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Adam A. Muchhadda
Son of Abdul Karim Muchhada
Muslim, adult, Resident of
199, Bock-B, Adam Jee Nagar,
Khatiawar Cooperative Housing Society,
Tipu Sultan Road,
Karachi ………………………..……………………………… Plaintiff
VERSUS
Captain (R) H.A. Rahim
Son of Kaka Muhammad
Muslim, adult, resident of
15-A, Dada Bhay Town,
shaheed-e-Millat Road, Extension,
Karachi ……..…………….…………………………….. Defendant
4. That in spite of the facts, the Defendant purposely and willfully failed
to receive the reply of his notice, send by the Chairman, he on 04-11-
2018 in Daily Millat Gujrati Karachi published a defamatory notice /
pronouncement with the sole purpose to impute and defame the
plaintiff. The allegations made by the plaintiff against the Defendant
in publication dated 04-11-2018 are completely false, incorrect as for
the allegations, the Defendant has no proof. (Copy of pronouncement
Daily Millat Gujrati and its true translations are enclosed and
marked as annexure C & D).
mental pain, agony and torture amongst his friends and relatives
because of the letter written by him to the Chairman and public notice
in Daily Millat Gujrati. The plaintiff has also suffered loss in business
activities and in performance of his lawful obligations in the Society
as well.
6. That the plaintiff due to false allegations of the Defendant made in the
letter dated 14-09-2018, written to the Chairman of the Society and
public notice dated 04-11-2018, published in Daily Millat Gujrati
Karachi send a legal notice by TCS, UMS and registered post but
letter sent through UMS & TCS were returned in the endorsement to
refuse to receive by the Defendant but the notice sent through
Registered post have not been returned so far, so therefore, there is
lawful presumption that the same has been delivered to the Defendant.
(Photostat copy of legal notice dated 13-11-2018, envelops returned
by TCS and UMS and postal receipts are enclosed and marked as
annexure E, F, G & H).
9. That the cause of action accrued to the plaintiff against the Defendant
firstly on 14-09-2018, when he made unlawful demand with false
Page # 11
allegations from the Chairman of the Society, on 04-11-2018, when he
published a contemptuous statement / pronouncement in Daily Millat
Gujrati Karachi and further on 13-11-2018, when legal notice given
to him and the same remain to continue day to day till the filing of this
suit within the local limits of Police Station, District Karachi East, as
the cause of action accrued therein. The plaintiff and Defendant both
are resident of Karachi city, which is within the jurisdiction of this
Honorable Court.
11. That for the purpose of Court-fee and jurisdiction the suit is valued at
Rupees fifty millions and maximum Court-fee of Rs. 15,000/- has been
affixed.
P R A Y E R
The plaintiff, therefore, prays for judgment and decree in his favor and
against the Defendant as under;-
a). To direct the Defendant to pay Rupees Fifty Millions or any other
amount, which this Honorable Court may deem fit and proper under
the circumstances of this suit, to the plaintiff .as damages.
b). Compensatory Cost of the suit under Section 35.A of the Civil
Procedure Code.
c). Any other equitable relief(s) which this Honorable Court deems fit and
proper under the circumstances of this suit.
Karachi.
Dated:- 25.05.2018. Plaintiff
V E R I F I C A T I O N.
Deponent
CNIC No. 42201-4127361-9
Cell No. 0321-2017788
VERSUS
Captain (R) H.A. Rahim ….…………………………….. Defendant
ADDRESS OF PLAINTIFF
FOR SERVICE
VERSUS
Captain (R) H.A. Rahim ….…………………………….. Defendant
VERSUS
Captain (R) H.A. Rahim ….…………………………….. Defendant
All legal heirs are residing with the plaintiff at House. # 199, Adam
Jee Nagar, Block B, Tipu Sultan Road, Karachi.
In the event of death of the plaintiff Legal Heir #. 4 shall intimate this
fact to the Honorable Court.
VERSUS
Captain (R) H.A. Rahim ….…………………………….. Defendant
LIST OF DOCUMENTS
To be prepared later with consideration of Tanveer