IN THE HIGH COURT OF SINDH AT KARACHI

Civil Suit No. 220/12

Irfan Ahmed Prop. Lillah Autos. ...Plaintiff
v/s
Federation of Pakistan & Ors. ..Defendants.
COUNTER AFFIDAVIT
I, Lt. Shahid Waqar Anwar S/o Muslim, Adult,
working in Pakistan Navy, R/o Karachi, do hereby state on oath
as under:-

1.

That I am the Authorised Officer in this matter and hence fully

conversant with facts of this case.

2.

That I have studied the contents of Application U/S 151

CPC for Direction to Defendants for release of admitted payment

of 22 Delivered items out of 50 claimed items along with the
supporting affidavit. I hereby deny all the allegations made therein
except for those specifically admitted by me hereinafter.
3.

That this is not a proper application. The plaintiff is required

to move an application under correct provision of Law.

4.

That this Application amounts to admission that the suit of the

plaintiff is frivolous and false. The claim of delivery of 50 items to

the defendants is falsified. This demand implies that rest of
contents of the plaint are not correct and the plaintiff is prepared
for the suit to be decided finally without adducing any evidence by
the parties.
5.

That the plaintiff has to prove by Documentary and oral

evidence that spares and services of the value of Rs. 60,52,790/-

were delivered to the Defendants. The list produced with this

Application is not a cogent, Plausible and strong piece of evidence.
6.

That the contents of Para 2 of the application are

emphatically denied to the extent that the plaintiff was ever

abducted and tortured by the defendants at any time. However, a
frivolous, false and concocted Suit No.1698/2010 for Recovery of
imaginary damages for torts and restitution of chattels is pending
adjudication in this Honble Court. No harassment has been or is
being caused to family of the plaintiff. All these are wild
allegations without any substance.
7.

That with regard to contents of Para3 of this Application, it is

submitted that no legitimate payment of the Plaintiff was ever

stopped. The unfair business tactics and activities might have
caused any difficulties to the Plaintiff being a natural
PHANOMENA. The Defendant cannot be held responsible for any
business Losses. The Income Tax Return are not any proof in this
regard which normally are manipulated.
8.

That as far as contents of Para 4 are concerned, there is no

admission of any liability. The Suit No.1698/2010 is a separate

attempt on part of the Plaintiff to hoodwink the Defendants and
make unlawful gains by illegal, unlawful and unjustified demands.
No pressure or coercion has ever been exercised by the Defendants
in respect of the Plaintiff.
9.

That the contents of Para 5 are patently false, frivolous,

concocted and untrue. As such, the same are strongly denied.

Nature of both the Suits is frivolous and false which are liable to
be dismissed.

10. That the contents of Para 6 are misconceived and false. Hence,
strongly denied. The instant application is liable to be dismissed.
11.That contents of Paras 1,2 and 3 of the affidavit are formal
which need no reply.
12.That whatever has been stated above is true and correct to the
best of my knowledge and belief.

Karachi;
Dated: .03.2014

Deponent

The Deponent is identified by me.

Advocate
Affirmed on oath before me at Karachi on this ______
day of January 2014, by the Deponent identified to me by Mr.
Adil Hayat Sandhu, Advocate, who is personally known to me.
COMMISSIONER FOR TAKING AFFIDAVIT