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Plaintiff
V/S
1. The Federation of Pakistan,
Ministry of Communications,
Ports and shipping,
Through their Secretary,
Government of Pakistan,
Islamabad.
2. Karachi Port Trust,
Through their Chairman,
KPT House,
Karachi.
3. The Manager,
Anti-Encroachment Department,
Karachi Port Trust,
KPT House,
Karachi.
4. Hazrat Shah,
Proprietor of
ARA Machine,
Situated at Plot No. D-8,
KPT Boat Building Yard,
Fish Harbour,
West Wharf Road,
Karachi.
Defendants
10. That the act of filling the Sea BED and converting the same
into dry land by the defendants is damaging the existence and
growth of the jungle of TIMOR plants which is most essential
and useful for the environment and Sea World.
11. That the defendants have discriminated against and
deprivedthe plaintiff of his lawful rights by allotting and
regularizing the space of 30 feet wide Road under use and
occupation of the plaintiff. The defendants are also blocking,
closing the entry and approach Route Space to Plot No. A-35
owned and occupied by the Plaintiff to his Barges by filling the
ocean Area by Debris and converting the sea belt into dry land
in connivance with each other.
Photographs of filling the Sea Belt are produced as Annex D to D-9
17. That the plaintiff has prepared a layout plan/ map of KPT
plots at Boat building yard West Wharf Road, Karachi detailing
the situation of illegal residential area, sea water Area and the
position of plaintiff and the defendant No.4
A photo Copy of this Map is produced as Annex F
23.
24.
the plaint.
PRAYER :
In View of all the submissions made above, this
Honble Court may be pleased to pass a Judgment and decree as
under:-
A.
above newly created Plot No. D-8/II KPT Boat Building Yard,
Fish Harbour, Karachi, in favour of Defendant No.4 is illegal,
unlawful and liable to be cancelled.
C.
F.
Karachi;
Dated:
PLAINTIFF
Through Attorney.
ADVOCATE
FOR THE PLAINTIFF
VERIFICATION
I, Abid Hussain S/o . Muhammad Janah,
Attorney of the Plaintiff, do hereby state, declare, verify and
affirm on oath that whatever has been stated above in the plaint
is true and correct to the best of my knowledge and belief.
Annex A to F
Address of Plaintiff:
As given in TITLE.
ADVOCATEcell.0300-2338392
0345-2806794