IN THE COURT OF DISTRICT JUDGE, MULTAN.

Malik Javed Mukhtar S/o Malik Allah Yar, caste Jat Bosan, R/o H.
No. 888/53, Usman Abad Colony, Multan.
Appellant
VERSUS
Malik Javed Iqbal S/o Malik Allah Yar, caste Jat Bosan, R/o Basti
Bosan Utar, Tehsil & District Multan.
Defendant

Appeal u/s 96 C.P.C. against the Judgment

& Decree dated 30.9.2000 passed by Mr.
Mahmood Haroon Khan, Civil Judge,
Multan whereby he dismissed the suit filed
by the plaintiff.
CLAIM IN APPEAL: -
To accept the appeal and by setting aside
the impugned judgment & decree, to
decree plaintiff’s suit.

Value of appeal __ __ Rs. 200/-

Respectfully Sheweth: -
1. That brief facts which brought the parties to this litigation are
that plaintiff is the owner of house No. 888/53 situated at
Usman Abad Colony Multan to the extent of 7/24 share being
legal heirs of Allah Yar deceased father of the plaintiff and
defendant who are real sons of the deceased. Another son
Malik Fida Hussain and widow Mst. Fazla Mai are also legal
heirs of the deceased. Deceased Haji Allah Yar divided the
property in disputed during his life time and plaintiff raised
construction to the extent of his share over property in dispute
and started to live in. But later on at the time of division of
deceased’s remaining property, confliction arose between the
parties and they came to litigation. Few days prior of this suit
plaintiff came to know that defendant has got executed a
fictitious sale deed in his favour regarding the property in
dispute and wants to dispossess the plaintiff from his share,
while neither any sale deed was executed nor any part of
property was transferred to any legal heir by the plaintiff
because deceased was a religious man and had intention to
distribute his assets among his legal heirs according to
Shariat. But defendant being educated and clever person got
executed the impugned sale deed hence, this suit.
Defendant contested the suit by saying that his step
mother became seriously ill and crops of cotton were
destroyed due to virus in the year 1977-78, due to which his
deceased father was in need of money therefore, he sold out
the property in dispute to the defendant. Defendant was
employed in a bank since 1975 therefore, he was in a position
to purchase the property in dispute. In this way he became the
owner of property in dispute through a registered sale deed
during the life time of his father and property in dispute is not
asset of deceased hence, plaintiff cannot inherit the property in
dispute.
Out of pleading of the parties following issues were
framed: -
ISSUES: -
1. Whether the plaintiff has no cause of action? OPD.
2. Whether the suit is time barred? OPD.
3. Whether the description of the suit property is not
accurately been given in the plaint? OPD.
4. Whether the value of the suit property for the purpose
of court fee and jurisdiction has not been properly
determined? OPD.
5. Whether the suit is false and vexatious and the
defendant is entitled to recover special cost? OPD.
6. Whether the plaintiff is owner in possession of 7/8
share in the property in dispute? OPD.
7. Whether the sale deed No. 7799 dated 21.5.78 was
executed by Malik Allah Yar Khan in favour of the
defendant lawfully and after receiving the
consideration? OPD.
7-A. If issue No. 7 above is not proved then whether this
document is based on fraud and mis-representation,
 without consideration and thus liable to be set aside?
OPD.
Plaintiff produced Ghulam Hussain PW. 1 who
partitioned the property in dispute among the legal
heirs of the deceased in the life time of the deceased.
PW. 2 is Sheikh Feroz-ud-Din who prepared the site
plan. PW.3 is Ghulam Qadir who constructed the
property in dispute and PW. 4 is the plaintiff himself.
Ex.P.1 is the site plan of property in dispute, Ex.P.2 is
the telephone bill, Ex.P.3 is the bill of sui gas, Ex.P.4 is
the property tax form & Ex.P.5 is the copy of impugned
sale deed.
Defendant produced Habib Ahmad Khan Record
Keeper as DW.1, DW.2 Haji Ghulam Sarwar executant
of sale deed, DW.3 Muhammad Yousaf marginal
witness of sale deed, DW.4 is Rab Nawaz. DW. 5 is the
defendant himself. Ex.D.1 is copy of the impugned sale
deed and Ex.D.2 is the copy of PT.1 form.
2. Issues No. 1 to 5 were found against the defendant, issue No.
7, 7-A & 8 were found against the plaintiff and on the basis of
findings on these issues, plaintiff’s suit was dismissed vide
impugned judgment and decree.
3. That the impugned judgment and decree is legally not
maintainable and is liable to be set aside and reversed inter
alia on the following: -
GROUNDS
(i) That while giving findings on issues No. 7, 7-A & 8, the
learned Trial Court acted unreasonably and capriciously
in ignoring entire evidence procedure by the plaintiff-
appellant and giving undue weight to defendant’s
untrustworthy evidence and as such adopted unjudicial
approach ignoring facts and law. Findings on these
issues are therefore erroneous and legally not
maintainable and are liable to be set aside and reversed.
(ii) That the learned Trial Court erred in law firstly to allow
the defendant to produce Secondary Evidence of the
 disputed Sale Deed, without proof of loss of the original
and thereafter allowing the plaintiff to produce the
original without placing the same on the record of the
case. Especially where the production of the original
was refused by the learned Trial Court and on Revision
by the learned Additional District Judge, Multan. The
production of the original disputed Sale Deed and that
too without retaining it on the record of the file is
illegal amounting to depriving the plaintiff of his
valuable right of rebuttal. Defendant’s evidence to that
extent cannot be read in evidence.
(iii) That finding on issue No. 4 regarding valuation of suit
for the purpose of C.F. is misconceived and illegal.
(iv) That the impugned judgment & decree is against law
and facts of the case and is liable to be set aside and
reversed.
(v) That at the time of argument, Zafar Iqbal Khan
Advocate counsel for the plaintiff referred to as many
as 23 authorities, and delivered photo-copies with
index, but the learned Trial Judge did neither perused
nor referred to these authorities in the impugned
judgment.
Wherefore, it is respectfully prayed that appeal
be accepted and by setting aside the impugned
judgment & decree, plaintiff’s suit be decreed with
costs throughout.
Appellant,

Dated: _____________
(Malik Javaid Mukhtar)

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts, Multan.
C.C. No. 2216.
IN THE COURT OF DISTRICT JUDGE, MULTAN.
 Malik Javed Mukhtar Vs. Malik Javed Iqbal

CIVIL APPEAL

STAY APPLICATION

Respectfully Sheweth: -
1. That the above captioned appeal has been filed in this Hon’ble
Court.
2. That admittedly plaintiff is in possession of the disputed
property as legal heir of his deceased father, the original
owner.
3. That as per grounds of appeal, there is every chance of its
success.
4. That defendant, on the strength of the impugned judgment &
decree is bent upon to dispossess the petitioner/appellant form
the property in dispute. In case of petitioner’s dispossession,
he will suffer irreparable loss. Loss of possession has always
been considered by the higher courts as irreparable loss.
5. That balance of convenience also tilts in favour of the
petitioner.
Wherefore, it is respectfully prayed that Status
Quo in respect of plaintiff’s ownership & possessory
rights of property in dispute be ordered to be
maintained. Affidavit attached.
Petitioner,
Dated: _____________
(Malik Javaid Mukhtar)

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts, Multan.
C.C. No. 2216.
IN THE COURT OF DISTRICT JUDGE, MULTAN.
 Malik Javed Mukhtar Vs. Malik Javed Iqbal

CIVIL APPEAL

STAY APPLICATION

AFFIDAVIT of: -
Malik Javed Mukhtar S/o Malik Allah Yar, caste Jat
Bosan, R/o H. No. 888/53, Usman Abad Colony,
Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above application are true and correct to the
best of my knowledge and belief and nothing has
been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of October 2000 that the contents of this affidavit
are true & correct to the best of my knowledge
and belief.

DEPONENT

IN THE COURT OF JUDGE BANKING COURT,

MULTAN.
Mulazim Hussain S/o Haji Ghulam Husain, caste Thaheem, R/o
Mauza Nai Wala, Tehsil & District Multan.
Plaintiff
Versus
1. Manager, Agricultural Development Bank of Pakistan, Branch
Abdali Road Nawan Shehar, Multan.
2. Mobile Credit Officer, Agricultural Development Bank of
Pakistan, Branch Abdali Road Nawan Shehar, Multan.
3. Tehsildar/Recovery Officer, Agricultural Development Bank
of Pakistan, Branch Abdali Road Nawan Shehar, Multan.
Defendants

SUIT FOR MANDATORY INJUNCTION

directing the respondents to act in accordance
with the Concessional Scheme introduced by
the Government regarding concession of
interest on the principal amount of loan and
for Permanent Injunction restraining the
defendants from adopting coercive
measures/arrest against the plaintiff for the
recovery of amount which is not legally due or
in the alternative Suit for Rendition of
Accounts.

Respectfully Sheweth: -
1. That names and addresses of the parties have correctly been
given in the heading of the plaint for the effective service of
summons.

2. That the plaintiff is an agriculturist. He applied for loan from

respondent Bank fro the purchase of Tractor, seed and
fertilizers.
3. That the plaintiff’s application was accepted by the
respondents and a loan of about Rs. 410,000/- was sanctioned
on 14.07.97 in favour of the plaintiff for the purchase of
Tractor, seed and fertilizers. (The correct figure of the loan
amount will be given by the respondent Bank).

4. That for the security of loan, the plaintiff mortgaged his

agricultural land with the respondent Bank.

5. That it may be mentioned here that the Tractor was purchased

with the loan amount and also the plaintiff contributed Rs.
70,000/- from his own pocket. The Tractor was registered in
the name of the respondent Bank, but the actual possession of
the Tractor was handed over to the plaintiff.

6. That repayment of loan was to be made in eight years in six

monthly installments of Rs. 30,000/- each by the end of June
and by the end of December every year. However, a
concession of complete first year was given to the plaintiff,
whereafter, the installments were to begin.

7. That the plaintiff paid installments rather before the dates it

was due and also much more amount than the due
installments. The detail of paid installments is given as below:
Installments paid Date of Payment Amount paid
Ist Installment 30.3.1998 Rs. 10,000/-
IInd Installment 20.7.1998 Rs. 84,300/-
IIIrd Installemtn 30.12.1998 Rs. 85,137/-
IVth Installment 31.12.1998 Rs. 2,870/-
Total amount Rs,
182,307/-
Photo-state copies of receipts are attached as Annexes “A to A/3”.

8. That as per conditions of the loan, the plaintiff was to pay six
monthly installments of Rs. 30,000/- each from June 1998 to
June 2000 which comes to Rs. 150,000/- and as such in view
of the above paid amount, the plaintiff has already paid Rs.
32,307/- more than the installments due.
9. That defendant No. 2 is a greedy person who is in the habit of
threatening the loanees with arrest for no fault on their part
and then, used to ask for illegal gratification.

10. That in view of his such uncalled for conduct, the plaintiff in
the month of March 2000, filed a writ petition against him,
wherein, vide order dated 2.3.2000 his lordship Mr. Justice
Bashir A. Mujahid directed the bank officials to act strictly in
accordance with law after determination of the accounts.

11. That inspite of the above directions of the Hon’ble High

Court, respondent No. 2 along-with respondent No. 3 and
police including lady police, a week ago, raided the plaintiff’s
residence at Mauza Nai Wala to arrest him. Lady police
entered the house and started searching every nook and corner
of the house and other members of the raiding party climbed
over the four-walls of the house and as such violated Parda of
the plaintiff’s ladies. Plaintiff was not present in the house. A
professor giving tuition to plaintiff’s children was caught hold
up and brought outside the house, where he showed his
identity and said that he has nothing to do with the loan, he is
just a third person. He was then released.

12. That the plaintiff’s valuable land which is much more than
sufficient to cover the loan amount is already mortgaged with
the respondent Bank as security of loan. The Tractor
purchased partly with the loan amount is also registered with
the name of respondent Bank. The plaintiff had been vigilant
in repayment of loan rather much more than it was due. In the
circumstances, it is cruel on the part of defendants to take
coercive measures and extreme steps for recovery of
outstanding amount by arresting and detaining the plaintiff in
jail. Such threatening steps of the defendants for the recovery
of undue installments are without lawful authority and against
the law laid down in 1995 MLD 12.

13. That the plaintiff requested the defendants not to take any
coercive measures and not to harass the plaintiff and his other
 family members by threatenening to arrest and put him in jail
but they are adamant to do so.

14. That cause of action arose to the plaintiff a week ago when
the defendants along-with police raided the plaintiff’s house
for his arrest.

15. That loan amount was raised from the defendant’s Multan
branch, hence, this Hon’ble Court has jurisdiction to entertain
and decide the suit.

16. That valuation of suit for the purpose of court fee and
jurisdiction to the extent of first relief of injunction is fixed at
Rs. 200/- and a court fee of Rs. 10/- is fixed for second relief
of rendition of accounts.
Wherefore, it is respectfully prayed that a decree
for mandatory injunction directing the defendants to act
in accordance with their own concessional scheme and
for permanent injunction restraining the defendants
from harassing the plaintiff for the recovery of any
installment, which is not due, in the alternative, decree
for rendition of accounts be passed in favour of the
plaintiff and against the defendants. Cost of suit may
also be awarded.
Any other relief, which the Hon’ble Court deems
fit, may also be awarded.
Humble Plaintiff
Date: _____________

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts, Multan.
C.C. No. 2216.

IN THE COURT OF JUDGE BANKING COURT,

MULTAN.
 Riaz Hussain Vs. A.D.B.P. and others

Suit for Mandatory Injunction.

STAY APPLICATION

Respectfully Sheweth: -
1. That the above captioned suit has been filed before this
Hon’ble Court.

2. That the plaintiff has availed the loan facility for agricultural
purposes from the defendant Bank in the year 1997 and same
was to be repaid in six monthly installments of Rs. 28,000/-
each within a period of eight years.

3. That the installments already paid by the petitioner come to

Rs. 568,100/- while he was bound to pay only Rs. 112,000/-
by the month of June 2000 and as such an amount of Rs.
456,100/- has already been overpaid.

4. That defendant No. 2, out of ill-will and grudge, is all the time
out to arrest the petitioner for the recovery of undue amount
and his such act is illegal and uncalled for.

5. That the Hon’ble High Court, in a writ petition filed by the

plaintiff against the defendants had directed the defendants to
strictly act in accordance with law after determining the loan
account but the defendant No. 2 does not feel bound by the
order and a week ago he along-with police had raided the
plaintiff’s house to effect his arrest but as the petitioner was
not present at home, the defendant No. 2 failed in his
malicious designs.
6. That the entire land of the plaintiff valuing more than the full
amount of the loan is mortgaged with the Bank. The Tractor
purchased is also registered in the name of defendant Bank
and the plaintiff had been vigilant to pay the amount of
installments more than it was due and in the circumstances,
the defendant No. 2’s such coercive action against the plaintiff
is illegal and uncalled for and against the law laid down by
the Hon’ble High Court 1995 MLD 12.

7. That defendant No. 2 is out to arrest the petitioner and in case

he succeeds in his malicious act, the plaintiff shall suffer an
irreparable loss.

8. That in view of the over-payment made by the plaintiff, the

suit of the plaintiff is likely to succeed. Balance of
convenience also tilts in favour of the plaintiff.

Wherefore, it is respectfully prayed that the

defendants/respondents be restrained from effecting
arrest of the plaintiff/petitioner illegally directing them
also to act strictly in accordance with law.
Affidavit attached.
Humble Applicant,
Dated: _________
(Riaz Hussain)

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts, Multan.
C.C. No. 2216.

IN THE COURT OF JUDGE BANKING COURT,

MULTAN.
 Riaz Hussain Vs. A.D.B.P. and others

Suit for Mandatory Injunction.

STAY APPLICATION

AFFIDAVIT of: -
Riaz Hussain S/o Haji Ghulam Husain, caste Thaheem,
R/o Mauza Nai Wala, Tehsil & District Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above application are true and correct to the
best of my knowledge and belief and nothing has
been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of November 2000 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief.

DEPONENT

IN THE COURT OF SARDAR MUHAMMAD BABAR,

CIVIL JUDGE IST CLASS, MULTAN.
Sheikh Umar Ali S/o Muhammad Abdullah, caste Sheikh, R/o
House No. 72, Hassan parwana Colony, Multan.
Plaintiff
VERSUS
1. Ch. Rehmat Ali S/o Acchey Khan, caste Rajput, R/o 38/40, Block
“Y” Satellite Town, Bahawalpur (deceased) through heirs: -
1-A Muhammad Aslam
1-B Muhammad Saleem
1-C Muhammad Iqbal Ch. Rehmat Ali,
1-D Hamid Saeed Sons caste Rajput, R/o 38/40
1-E Mehmood Saeed Block “Y” Satellite
1-F Sarfraz Ali Town, Bahawalpur.
1-G Javed Ali Zahid
1-H Mst. Kishwar Sultana Akhtar
(daughter)
2. Muhammad Aslam S/o Ch. Rehmat Ali (deceased), caste Rajput,
R/o 38/40, Block “Y” Satellite Town, Bahawalpur.
3. Hussain Bakhsh (deceased), through: -
3-A Allah Ditta S/o Hussain Bakhsh (deceased), caste Jat Sumra,
R/o Mouza Muzaffar Abad, Tehsil & District Multan.
3-B Nasir Iqbal (deceased) through: -
3-B/I Mst. Razia Bibi (widow)
3-B/II Zaffar Iqbal
3-B/III Mazhar Iqbal Sons
3-B/IV Jaffer Hussain (minors) Nasir Iqbal
(deceased)
3-B/V Mst. Aasma Bibi through Mst. Razia Bibi
3-B/VI Mst. Fatma Bibi daughters guardian ad-litem, real
3-B/VII Mst. Aasia Bibi (minors) mother of minors
3-B/VIII Mst. Nadia Bibi (defendant No. 3-B/I)

3-C Nasir Iqbal Sons of Hussain Bakhsh (deceased)

3-D Ghulam Shabbir (minors) through Allah Ditta real brother
3-E Ghulam Haider guardian ad-litem of minors, caste Jat
Sumra, R/o Mouza Muzaffar Abad, Tehsil
& District Multan.
3-F Mst. Shamshad Bibi Daughters of Hussain Bakhsh
3-G Mst. Hajran Bibi (deceased), caste Jat Sumra, R/o
(deceased) through: - Mouza Muzaffar Abad, Tehsil &
District Multan.
3-G/I Khadim Hussain husband Mst Hajran Bibi (deceased)
3-G/II Mst. Allah Rakkhi minor daughters of Mst. Hajran Bibi
3-G/III Mst. Parween (deceased), caste Jat Sumra,
through
3-G/IV Mst. Chand Bibi guardian ad-litem Khadim Hussain
3-G/V Mst. Tahira Bibi real father of the minors, R/o
3-G/VI Mst. Sumera Bibi Mouza Muzaffar Abad, Tehsil &
District Multan. (3-G/I)
3-H Mst. Irhsad Bibi daughters Hussain Bakhsh (deceased),
3-I Mst. Shamim Bibi caste Jat Sumra, R/o Mouza
3-J Mst. Karam Bibi widows Muzaffar Abad, Tehsil &
3-K Mst. Bakhsh Ilahi District Multan.
4. Hassan Bakhsh
5. Ahmad Bakhsh Sons of Fateh Muhammad, caste
6. Wahid Bakhsh Jat Sumra, R/o Mouza Muzaffar
7. Aashiq Hussain Abad, Tehsil & District Multan.
8. Muhammad Bakhsh
9. Allah Wasaya S/o Raheem Bakhsh, caste Parhiyar, R/o Mouza
Hamid Pur Kanora, Tehsil & District Multan.
10.Sher Muhammad (deceased) through: -
10-A Mst. Shamim Akhtar widow Sher Muhammad (deceased)
10-B Mujahid Hussain son (minor) caste Parhiyar, R/o Mouza
10-C Mst. Farhat Bibi daughters Hamid Pur Kanora, Tehsil &
10-D Mst. Shaista Bibi (minors) Multan.
10-E Zahid Hussain Minor sons and daughters
10-F Shoaib Hussain Sons through guardian ad-litem
10-G Zohaib Hussain (minors)
Mst. Shamim Akhtar
real mother of minors (10-A)
11.Falak Sher S/o Raheem Bakhsh, caste Parhiyar, R/o Mouza
Hamid Pur Kanora, Tehsil & District Multan.
Respondents

AMENDED PLAINT
 Plaint for Specific Relief.
Application for Restoration of Suit.

Respectfully Sheweth: -
1. That the above-mentioned case was fixed for 20.12.2000 for
rebuttal evidence of the plaintiff.

2. That on the said date, four witnesses were present in the court to
get their evidence in rebuttal but recorded the learned counsels
for the defendants were not prepared to cross-examine them.
Only one witness was cross-examined and the remaining three
were sent back after obtaining signatures on the file as mark of
their presence in court.

3. That two applications, one for permission to produce secondary

evidence and the second under article 32, 3 C.P.C. was also
pending adjudication and the learned counsels for the defendants
were also not prepared to argue only 3 days were left to complete
the hearing of the old cases, the learned counsel for the
defendants offered to adjourn the case Cina die and after the
target date is over, he would not raise any objection for the
restoration of suit, so adjourned Cina die and signed his
statement recorded by the learned court. Seeing no other option,
the plaintiff’s counsel also agreed and signed the statement.

4. That a valuable right of the plaintiff is involved and in case his

suit is not restored and decided on merits, he would suffer an
irreparable loss. It has been repeatedly held by the Superior
Courts that parties to lis may not be knocked out technically and
cases be decided on merits.

5. That the suit was adjourned Cina die not on any fault on the part
of the plaintiff and as such there is no technical or legal reason in
the way of restoring the plaintiff’s suit.

Wherefore, it is respectfully prayed that

plaintiff’s above captioned suit be restored and be
 decided on merits after giving him opportunity to
adduce the evidence in rebuttal.

Affidavit is attached herewith.

Applicant/Plaintiff

Through: -
Zaffar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.

IN THE COURT OF SARDAR MUHAMMAD BABAR,

CIVIL JUDGE IST CLASS, MULTAN.
 Sheikh Umar Ali Vs. Ch. Rehmat Ali, etc.

AFFIDAVIT of: -
Sheikh Umar Ali S/o Muhammad Abdullah, caste
Sheikh, R/o House No. 72, Hassan parwana Colony,
Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-mentioned plaint are true and correct
to the best of my knowledge and belief and
nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of January 2001 that the contents of this affidavit
are true & correct to the best of my knowledge
and belief.

DEPONENT

IN THE COURT OF DISTRICT JUDGE, MULTAN.

Fazal Elahi S/o Allah Dad, caste Rajput, R/o Plot No. 145, Timber
Market, Multan.
Plainitiff/Appellant
Versus
1. Hafiz Khan Shameer Ss/o Malik Muhammad, caste
Arain
2. Sanaullah Rs/o H. No. 1113/8-M, Near Nala
Wali Muhammad, Mohallah Gulam
Abad, Multan city.
3. Ch. Abdul Hameed S/o Ch. Noor Din, caste Arain, R/o
Chowk B.C.G. Mohallah Muhammad Pura, Multan.
4. M.D.A. Multan.
Defendants

APPEAL U/s 96 of C.P.C. against the order &

decree dated 22.11.2000 passed by Ch.
Rasheed Ahmad Civil Judge, Multan,
whereby he rejected the plaint of the
plaintiff’s suit.

CLAIM IN APPEAL: -
To accept the appeal, to set aside the
impugned judgment & decree and to
remand the case in hand.
Value of appeal: - Rs. 2,000/-

Respectfully Sheweth: -
1. The facts of the case are that plaintiff/appellant filed a suit in the
court of Senior Civil Judge, Multan against the
defendants/respondents for declaration & permanent injunction
that he is owner in possession of plot No. 145 measuring 2
Kanals situated in Timber Market Multan and that agreement
dated 14.3.90 in respect of 10 Marlas, part of the plot, from Ch.
Abdul Hameed defendant No. 3 on the basis of General Power of
 Attorney in favour of defendant no. 2 is illegal, against facts,
without consideration and based on fraud, hence, ineffective qua
the rights of the plaintiff/appellant and for permanent injunction
as consequential relief restraining the defendants No. 1 & 2 to
interfere in his ownership and possessory rights regarding plot in
dispute. It was averred in the plaint that plaintiff never sold out
any part of the plot to defendant No. 2 nor he empowered
defendant No. 3 to sell it to defendants No. 1 & 2 nor he received
any amount as consideration of the said share of plot. He further
stated that he is in possession of the plot as owner and the said
agreement is not binding, hence, ineffective qua his rights and is
liable to be cancelled. It was further averred that he came to
know of the said agreement only two days prior to the institution
of the suit when defendant No. 1 tried to take possession of the
plot forcibly by putting bricks on the plot.
2. That the learned trial court summoned the defendants who,
instead of filing written statement, moved an application under
Section 7 Rule 11 C.P.C. praying for rejection of plaint on the
ground that in a previous round of litigation between Masjid
Sultania Vs. Hafiz Khan Shameer. The defendants were declared
as owner of the plot and this fact was known to the plaintiff, as he
filed a written statement in another suit titled Hafiz Khan
Shameer Vs. Fazal Elahi and that the said agreement was also
signed by a son of the plaintiff. Said Suit being incompetent, was
dismissed.
3. That in written reply, the plaintiff denied filing of any written
statement in the said suit and also denied that his son ever signed
the agreement. As to general power of attorney, it was stated that
the same was executed for specific purpose to execute agreement
in favour of 51 persons, who ultimately received their amount
back from the plaintiff and matter came to an end.
4. That the learned trial court accepted the application under Order
7 Rule 11 C.P.C. and rejected the plaint vide order and decree
dated 22.11.2000 impugned on the ground of non payment of
proper court fee and suit being barred by time.
5. That order and decree impugned is illegal and is liable to be set
aside inter alia on the following: -
GROUNDS

i) That non payment at C.F. cold not be a ground for out

and out rejection of plaint without first asking the
plaintiff to pay proper C.F. the impugned order thus
passed is without jurisdiction and legally not
maintainable. Even otherwise the suit was properly
valued but no opportunity was given to the plaintiff to
argue on the point of valuation.
ii) That the 2nd ground which prevailed in passing of the
order of rejection of plaint that suit is barred by time is
not based on any substantive piece of evidence on the
record. In absence of written statement, only the
averments in plaint were to be seen and whether,
presuming averments to be true, court can give relief to
the plaintiff or not. Reliance of the learned trial court in
a written statement, same being not a substantive piece
of evidence without proof, alleged to have been filed by
the plaintiff in some other suit was not legal especially
when the said filing of written statement was denied by
the plaintiff and that the suit being incompetent was
dismissed.
Wherefore, it is respectfully prayed that
appeal be accepted, impugned order & decree be
set aside and case be remanded to the learned
trial court for decision on merits after recording
evidence of the parties.
Appellant,

Through: -
Zaffar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.
IN THE COURT OF DISTRICT JUDGE, MULTAN.
 Fazal Elahi Vs. Hafiz Khan Shameer, etc.

CIVIL APPEAL

Application U/s 5 of Limitation Act, for

condonation of delay in filing the appeal.

Respectfully Sheweth: -
1. That appeal captioned above was presented to C.O.C. of this
Hon’ble Court yesterday which was returned to the applicant’s
counsel with objection that same is barred by time, hence,
could not be entertained.

2. That order & decree impugned was passed on 22.11.2000.

Application for obtaining copies was made as the same date.
Copy was delivered to the 3.1.2001.

3. That the appellant handed over these copies to Mr. Zafar Iqbla
Khan Advocate with instructions to file the appeal. Said
counsel, due to rush of work, took 14 days to prepare and file
appeal on 17.1.2001.

4. That U/s 12 Limitation Act, the time spent in obtaining copies

of the judgment & decree, is to be reckoned till receipt of
copies on 3.1.2000 and such appeal is within time.

5. That the appellant, within a period of one month after making

application, approached copying agency many times for
receipt of copies, but he was told that copy is not prepared.

6. That appellant thereafter, was never informed by the copying

agency that copies were prepared.

7. That appellant is an old man aged 90 years living in Timber

Market, a far off place in Multan and faces much difficulty in
travelling from his residence to District Courts very often.
8. That delay, if any, in filing the appeal, is not due to any fault
on the part of the appellant.

9. That, in case, delay is not condoned, appellant shall suffer

irreparable loss.

Wherefore, it is respectfully prayed that delay, if

any, in filing the appeal may be condoned.
Affidavit of appellant & his counsel is attached
herewith.
Applicant/Appellant,

Dated: 18.1.2001

Through: -
Zaffar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.

IN THE COURT OF DISTRICT JUDGE, MULTAN.

 Fazal Elahi Vs. Hafiz Khan Shameer, etc.

CIVIL APPEAL

APPLICATION FOR CONDONATION OF DELAY.

AFFIDAVIT of: -
I, Zafar Iqbal Khan, Advocate High Court, C.C. No.
2216, 124-District Courts, Multan, do hereby solemnly
affirm as under: -

1. That appellant Fazal Elahi handed over me copies of judgment &

decree impugned on 3.1.2001 with instruction to file appeal.

2. That being busy in another court, I could not attend to it for some
days and thereafter I prepared appeal and filed it.

3. That my above statement is true to the best of my knowledge and

belief, nothing is concealed.

DEPONENT,

Zafar Iqbal Khan,

Advocate High Court,
Multan.

IN THE COURT OF DISTRICT JUDGE, MULTAN.

 Fazal Elahi Vs. Hafiz Khan Shameer, etc.

CIVIL APPEAL

APPLICATION FOR CONDONATION OF DELAY.

AFFIDAVIT of: -
Fazal Elahi S/o Allah Dad, caste Rajput, R/o Plot No.
145, Timber Market, Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-mentioned application are true and
correct to the best of my knowledge and belief
and nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of January 2001 that the contents of this affidavit
are true & correct to the best of my knowledge
and belief.

DEPONENT

From: -
The office of: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts, Multan.

To,
The Chief Engineer,
 Irrigation Zone Dera Ghazi Khan,
Through S.D.O. R.T.W. Right Sub-Division
Dera Ghazi Khan.

Subject: - Case titled Hazoor Bakhsh etc. Vs. Govt. of the Punjab.

Respected Sir,
With reference to your letter No. 91/PF dated
2.12.2000, it is stated with regret that I have been conducting the
case since its institution but the Department had not taken care of
making payment of my fee amount to Rs. 12,000/-. I shall however,
appear and conduct the case on 22.1.2001. My fee may be paid at
your earliest convenience.

Yours sincerely,

Zafar Iqbal Khan,

Advocate

IN THE COURT OF MIAN MUHAMMAD RIAZ KHURRAM,

CIVIL JUDGE, MULTAN.
 Syed Abdullah Ahmad Vs. Ahsan Raza

Suit for Declaration.

Application under Order 7 Rule 11 C.P.C.

WRITTEN REPLY: -
Written reply of the above application on the behalf of plaintiff is
submitted as under: -
1. That para No. 1 of the application is correct.
2. That para No. 2 of the application is incorrect. The suit is barred
by time.
3. That para No. 3 of the application is misconceived, hence,
incorrect.
4. That para No. 4 of the application is incorrect. It is correct that
decree of court does not come within the definition of property.
5. That para No. 5 of the application is incorrect. It is incorrect that
suit in the present form is not maintainable.
6. That para No. 6 of the application is again misconceived. Hence,
incorrect. It is incorrect that suit is liable to be dismissed under
Order 7 Rule 11 C.P.C.
Prayer in application is misconceived and incorrect.
Application merits dismissal. Same be dismissed with
costs.
Plaintiff/Respondent
Dated: 22.1.2001
Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.
In the Court of Muhammad Arshad Malik, Additional District
Judge, Multan.

(1) Muhammad Hafeez etc. Vs. Mst. Rizwana Zafar

 Civil Appeal

(2) Muhammad Siddique etc. Vs. Mst. Manzoor alias

Parween Begum.
Civil Appeal

APPLICATION FOR RECORDING

COMPROMISE ARRIVED AT
BETWEEN THE PARTIES.

Respectfully Sheweth: -
1. That the above-captioned two appeals are pending before this
Hon’ble Court which are fixed for today.

2. That in addition to these two appeals, another appeal R.F.A. No.

138/96 titled Mst. Rizwana Zafar etc. Vs. Muhammad Hafeez
etc. is also pending before the Hon’ble Lahore High Court,
Multan Bench, Multan.

3. That parties too all the above mentioned three appeals have
arrived at the compromise in the following terms: -

i) That in the first above-mentioned appeal captioned

Muhammad Hafeez etc. Mst. Rizwana Zafar etc., the
appellants withdraw their appeal and as such the
impugned decree passed by the learned Civil Judge
shall remain intact.

ii) That in the second appeal titled Muhammad Siddique

etc. Vs. Mst. Manzoor alias Parween Begum etc., the
appellants withdraw their appeal with a slight
modification regarding detail of land mentioned in the
decree. The land mentioned in the decree sheet consists
of Khasra No. 11/4/1, 5, 6, 7 measuring 27 Kanals 2
Marlas which shall be replaced as Khasra No. 11/13
measuring 7 Kanals 9 Marlas, 11/14 measuring 7
Kanals 2 Marlas, 11/15/1 measuring 7 Kanals 11
Marlas, 11/15/2 measuring 0 Kanals 9 Marlas, 11/6
MIN Sharqi measuring 0Kanals 6 Marlas and 10/10
 measuring 4 Kanals 5 Marlas; total land 27 Kanals 2
Marlas according to Register Haq Daran Zamin for the
year 1994-95 Mouz Gagra Tehsil Multan and to that
extent, the detail of land mentioned in the impugned
decree shall be amended and replaced.
Appellants have already handed over
physical possession of the land measuring 27 Kanals 2
Marlas mentioned above along-with standing wheat
crop to Mst. Manzoor alias Parween Begum
(respondent). From now Mst. Manzoor shall be deemed
to be owner in possession of the said land and
appellants shall have no concern whatsoever with the
ownership and possession of land.

iii) That in consideration to the withdrawals of the above-

mentioned two appeals, Mst. Rizwana Zafar etc., the
appellants in R.F.A. No. 138/96 titled Mst. Rizwana
Zafar etc. Vs. Muhammad Hafeez etc. shall
immediately withdraw their appeal. The moment,
Muhammad Hafeez and Muhammad Siddique make the
statement of withdrawal of their two appeals before this
Hon’ble Court, the third appeal R.F.A. No. 138/96 shall
also be taken as withdrawn. However, necessary steps
shall immediately be taken by Rizwana Zafar etc. for
withdrawal of their appeal in the High Court.

iv) That Cost of litigation shall be borne by the parties.

v) That according to the compromise, the detail of land

shall be adjusted/corrected in the decree sheets
accordingly.

vi) That this compromise is final between the parties and

there shall be no litigation in future regarding this land
such as suit for pre-emtpion etc.

Appeal No. 1. Muhammad Hafeez (Appellant),

Muhammad Siddique (Appellant)

 Through: - Malik Muhammad Afzal Advocate

Mst. Rizwana Zafar (Respondent)

Through: - Zafar Iqbal Khan Advocate

Appeal No. 2. Muhammad Siddique (Appellant No. 1)

Muhammad Hafeez (Appellant No. 2)

Through: - Malik Muhammad Afzal Advocate

Mst. Manzoor alias Parween Begum

(Repsondent)

Through: - Zafar Iqbal Khan Advocate.

R.F.A. No. 138/96 Mst. Rizwana Zafar (Appellant No. 1)

Mst. Samina Zafar (Appellant No. 2)

Mst. Farzana Zafar (Appellant No. 3)

Identified by Zafar Iqbal Khan Advocate.

Muhammad Hafeez (Respondent No. 1)

Muhammad Siddique (Respondent No. 2)

Through: - Malik Muhammad Afzal Advocate.

Dated: 14.2.2001
In the Hon’ble Lahore High Court, Multan Bench, Multan.
 Mst. Rizwana Zafar etc. Vs. Muhammad Hafeez etc.

R.F.A. No. 138/96

Application for recording the compromise.

Respectfully Sheweth: -
1. That as per compromise Ex.C.1, Muhammad Hafeez etc. have
withdrawn the other two appeals form the court of Mr.
Muhammad Arshad Malik, Additional District Judge, Multan.

2. That in consideration of the said withdrawals of the two appeals,

the appellants withdraw the present appeal R.F.A. No. 138/96
with a slight modification in detail of suit property mentioned in
the impugned decree sheet.

3. That in the impugned decree sheet, the land to the extent of 27

Kanals 2 Marlas consisting of Khasra No. 11/13 measuring 7
Kanals 9 Marlas, 11/14 measuring 7 Kanals 2 Marlas, 11/15/1
measuring 7 Kanals 11 Marlas, 11/15/2 measuring 0 Kanals 9
Marlas, 11/6/2 MIN measuring 0 Kanals 6 Marlas and 10/10
measuring 4 Kanals 5 Marlas shall be replaced by Khasra No.
11/4/1, 5, 6, 7 measuring 27 Kanals 2 Marlas as the above said
Khasra No’s have already been given to Mst. Manzoor alias
Parveen Begum under compromise in appeal titled Muhammad
Siddique etc. Vs. Mst. Manzoor alias Parveen Begum in place of
Khasra No’s 11/4/1, 5, 6, 7 measuring 27 Kanals 2 Marlas.

4. Cost of litigation shall be borne by the parties.

Wherefore, it is respectfully prayed that this
Hon’ble Court may be pleased to pass an order for the
enlistment of R.F.A. No. 138/96 and whereafter be
disposed off in terms of compromise.

Applicants/Appellants,
 1. Mst. Rizwana Zafar,

2. Mst. Samina Zafar,

3. Mst. Farzana Zafar,

Through: -
Zafar Iqbal Khan,
Advocate High Court,
C.C. No. 2216
Counsel for the appellants.

1. Muhammad Hafeez,

2. Muhammad Siddique,
(Respondents)

Through: -
Malik Muhammad Afzal,
Advocate High Court,
Counsel for the respondents.

Dated: 14.2.2001

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 Criminal Appeal No.____________/2001

Muhammad Saleem alias Cheema & another

Versus
The State

INDEX

S. No. NAME OF DOCUMENTS ANNEXES PAGES

1 Urgent Form
2 Opening Sheet
3 Grounds of Appeal
4 Copy of Judgment
5 Vakalatnama
HUMBEL APPELLANT,
Dated: ____________
(Muhammad Saleem, etc.)

Through: -

Zafar Iqbal Khan,

Advocate High Court,
124-District Courts,
Multan.
C.C. No. 2216

Sterce: H.C.J.D/B--1
(Opening Sheet for Criminal Appeals (Section 419, Criminal Procedure
Code)

LAHORE HIGH COURT, LAHORE

BENCH AT MULTAN.

JUDICIAL DEPARTMENT

CRIMINAL APPEAL NO. OF 2001

 DIVISIONAL REGISTRAR NO.
Whether filed by Stamp on
District Date of filing petition. appel--lant in person or petition of
by Counsel or Agent. Appeal.
Counsel.
Zafar Iqbal Khan
Multan. 17-2-2001 Advocate High Court.

1. Muhammad Saleem alias Cheema

2. Haq Nawaz, sons of Muhammad Ashiq,
caste Malang, residents of Ban Bosan, P.S. Alpa, Multan.
APPELLANTS
Versus
The State ……………RESPONDENT

APPEAL U/s 410 Cr.P.C. against the judgment passed by Mr.

Muhammad ArshadMalik, Additional Sessions Judge, Multan.
Date of judgment:29.1.2001
CHARGE under section 302/34 P.P.C.
SENTENCE: Muhammad Saleem and Haq Nawaz both to undergo
life imprisonment u/s 302 (b) P.P.C. Both the accused are directed to
pay Rs. 50,000/- each as compensation to the legal heirs of the
deceased u/s 544-A Cr.P.C. and in case of non-paymnet of
compensation amount, the convicts shall have to further undergo six
months S.I.
The benefit of Sec. 382 (b) Cr.P.C. shall be admissible to both
the accused while computing their sentence.
Case F.I.R. No. 239/97 dated 21.11.1997
U/s: 302/34 P.P.C. Police Station Alpa, Multan.
GROUNDS
a) That the appellants are innocent. They have not committed
any crime.
b) That the prosecution evidence is discrepant, interested and
untrustworthy. The prosecution witnesses are closely related
to the complainant who are inimical towards the accused.
Their testimony, without independent and strong
corroboration, could not be relied upon for conviction of the
accused.
c) That no recovery having been effected from the accused,
necessary corroborative evidence was lacking qua them.
Accused had been found innocent during the course of
investigation by the I.O. and D.S.P. Circle.
d) That motive given in the F.I.R. was very weak and also
prosecution has failed to prove it and rightly disbelieved by
the learned Trial Court.
e) That while passing the impugned judgment, the learned Trial
Judge has not kept in view the principles of Safe dispensation
of Criminal Justice.
f) That at the worst, keeping in view the nature of injuries, it
cannot be said that accused had intention to cause death of the
deceased or to cause such bodily injury with knowledge that it
was likely to cause death or was sufficient in ordinary cause
of nature to cause death of the deceased. As such conviction
u/s 302/34 P.P.C. is bad.
Wherefore, it is respectfully prayed that the
record of the Trial Court may kindly be summoned, and
perused, and by accepting the appeal, the conviction
and sentence of the humble appellants be set aside, and
humble appellants may kindly be acquitted of the
charge.
Appellants,
Dated: ________
Muhammad Saleem etc.

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.
C.C. No. 2216

Certificate: -
Certified that this is the first appeal on
the subject.
Advocate

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.
 C.M. No. __________/2001
In
C.R. No. 57-D/2001

Muhammad Shareef and another

Versus
Malik Ashiq Muhammad deceased through his legal heirs and others

Application u/s 151 C.P.C. for recalling

order of Status Quo passed on C.M. No.
2-C/2000.

Respectfully Sheweth: -
1. That Jamal Din was the owner of house in dispute who died
on 18.6.73 issueless. Ashiq Muhammad, the predecessor of
the applicants, was the only legal heir of the decease Jamal
Din. It is proved and concurrently found by the learned courts
below that the revision petitioners who are sons of Mst.
Sattharai alias Haseena was the daughter of Raj Ameer and
not of Jamal Din and as such she had nothing to do with the
inheritance of Jamal Din.

2. That by giving concurrent findings of fact, the learned courts

below, had not acted in the exercise of jurisdiction illegally or
with material irregularity. The impugned judgments are based
on evidence on the record. There is no misreading or no non-
reading of evidence. The order of granting temporary
injunction in the form of status quo is perverse without there
being a prima facie case. The revision petitioners had been
depriving the rightful owner, applicants of their property since
18.6.73, the date of death of Jamal Din.

4. That challenge to Issue No’s 2 and 5 is not available to the

revision petitioners as the same had already been dismissed
 vide order dated 12.7.94 passed by Mr. Justice Saeed-ur-
Rehman Farrukh, in C.R. No. 1028/94 in execution of the
decree.

Wherefore, it is respectfully prayed that order of

status quo may kindly be vacated so that the applicants
who are rightful owners of the property in dispute may
be able to take possession of the property.
Applicants,

Dated: ________
Malik Muhammad Rafique etc.
Legal Heirs of Malik Muhammad Ashiq

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.
C.C. No. 2216

BEFORE THE HON’BLE JUDGE BANKING COURT,

MULTAN.
Nazar Hussain S/o Khadim Hussain, caste Thaheem, R/o Mouza Nai
Wala, Tehsil & District Multan.
Plaintiff
Versus
1. Manager, Agricultural Development Bank of Pakistan, Branch
Abdali road, Nawan Sheher Multan.
2. Mobile Credit Officer, Agricultural Development Bank of
Pakistan, Branch Abdali road, Nawan Sheher Multan.
Respondents

Suit for rendition of accounts and for

injunction restraining the defendants
from recovering any undue amount
from the plaintiff by adopting coercive
measures without first determining the
amount as due.

Respectfully Sheweth: -
1. That the plaintiff obtained loans of Rs. 40,000/- in the year
1995, Rs. 48,000/- in the year 1996, Rs. 60,000/- in the year
1998-99 and Rs. 65,000/- in the year 1999-2000 total amount
of loans comes to the Rs. 213,000/- from the defendant Bank.

2. That the plaintiff paid back the amount of loan in the

following installments: -

S.No. Date Amount

1. 9.6.1995 48,132/-
2. 28.12.1995 18,500/-
3. 8.1.1996 2,870/-
4. 21.1.1996 729/-
5. 4.12.1996 9,000/-
6. 12.12.1996 5,000/-
 7. 19.12.1996 6,000/-
8. 20.6.1998 23,000/-
9. June 1998 15,000/-
10. December 1999 25,000/-
11. 19.12.1996 23,000/-
12. June 1999 30,000/-
13. December 1999 15,000/-
Total amount paid: 234,231/-
That as such the plaintiff had already paid Rs. 21,231/- over
and above the original amount.

3. That the defendant bank served the plaintiff with a notice to

deposit Rs. 110,000/- more, which amount is not due.

4. That the defendants were asked repeatedly for the rendition of

accounts but they pay deaf ear to the request of the plaintiff
and instead they started raiding the plaintiff’s residence for his
arrest for the recover of the amount which is not due.

6. That cause of action accrued to the plaintiff lastly a weak ago

when the defendant No. 2 refused for the rendition of
accounts and raided the plaintiff’s house for his arrest.

7. That loan amount was raised at Multan and also to be paid

back in Multan, hence, this Hon’ble Court has jurisdiction to
entertain and hear the suit.

8. That according to law a court fee of Rs. 10 is fixed for the

prayer of rendition of accounts and value for the purpose of
court fee and jurisdiction is fixed for Rs. 200/- which is
exempted from payment of Court fee.

Wherefore, it is respectfully prayed that a decree

for rendition of accounts be passed in favour of the
plaintiff against the defendants and for injunction
restraining the defendants from harassing the plaintiff
for the recovery of amount which is not due and untill
the rendition of accounts be passed. Cost of suit may
also be awarded.
 Any other relief, which this Hon’ble Court
deems fit, may also be awarded to the plaintiff.
Humble Plaintiff,

Dated: ________
(Nazar Hussain)

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.

Verification: -
Verified on oath this____ day of February
2001 that all the contents of the above plaint
are true and correct to the best of my
knowledge and belief.
Plaintiff

BEFORE THE HON’BLE JUDGE BANKING COURT,

MULTAN.
 Nazar Hussain Vs. Manager, A.D.B.P.

Application U/s 151 C.P.C. for grant of injunction.

Respectfully Sheweth: -
1. That the above captioned suit has been filed in the Hon’ble
Court.

2. That the plaintiff has availed the loan facility to the tune of Rs.
213,000/- on different dates and repaid amount of Rs. 234,231/-
and as such has paid 21,231/- over and above the original loan
amount.

3. That the defendant No. 2 out of ill will and grudge, is all the
times out to arrest the plaintiff for the recovery of undue amount
and his such act is illegal and uncalled for.

4. That plaintiff’s valuable land of more than the entire loan

amount, is mortgaged with the bank. The plaintiff had been
vigilant to pay the amount of installments more than it was due
and also before the due dates and in the circumstances, the
defendant No.2’s such coercive action against the plaintiff is
illegal and uncalled for and the against the law laid down by the
Hon’ble High Court in 1995 MLD 12.

5. That the defendant No. 2 is out to arrest the petitioner and in

case, he succeeds in his malicious act, the plaintiff shall suffer an
irreparable loss.

6. That in view of the over payment made by the plaintiff the suit of
the plaintiff is likely to succeed.

7. That balance of convenience also tilts in favour of the plaintiff.

Wherefore, it is respectfully prayed that

the defendants/respondents be restrained from
affecting arrest of the plaintiff/applicant illegally
 without first determining the amount as due and
defendants may also be directed to act strictly in
accordance with law. Affidavit attached.
Applicant,

Dated: ________
(Nazar Hussain)

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.

BEFORE THE HON’BLE JUDGE BANKING COURT,

MULTAN.

Nazar Hussain Vs. Manager, A.D.B.P.

 STAY APPLICATION

AFFIDAVIT of: -
Nazar Hussain S/o Khadim Hussain, caste Thaheem,
R/o Mouza Nai Wala, Tehsil & District Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-titled application are true and correct
to the best of my knowledge and belief and
nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of February 2001 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief and nothing has been kept
concealed thereto.
DEPONENT

IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

C.M. No. __________/2001

In
C.R. No. 57-D/2001
 Muhammad Shareef and another
Versus
Malik Ashiq Muhammad deceased through his legal heirs and others

Application u/s 151 C.P.C. for recalling order of

Status Quo passed on C.M. No. 2-C/2000.

AFFIDAVIT of: -
Malik Muhammad Rafique S/o Malik Ashiq
Muhammad, caste Awan, R/o Multan.

I, the above named deponent do hereby

solemnly affirm and declare that the contents of
the above-titled application are true and correct
to the best of my knowledge and belief and
nothing has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of February 2001 that the contents of this
affidavit are true & correct to the best of my
knowledge and belief and nothing has been kept
concealed thereto.
DEPONENT