IN THE COURT OF SENIOR CIVIL JUDGE, PESHAWAR.

In Re: Civil Suit No. of 2019.

Mrs. Nasreen Kausar and others……………………….... PLAINTIFFS.

Versus
Dr. Ibrahim Ahmad
And two others……………………..…………………….... DEFENDANT.

URGENT APPLICATION under Order 40

Rule 1 of the Code of Civil Procedure, 1908 for
Appointment of Receiver.

Respectfully Sheweth:

1. That the applicants/ plaintiffs have filed the accompanying suit for
Declaration, Possession through partition, Permanent Injunction and
Recovery etc. pertaining to the legacy/ inheritance of their late
predecessor.

2. That plaintiffs/applicants have been at pains to bring to the attention

of this Hon’ble Court the various illegal/criminal acts that
respondents/ defendants particularly defendant No. 1 had, as far as
plaintiffs had become aware, committed until filing of the suit. These
were detailed, as briefly as possible in the plaint, which may
graciously be read with and as a part of this application.

3. That the conduct of respondents/defendants particularly defendant

No. 1 has rendered it unsafe to trust him.

4. That the said defendant No. 1 has forcefully took the control of the
legacy/property left by the late predecessor, evicted the tenants, and
even his elderly mother and unmarried sister/s from the house which
is their only board at Peshawar. He is not allowing access to plaintiffs
and is appropriating all the funds and income of the property
including plaintiffs share to his own use.

5. That the joint properly is extremely valuable/expensive. It is

generating substantial income/profit. The defendant No. 1 is not
willing even to disclose it and is misappropriating the whole.
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In the circumstances, it will be just and convenient, to

appoint a RECEIVER of the property/assets detailed in the plaint,
pending decision of the suit and he may be directed to take into
possession all the property and receive/collect its income and deposit
the same in Court to be disbursed in line with the judgment/decree of
the Court.

Applicants/Plaintiffs
Through

Jehanzeb Khan Muhammadzai

Advocate, Supreme Court.

M. Sardar Khan and Associates

Dated: __. ____.2019 Advocates and Legal Consultants

AFFIDAVIT:

I Mrs. Nasreen Kausar (widow) of late Ahmad Jan, Residents of House

No. 729, Street No. 22, Sector E/6, Phase-VII, Hayatabad Peshawar do
hereby declare and affirm that the contents of the application above are true
and correct to the best of my knowledge and belief.

Deponent