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IN THE COURT OF CIVIL JUDGE SB.

SAMBRIAL

Ch. Sameer Sarwar Ghumman S/O Ch. Muhammad Sarwar Ghumman Caste Jatt Ghumman R/O
Majra Kalan Tehsil Sambrial District Sialkot (Plaintiff)

versus
1. Field Office Majra Kalan Tehsil Sambrial District Sialkot (Present)
2. Field Office Habib Pur Tehsil Sambrial District Sialkot (Former) (Defendants)

SUIT FOR DECLARATION:-

Respectfully sheweth as under;

1. That, the correct name of the plaintiff is Ch. Sameer Sarwar Ghumman and D.O.B is 29-
10-1982 as per CNIC bearing No. 34601-0766672-9.
2. That, the parents of the plaintiff got registered the date of birth of plaintiff in former union
council Habib Pur but inadvertently date of birth could not be registered in the concerned
record i-e Field Office Habib Pur Tehsil Sambrial District Sialkot.
3. That, the plaintiff is a resident of Pakistan and it was obligatory upon the defendant no. 2
to record the same in their record but the defendant no. 2 omitted to do the same.
4. That, now as the union council of the plaintiff got changed and present union council is
Field Office Majra Kalan and it is incumbent upon defendant no. 1 to register the date of
birth in their record; it was time and again said to the field office through secretary to
register the date of birth in their record but the defendant no 1is reluctant to do the same.
5. That, accrual of the suit, came in existence one week before on flat refusal of the defendant
no. 1.
6. That, the residence of the parties and cause of action accrued in Tehsil Sambrial that’s why
your Respected Court have jurisdiction to try the same.
7. That, the court fee PKR 1000 is fixed as per value of the suit.

PRAYER:

In view of the averments made in the suit; it is requested to pass declaratory decree
as per facts mentioned in Para No. 1 and 2 of the plaint in hand while ordering the defendant no. 1
to register the date of birth 29-10-1982 of the plaintiff in concerned record of field office along
with any other consequential relief be awarded which may be within the four corners of law.

APPLICANT:

Ch. Sameer Sarwar Ghumman S/O Ch. Muhammad Sarwar Ghumman Caste Jatt Ghumman R/O
Majra Kalan Tehsil Sambrial District Sialkot

THROUGH:

Fazeel Ahmad Ghumman Advocate

Office No. 10 Civil and Sessions Courts Sambrial

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