
plaintiff till the month of June, 1999.
4. That the valuable rights of the Respondent are involved in the
matter in hand and in case, this application is declined, the
Respondent would undoubtedly confront with more hardships
and inconvenience besides legal complications would also arise
and the dictum of Hon’ble Superior Courts that “every person
should not be condemned unheard” would be violated.
5. That balance of convenience too leans in favour of the
Respondent, because Small Business Finance Corporation has a
good prima-facie and arguable case and there are bright chances
of success. An affidavit is attached.
It is therefore most respectfully prayed that this
application may kindly be accepted and the
Respondent may graciously be permitted to defend the
suit on Respondent’s behalf.

Humble Respondent.

Through: -
Through:-
SAEED HASSAN HASHMI MANAGER
Advocate High Court,
Seat No. 40, Aziz Block
 District Courts, Multan.
IN THE COURT OF MUHAMMAD KHALIL CHAUDHARY,
JUDGE BANKING COURT NO-II, MULTAN.

In re:
Muhammad Alam etc. Vs. Small Business
Finance Corporation
Vehari etc.

Suit for Rendition of Account

Application for Grant of Permission
to defend the titled Suit.

AFFIDAVIT of:-
Mushtaq Sarwar Manager Small Business
Finance Corporation, Vehari.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the accompanying application for leave to
defend the suit are true and correct to the best of
my knowledge and belief.

Deponent.

Verification: -
Verified on oath at Multan,
this_____ day of August, 1999 that the contents
of this affidavit are true to the best of my
knowledge and belief.

Deponent
 IN THE COURT OF MALIK AHMAD BAKHSH BHAPA,
JUDGE BANKING COURT NO-I, MULTAN.

In re:
Wazeer Ahmad Vs. Small Business
Finance Corporation
Vehari etc.

Suit for Declaration

Memo of Appearance

Respectfully Sheweth:-
1. That the above titled suit is pending adjudication before this
Hon’ble Court and is fixed for today.

2. That the above titled suit of the undersigned has been engaged
as a counsel to defend the suit. The power of Attorney still has
not been received; the same will be produced as soon as
received.

Under the above circumstances, the memo of appearance

may kindly be accepted.

Through:-

SAEED HASSAN HASHMI

Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
Legal Advisor S.B.F.C.
 POWER OF ATTORNEY

In the ____________________________________________________________________________
in the matter of ____________________________________________________________________
______________________________________________Plaintiff/Appellant/Petitioner/Complainant

FIR. No._________________
Dated:___________________
U/s _____________________
P.S. ____________________
Versus

Defendant/Respondent/Accused
KNOW we all to whom these presents shall come that I/we, the undersigned, appoint
Saeed Hassan Hashmi
Advocate High Court
to be the Advocate for the _____________in the above mentioned case to do all following acts, deeds
and things or any of them, that is to say: -
1. To act, appear and plead in this court or any other court in which the same may be tried or heard in
the first instance or in appeal or review or revision or execution or in any other stage of its progress
until its final decision.
2. To present pleading, appeals, cross objections or Petitions for execution, review, revision, withdrawal,
compromise or other Petitions or affidavits or other documents as shall deemed necessary or
advisable for the prosecution of the said cause at all its stages.
3. To withdraw or compromise the said cause or submit to arbitration any differences or disputes that
shall arise touching or in any manner relating to the said cause.
4. To receive money and grant receipts thereof and to do all other acts and things which may be
necessary to be done for the progress in course of the prosecution of the said case.
5. To employee any other Legal Practitioner authorising him to exercise the power and authorities
hereby conferred on the Advocate whenever he may think fit to do so. AND I hereby agree to ratify
whatever the Advocate or his substitute shall do in the premises,
AND I hereby agree not to hold the Advocate or his substitute responsible for the result of the said
cause in consequence of his absence from the court when the said cause is called up for hearing
AND I hereby agree in the event of the whole or any part of the fee agreed by me to be paid to
Advocate remaining unpaid, he will be entitled to withdraw from the prosecution of the said cause
until the same is paid.
IN WITNESS WHEREOF I/WE hereunto set my/our hands to these presents the contents of which
have been explained to be understood by me this the
________day of ________1999.
Accepted subject to payment of full fee.

Saeed Hassan Hashmi

Advocate High Court __________________________
40-Aziz Block District Courts, Multan. (Signature or thumb impression)
 LIST OF PENDING COURT CASES AS ON 15.09.2000

Sr. Consumer Name & Address of Title of the Date of Stay Amount involved Amount Status Remarks
No. No. the Suit/Appeal/Petition filing of granted/ not recovered
Consumer/plaintiff Suit/ Nature of suit/ Name of court granted Default Pilferage if any
Appeal/ cause of action.
Petition.
1131084572 Muhammad Ali R/o Muhammad Ali Suit for Muhammad. Stay granted 5056 __ Fixed for There
1 Street No. 4, T.B. Vs 30.3.98 Declaration. Naeem Sheikh but vacated. evidence of are bright
Hospital, Multan. S.N.G.P.L. S.N.G.P.L. chances
Gul Sher Muhammad Gul Sher Muhammad Suit for Sadiq Masood Stay granted 148106 Evidence
2 11210028373 R/o Mohallah Sadiq Vs 17.10.98 Declaration. but vacated.
Abad, old Shujabad S.N.G.P.L.
Road, Multan.
Rana Shahid Iqbal S.N.G.P.L. 13.11.99 Recovery Ch. Muhammad Recovery 125824.18 Evidence
City Top Restaurant Vs Siddique suit of
3 11200026826 B.C.G. Chowk Bwp. Rana Shahid Iqbal S.N.G.P.L
Road, Multan. .
4 11240018803 Sh. Asif Data Bakery Sh. Asif Ali 24.9.99 Suit for Rana Stay granted X 10137/- Full Evidence
13-A Nusrat Road, Vs Declaration Muhammad but vacated. alongwith
Multan. S.N.G.P.L. Akram charges
5 11320427524 Sh. Asif Data Bakery Sh. Asif Ali 27.7.99 Suit for Rana Stay granted X Evidence
13-A Nusrat Road, Vs injunction Muhammad but vacated.
Multan. S.N.G.P.L. Akram
6 11210028373 Gul Sher Muhammad S.N.G.P.L. 2.12.99 Recovery Ch. Rasheed Recovery 139105.92 Evidence
R/o Mohallah Sadiq Vs Ahmad suit of
Abad, old Shujabad Gul Sher S.N.G.P.L
Road, Multan.
7 11200028435 Pop Corn Factory, S.N.G.P.L. 15.12.99 Recovery Ch. Rasheed Recovery 25216/- Summons
Yaqoob Town Vs Ahmad suit for
Multan. Muhammad Ashfaq attendance
8 Peer Khursheed Muhammad Iqbal Dec’1999 Suit for Mian M. Riaz Stay granted Report of
Colony, Multan. Vs S.N.G.P.L. declaration Khurram but vacated. Commission
9 11200020099 Chowk Shah Abbas, Irshad Ahmad 25.11.99 Suit for Muhammad Stay granted 62862/- Evidence
Suraj Kund Raod, Vs declaration Naeem Sheikh but vacated. of plaintiff
Multan. S.N.G.P.L.
10 11210028276 Gali No. 2, Mohallah S.N.G.P.L. 24.1.2000 Recovery Sadiq Masood Recovery 11925/- Evidence
Aslam Abad, Masoom Vs suit
Shah Road, Multan. Hafiz Maqsood
11 11200029869 Gali No. 1 Ghaus S.N.G.P.L. 14.3.2000 Recovery Sardar Recovery 630047/- Evidence
Abad, near Central Vs Muhammad suit
Jail, Multan. Ali Sher Babar
12 11200030120 Plot No. 46, Mauza S.N.G.P.L. 14.3.2000 Recovery Sardar Recovery 73208/- Ex-parte
Taraf Daira Vehari, Vs Muhammad suit Evidence
road Multan. Muhammad Tahir Babar
13 11200029126 Muhammad Hashim, S.N.G.P.L. 16.5.2000 Recovery Mian Recovery 23457.53 Correct
R/o Muhammadi Vs Muhammad suit address
Mohallah Multan. Hashim Ali Riaz Khurram
14 14304008088 Muhammad Yousaf, Muhammad Yousaf 4.4.2000 Suit for Taj Muhammad Stay not 4873/- Argument
R/o H.No. 2004, I/s Vs injunction Mirza granted
Daulat Gate, Multan. S.N.G.P.L.
15 11210026407 H. No. 1263, Bagh S.N.G.P.L. 23.5.2000 Recovery Sadiq Masood Recovery 104232/- Summon
Vehra O/s Dehli Vs suit
Gate, Multan. Muhammad Rafiq
16 11240029539 Shop No. 1500/8, S.N.G.P.L. 23.5.2000 Recovery Mahmood Recovery 28146/- Recovery
Lakar Mandi Multan. Vs Haroon Khan suit
Abdul Khaliq
17 11210023011 Fish Corner H. No. 3, Muhammad Nasir 5.4.2000 Suit for Taj Muhammad Stay not 84296/- Arguments
Main Street Masoom Vs declaration Mirza granted
Shah Road, Multan. S.N.G.P.L.
18 11350999948 Muhammad Nawaz Capt. Muhammad May’2000 Suit for Syed Pervaiz Ali 19040/- Arguments
77 A.C. Saddar C-12, Nawaz declaration Shah
Circuit House, Multan. Vs S.N.G.P.L.

19 11210030358 Mohallah Iqbal Sh. Muhammad Jan’2000 Suit for Mian Stay not 116845/- Evidence
Nagar, T.B. Hospital Saleem injunction Muhammad granted
Multan. Vs Riaz Khurram
S.N.G.P.L.
20 11213220026 Arshad Sweet Mart, Arshad Ali 2.6.2000 Suit for Rana .Stay 57994/- Arguments
Opp. Hassnain Oil Vs declaration Muhammad granted
Mills, Central Jail, S.N.G.P.L. Akram
Multan.
21 11320220155 Muahammad Hanif Muhammad Hanif Aug’2000 Appeal Basheer Ahmad Stay not 29110/ Summon-
R/o Gulgasht Colony Vs Bhatti granted. ing of
Multan. S.N.G.P.L. record.
22 11220027263 Farzand Ali R/o Farzand Ali Suit for Muhammad Stay granted 18000/- Arguments
Rewari Sweet Vs permanent Akram Rana (Security)
Chowk S.N.G.P.L. injunction.
Kumharanwala, Mtn.
23 11200030432 R/o Shop behind Dilawar Hussain Suit for Hafiz Stay granted 190854/- Arguments
Yaqboob Town New Vs. declaration Muhammad
central Jail Multan. S.N.G.P.L. Iqbal Kaliyar

SAEED HASSAN HASHMI,

Advocate High Court
Multan.
 TO WHOM IT MAY CONCERN

Dear Sir/Madam,
Rashid Hassan
It is to confirm that the above named was assaulted by Police
in 1983 and he was struck by hand gun on his head. He was
subsequently detained for about 4 weeks. All this happened because
he was campaigning against the Military Regime for restoration of
Civil Liberties and Democracies.
Thanking you,

Sajjad Hussain Khan Malazie,

Advocate High Court,
District Courts, Multan.
To,
The Manager,
Habib Bank Limited,
Gulgasht, Multan.

Subject: - LEGAL OPINION.

Dear Sir,
Mr. Haji Noor Muhammad Khan S/o Haji Muhammad Bakhsh Khan
resident of Al Ata Colony, Street No. 3, Shah Badar Road, Multan, wants a
loan amounting to Rs. 180,000/- from H.B.L. Branch Gulgasht. He has
submitted the following documents for legal opinion: -

1. Copy of Register Haqdaran Zameen of year 1996-97 regarding a land

measuring 0k—6M bearing Khewat No. 1252/1251, Khatooni No.
1654 in Taraf Mubarak in the name as above mentioned.

2. Original sale deed regarding land measuring 0K—6M bearing Khewat

No. 1233 with black ink, 1166 with red ink, Khatooni No. 1681 MIN,
Khasra No. 3393/2924 according to Register Haqdaran Zameen of
year 1988-89, Deed No. 9515/1.

3. Non-encumbrance certificate issued by the Sub-Registrar (Urban)

dated 25.4.2001 regarding the above mentioned property.

4. A Certificate/Sanction letter, issued by the Municipal Corporation,

Multan dated 15.4.2001.
5. Attested copy of Register P.T.1 for the year 2000-2001 issued by the
Excise and Taxation department showing the ownership of above
referred applicant.

6. Approved map of the property dated 15.4.2001.

7. An Evaluation Certificate issued by the approved architect of the bank

i.e. Combine Associates, Multan, with its reference No.
CA.387/A/2001 dated 25.4.2001 showing the valuation of the
property equivalent to Rs. 688,000/-.

8. A quotation given by business Manager of Allied Business Machines

dated 28.4.2001.

On perusal of above papers, apparently the interest of the

bank is fully protected/safe subject to furnishing other
documents i.e. contract (if any), mortgage deed in favour of the
bank, etc. as per existing rules and policy of the bank. The
applicant may avail the loan facility.

Submitted for your kind perusal and further necessary

action.
Yours Sincerely,

SAEED HASSAN HASHMI,

Advocate High Court,
40-Aziz Block, District Courts,
Multan.
(Legal Advisor H.B.L.)
 IN THE COURT OF JUDGE BANKING COURT, MULTAN.

Suit No. _________/2001

House Building Finance Corporation, Head Office 3rd Floor, Finance

and Trade Centre, Shahrah-e-Faisal, Karachi, through its District
Manager, H.B.F.C. District Ofifce, Suleman Plaza, near Chungi
No. 9, Multan.
PLAINTIFF
VERSUS
Malik Farooq Ahmad S/o Malik Fazal Elahi, R/o (i) 53-A Nishtar
College, Multan, (ii) Kotla Waris Shah, Tehsil & District Multan.
RESPONDENT

Suit for recovery of account of original

investment Rs. 225,910/- + on account of
additional investment Rs. 153,776/- total
Rs. 379,686/- upto 30.6.2000 and also
rental share, insurance premium and
demand charges etc. of the H.B.FC. till full
and final payment of recovery of
outstanding balance by sale of
mortgaged/assigned property mentioned
in para No. 3 of the plaint and form the
present and other assets of the defendant.

Sir,
The plaintiff respectfully submits as under: -

1. That plaintiff’s corporation is a statutory body constituted

under House Building Finance Corporation Act, XVIII, 1952
and is a Banking Company as defined in the Banking
Companies (Recovery of Loans, Advances, Credits and
 Finance) Act, 1997, presently having its Head Office at
Karachi and District Offices at other places of Pakistan
including one of its office at Multan. The District Manager,
Multan being its District Manager is authorised to institute the
present suit signed, verify pleadings, to do such acts which are
necessary and incidental thereto being conversant with the
facts of the case and is able to depose about the fate.

2. That the plaintiff provides financial facilities on partnership

basis for the construction and purchase of house/building in
Pakistan in terms of Act XVIII, 1952 and Rules &
Regulations made thereunder.

3. That the defendant availed investment of original Rs.

100,000/- + additional Rs. 50,000/- from the plaintiff to
construct the house of Khasra No. 129, Khewat No. 1 black, 1
red, Khatooni No. 1 to 9, measuring 10 Marlas situated in
Mauza Kotla Waris Shah, Multan, through case file No.
HFFMTN-5726. Account No. original 30600944 and
additional 70601685-84 on the terms and conditions as set out
in Registered Deed of assigned and Partnership (hereinafter
called “Assignment Deed”) executed by the defendant on
14.11.1988 and 15.11.1989 in the office of Sub-Registrar
(Urban), Multan under the provision of H.B.F.C. Act XVIII,
1952 and the Rules and Regulations made thereunder. An
attested copy of Registered Assignment Deeds are filed
herewith and marked as Annexes “A & B”. The assigned
property is bounded as under: -

East: Plot of Imran and others

West: Street 12’ wide
South: Plot of Fatima
North: Street

4. That the defendant had to pay the said investment to the

plaintiff in monthly installments of original Rs. 1103/- +
additional Rs. 824/- per month initially, regularly and terms of
 the said Registered Deed of Assignment and Partnership, but
he did not regularly pay the same inspite of issuance of legal
notices by the plaintiff.

5. That on account of breach of terms and conditions of the said

Registered Assignment Deed, the plaintiff has become entitled
to recall the entire balance of investment including share of
the corporation, insurance premium and demand charges from
the defendant, which comes to original Rs. 225,910/- +
additional Rs. 153,776/- total Rs. 379,686/- as on 30.6.2000.

6. That the defendant has failed to repay the above balance

amount to the plaintiff whereby he has committed breach of
the terms & conditions of the Registered Assignment Deed in
the payment of monthly installments with a share of the
Corporation and Demand charges and as stated above amount
of original Rs. 225,910/- + additional Rs. 153,776/- total sum
of Rs. 379,686/- is due upto 30.6.2000.

7. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on 2.7.2000 when the
period of the notice dated 17.6.2000 expired and the
defendant failed to repay the above said investment and share
of the Corporation of the plaintiff.

8. That the value for the purpose of court fee and jurisdiction is
Rs. 379,686/- and a court fee of Rs. 15,000/- has been affixed
and paid.

It is therefore, respectfully prayed that: -

a) A decree be passed in favour of the plaintiff against the

defendant for the recovery of Rs. 379,686/- along-with
Demand Charges, Insurance premium and rental share
etc. of H.B.F.C. from July 2000 till full and final
recovery by the delivery of vacant possession and sale
of the house/building construction on the aforesaid
property/plot on Khasra No. 129, Khewat No. 1 black,
 1 read, Khatooni No. 1 to 9, measuring 10 Marlas
situated in Mouza Kotla Waris Shah, Tehsil & District
Multan mentioned in the registered Deeds of
Assignment and Partnership, original Deed No. 9850,
Book No. 1, Volume 602, page 183 dated 14.11.1988
and (ii) Deed of Assignment and Partnership No.
10480, Book 1, Volume 707, page 91 dated 15.11.1989,
executed before the Sub-Registrar (Urban) Multan,
which is already assigned with the plaintiff under terms
and conditions of the above-mentioned Deed of
Assignment and partnership.

b) In case the decretal amount is not satisfied by the sale

of mortgaged/assigned property, a decree for the
balance amount may also be passed in favour of the
plaintiff H.B.F.C. against the person and other assets/
properties of the defendant.

c) An injunction restraining the defendant and every body

claiming through from or under him in any manner,
transferring or dispossessing of the same above
mentioned property.

d) Ad-interim attachment of the said property and the plot

mentioned above.

e) Cost of the suit also be awarded.

Any other relief warranted by the facts and

circumstances of the case, may also be granted.

Plaintiff,

Dated: ________
H.B.F.C.
Through: - its District Manager,
Multan.
 Through: -
(Muhammad Qasim Khan),
Advocate High Court,
District Courts, Multan.

VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff
 IN THE COURT OF JUDGE BANKING COURT, MULTAN.

Suit No. _________/2001

House Building Finance Corporation, Head Office 3rd Floor, Finance

and Trade Centre, Shahrah-e-Faisal, Karachi, through its District
Manager, H.B.F.C. District Office, Suleman Plaza, near Chungi
No. 9, Multan.
PLAINTIFF
VERSUS
1. Mst. Tahira Firdous wife of Muhammad Rafique.
2. Muhammad Rafique S/o Muhammad Saddique, caste Qureshi,
R/o near Waheed shopkeeper behind Police Lines No. 1,
Sadiq Colony, Multan, (ii) Plot No. 260-I Shah Rukne Alam
Colony, Multan.
DEFENDANTS

Suit for recovery of Rs. 568,157/- upto

31.8.2001 and also rental share, service
charges, insurance premium and demand
charges etc. of outstanding balance by sale
of mortgaged/assigned property mentioned
in para No. 3 of the plaint and from the
persons and other assets of the defendant.

Respectfully Sheweth: -
1. That plaintiff corporation is a statutory body constituted under
House Building Finance Corporation Act, XVIII, 1952 and is a
Financial Institution as defined in the Financial Institutions
(Recovery of Finances) Ordinance, 2001, presently having its
Head Office at Karachi and District Offices at other places of
Pakistan including one of its office at Multan. The District
 Manager, Multan being its District Manager is authorised to
institute the present suit signed, verify pleadings, to do such acts
which are necessary and incidental thereto being conversant with
the facts of the case and is able to depose about the fate.
2. That the plaintiff provides financial facilities on partnership basis
for the construction and purchase of house/building in Pakistan in
terms of Act XVIII, 1952 and Rules & Regulations made
thereunder.
3. That the defendants availed investment of Rs.347,000/- on
24.6.97 from the plaintiff to construct the house on plot No. 260,
Block I, Shah Rukne Alam Colony, Multan, through case file No.
HFS-MTN-9623, Account No. 70604383-75 on the terms and
conditions as set out in Registered Deed of assigned and
Partnership (hereinafter called “Assignment Deed”) executed by
the defendant No. 1 on 24.6.1997 in the office of Sub-Registrar
(Urban), Multan under the provision of H.B.F.C. Act XVIII, 1952
and the Rules and Regulations made thereunder. An attested copy
of Registered Assignment Deed is filed herewith and marked as
Annex “A”. The assigned property is bounded as under: -
North: Plot No. 259
South: Plot No. 261
East: Plots No. 249, 250, 251
West: Road 25’ wide

4. That the defendant No. 2 stood guarantor for defendant No. 1 and
he executed a Guarantor Form duly signed by him, which is also
annexed with the suit. In this way, he is equally liable to pay
outstanding the amount of H.B.F.C./plaintiff.

5. That the defendants had to pay the said investment to the plaintiff
in monthly installments of Rs. 5,342/- per month initially,
regularly and terms of the said Registered Deed of Assignment
and Partnership, but they paid nothing to discharge their liability
inspite of issuance of legal notices by the plaintiff.

6. That on account of breach of terms and conditions of the said

Registered Assignment Deed, the plaintiff has become entitled to
recall the entire balance of investment including share of the
 corporation, insurance premium, service charges and demand
charges from the defendant, which comes to
Rs. 568,157/- as on 31.8.2001, this amount includes Rs.
165,710/- outstanding rent, Rs. 5,928/- for insurance premium,
Rs. 5,360/- demand charges and Rs. 347,000/- for principal
amount.

7. That the defendants have failed to repay the above balance

amount to the plaintiff whereby they have committed breach of
the terms & conditions of the Registered Assignment Deed in the
payment of monthly installments with a share of the Corporation
and Demand charges; and as stated above, a total of sum of Rs.
568,157/- is due upto 31.8.2001.

8. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on when the
period of the notice dated expired and the
defendant failed to repay the above said investment and share of
the Corporation of the plaintiff.

9. That the value for the purpose of court fee and jurisdiction is Rs.
568,157/- and a court fee of Rs. 15,000/- has been affixed and
paid.

It is therefore, respectfully prayed that: -

a) A decree be passed in favour of the plaintiff against the

defendant for the recovery of Rs. 568,157/- along-with
Demand Charges, Insurance premium, service charges and
rental share etc. of H.B.F.C. from 31.8.2001 till full and
final recovery and by the delivery of sale of house/building
constructed on the aforesaid property/plot No. 260, Block
“I”, Shah Rukne Alam Colony, Multan, measuring 270.28
Sq. Yards mentioned in the registered Deeds of Assignment
and Partnership Deed No. 4993, Book No. 1, Volume 1950,
page 189 to 193, dated 24.6.1997, executed before the Sub-
Registrar (Urban) Multan, which is already assigned with
the plaintiff under terms and conditions of the above-
mentioned Deed of Assignment and partnership.
 b) In case the decretal amount is not satisfied by the sale of
mortgaged/assigned property, a decree for the balance
amount may also be passed in favour of the plaintiff
H.B.F.C. against the person and other assets/ properties of
the defendants.

c) An injunction restraining the defendant and every body

claiming through from or under him in any manner,
transferring or dispossessing of the same above mentioned
property.

d) Ad-interim attachment of the said property and the plot

mentioned above.

e) Cost of the suit also be awarded.

Any other relief warranted by the facts and

circumstances of the case, may also be granted.

Plaintiff,

Dated: ________
H.B.F.C.
Through: - its District Manager,
Multan.

Through: -
(Saeed Hassan Hashmi),
Advocate High Court,
40-Aziz Block,
District Courts, Multan.

VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff