IN THE COURT OF SENIOR CIVIL JUDGE, LAHOR

Suit No. _______/2015

Sana Butt W/o Mehmood Butt R/o Nathoki Post Office Bata
Pur Tehsil Cantt District Lahore.
Plaintiff

Versus

1. Public-at-large.
2. NADRA through its Director General, Provincial Headquarter
Punjab, 14/1 Sarwar Road, Lahore Cantt.
Defendants

SUIT FOR DECLARATION

Respectfully Sheweth:

1. That the names and addresses of the parties have

been correctly provided in the heading of the suit which

are sufficient for the purposes of service of

 summons/notices and other processes to be issued by

this Honorable Court.

2. That the brief facts of the case are that the name of the

plaintiff is Sana Butt which was correctly written in the

birth certificate of plaintiff and as well as on the old

national identity card, issued by concerning authority.

3. That the correct name of the plaintiff which is also

written in the Nikha Nama is Sana Butt. (A copy of birth

certificate, Nikaha Nama and Old CNCIC is attached as

(Annexure-A, B and c).

4. That the name of plaintiff as per NADRA record was

wrongly written as Sania Butt instead of Sana Butt which

is not correct.

5. That the plaintiff approached the defendant No.2 along

with above record with the request to correct her name in

the record of NADRA and issue a new CNIC with

corrected name of the plaintiff but defendant No.2 flatly

refused to accept the genuine request of the plaintiff.

 6. That the cause of action firstly accrued when defendant

No.2 issued CNIC of the plaintiff with incorrect the name

of the plaintiff and secondly a few days ago when plaintiff

approached the officials of the defendant No.2 who

refused to accept the genuine request of the plaintiff.

7. That the plaintiff is residing in Lahore, office of

defendant also present in Lahore and cause of action also

accrued in Lahore, hence this Honble Court has got the

jurisdiction to adjudicate upon the matter.

8. That the value of suit for the purpose of court fee and

jurisdiction is fixed for at Rs. 200/- hence no court fee is

required to be affixed.

PRAYER:

In view of the above, it is most respectfully prayed that:

(i) A declaratory decree may very kindly be passed in

favour of the plaintiff and against the defendants with

corrected the name of the plaintiff as per birth

certificate, old CNIC and Nikha Nama.

(ii) Respondent No.2 may very kindly be ordered to correct

the plaintiffs name in plaintiffs CNIC.

 (iii) Any other relief which this Honble Court may deem fit

and appropriate may also be awarded.

Plaintiff

Through;-

Mudaber Hussain Qureshi

Advocate High Court

Verification:

It is verified on oath at Lahore on this 18th day

of Nov, 2015 that para No. 1 to 4 are correct to the

best of my knowledge and para No. 5 to 7 are

correct to the best of my belief.

Pl

aintiff