Jectitation of marriage

							                                     1




   BEFORE THE COURT OF SENIOR CIVIL
   JUDGE WITH THE POWERS OF FAMILY
            JUDGE LAHORE.




                  Family Suit No.---------------------/2008

MST. FARHANA SARDAR daughter of Sardar Ali, Caste Pathan,

resident of 91-A-1, Gulberg III, Lahore.

                                                                PLAINTIFF

                                 VERSUS

Shan Muhammad son of Nawaz Jang Caste Pathan,




                                                              DEFENDENTS

            S U I T F O R JACTITATION OF MARRIAGE

Mat It Please This Court,


   1-    That the plaintiff is a resident of above said address and is a

         minor.

   2-    That the plaintiff is student of class ten in Divisional Public

         School, Model Town Lahore. Plaintiff use to go to school with

         his father or brother and in their absence
                                 2




3-   That on 28.04.08 she was present outside her school and

     waiting for her father when defendant along with two unknown

     persons came there on a car and kidnapped her forcibly and

     took her an unknown place. Plaintiff was made unconscious.

4-   That they took the plaintiff there and on 05.05.08 they forcibly

     got the signatures and thumb impressions of the plaintiff on

     some papers. house of the defendant was in a bad condition

     and was not able to live in it. So it was also mentioned at the

     time of agreement that the plaintiff will construct and renovate

     the whole house at his own expenses and when the tenancy

     will over, the whole amount will be paid by the defendant No.1

     to the plaintiff. The copy of rent agreement is attached

     herewith for the kind perusal of this Hon’ble Court.

5-   That the plaintiff is a bonafide tenant and has been fulfilling all

     the requirements of the rent agreement. That the plaintiff also

     spent a huge amount on the renovation and new construction of

     the house. The copy of the bill of the contractor which is paid

     by the plaintiff is also attached herewith this plaint.

6-   That the plaintiff is not a defaulter in the payment of rent till

     now and is also paying the utility bills regularly.
                                 3




7-    That a week ago defendant No.1 along with defendant No.2,

      who is an unknown person for the plaintiff came at the suit

      property and asks the plaintiff to dispossess the house. Plaintiff

      agreed and demanded his money which he had spent at house

      for renovation and construction. The defendant No.1 refused to

      give money to the plaintiff and departed. On the very next day

      the defendant No. 1 and 2 along with some armed persons

      came to the suit property and tried to dispossess the plaintiff

      forcibly. The plaintiff defends himself as a result they departed

      and before departure threatened the plaintiff of dire

      consequences.

8-    That according to the agreement of tenancy, it is clearly

      mentioned in the agreement that either party is liable to issue

      one month notice in advance and the defendant did not issue

      any notice for the vacation of the house.

9-    That the act of the defendants is illegal, unlawful and against

      the cannon of justice.

10-   That a day before yesterday the defendants along with some

      Gunda elements again came to the suit property and tried to

      dispossess the plaintiff illegally, unlawfully and without due

      course of law hence this suit.
                                         4




   11-   That the cause of action arose in favour of the plaintiff and

         against the defendants a week ago when the defendants tried to

         dispossess the plaintiff and the same act was repeated a day

         before yesterday and the same cause of action is still

         continuing.

   12-   That the parties are residing at Lahore and the suit property is

         also situated at Lahore, hence this Hon’ble Court has got

         jurisdiction to try the suit.

   13-   That the value of the suit for the purpose of court fee and

         jurisdiction is Rs. 200/-, which is exempted from court fee.



PRAYER
      In view of the above submissions, it is most respectfully

prayed that the decree for Permanent Injunction may kindly be

passed in favour of the plaintiff and against the defendants

restraining the defendants from interfering and dispossessing the

plaintiff from the suit property illegally and unlawfully and without

the due course of law. Meanwhile, Ad-interim injunctions may kindly

be awarded.

      Any other relief, which this Honourable court may deem fit,

just and appropriate, may also be granted to the plaintiff in the

interest of justice.




                                                            PLAINTIFF

                          Through:
                                 5




                            SIKANDAR ZULQARNAIN SALEEM
                                         Advocate High Court




                                     MUHAMMAD BASIT JAMIL
                                             Advocate High Court
                                       4-A Mozang Road, Lahore.

VERIFICATION:

Verify on oath at Lahore on this 16th day of November 2007 that
the contents of the Para No.1 to 8 are true and correct to the best
of my knowledge and remaining Paras No.9 to 11 are true to the
best of my belie

                                                  PLAINTIFF
                                     6




  IN THE COURT OF MR. ARIF MEHMOOD
       KHAN,CIVIL JUDGE,LAHORE.




Syed Imad-Ud-Din Hassan            Vs.        Daud Ahmad Chauhdary etc.

APPLICATION UNDER ORDER 39 RULES 1 & 2, READ WITH

                   SECTION 151 CPC FOR INTERIM RELIEF.
Respectfully Sheweth:-

   1-    That the petitioner has filed the accompanying suit in this
         Honourable Court for which no date of hearing is fixed so far.
   2-    That the contents of the main suit may kindly be read as an
         integral part of this application.
   3-    That the petitioner has a good prima-facie case and arguable
         case in his favour.
   4-    That if the respondents are not restrained from interfering and
         dispossessing the petitioner from suit property, illegally and
         unlawfully, the petitioner shall suffer an irreparable loss and
         injury.
   5-    That the balance of convenience lies in favour of the
         petitioners.
   It is, therefore most respectfully prayed that the respondents
may kindly be directed to restrain from interfering in the peaceful
possession of the petitioner and also from dispossessing him illegally,
unlawfully and without due course of law. Ad-interim injunctions may
also be awarded till the final disposal of the case.


                                                           PETITIONER

                                 Through:




                                                      Counsel
                                    7




  IN THE COURT OF MR. ARIF MEHMOOD
       KHAN,CIVIL JUDGE,LAHORE.




Syed Imad-Ud-Din Hassan           Vs.    Daud Ahmad Chauhdary etc.

APPLICATION UNDER ORDER 39 RULES 1 & 2, READ WITH

                   SECTION 151 CPC FOR INTERIM RELIEF.
AFFIDAVIT          of Syed Imad-Ud-Din Hassan son of Sued Shabbir
                   Hussain resident of House No. 9-B, Shalimar Link
                   Road Mughalpura, Tehsil Lahore Cantt. District
                   Lahore.

   I, the above name deponent do hereby solemnly declare and affirm as

under:-

   1-     That the petitioner has filed the accompanying suit in this
          Honourable Court for which no date of hearing is fixed so far.
   2-     That the contents of the main suit may kindly be read as an
          integral part of this application.
   3-     That the petitioner has a good prima-facie case and arguable
          case in his favour.
   4-     That if the respondents are not restrained from interfering and
          dispossessing the petitioner from suit property, illegally and
          unlawfully, the petitioner shall suffer an irreparable loss and
          injury.
   5-     That the balance of convenience lies in favour of the
          petitioners.



                                                           DEPONENT
VERIFICATION:-
                   Verified, on oath at Lahore on this 15th day of
                   November 2007 that the contents of the above
                   affidavit are true and correct to the best of
                   knowledge and belief and nothing has been
                   concealed.



                                                           DEPONENT

                   concealed.


                                                           DEPONENT