In the court of Mr.

imran civil judge Lahore

In re:

Sui Northern Gas Pipeline vs zaib un nisa

Suit for recovery of Rs. 104500/- along with mark up cost expenses till final realization

Shoaib farooq son of Allau ud Din Khawaja resident of House No. 34 Mohalla Riwaz Garden Lahore.

Applicant

Vs

1. Sui Northern Gas Pipe line LTD, registered office at Gas House, 21 Kashmir Road Lahore,
through Mr. Qaiser Masood its General Manager Lahore Region.
2. Zaib un nisa daughter of shuja ud din resident of plot no. 18-39 lower mall session court Lahore.

Respondent

Application under order 1 rule 10 read with section 151 CPC on behalf of petitioner/ shoaib farooq
son of allau ud din khawaja resident of house no 178 mohalla riwaz garden Lahore to be implead
the present applicant as defendant being necessary party in titled suit

Respectfully sheweth

1. That brief facts to file the present application are that the respondent No. 1 filed above titled
suit before this honourable court, same is pending adjudication and fixed for 24-12-2018.
2. That in fact respondent No. 2 obtained a domestic sui gas connection vide consumer No.
7006871000 from respondent No.1
3. That the respondent No. 2 sold her house to namely Basharat umer son of atta elahi along with
all domestic connections, thereafter said basharat umar sold the same house to the applicant
and after receiving consideration amount and executed a sale deed bearing document No. 1528,
Book No. 1 Jild No. 1833, dated 22-03-11 registered at sub registrar Data Gunj Bakhsh Town
Lahore, whereas the domestic sui gas connection still in the name of respondent No. 2
4. That when applicant purchased the same property then applicant moved an application to the
respondent No. 1 to change the nature of tariff from simple domestic to special domestic.
5. That at present the applicant is sole owner in possession of property along with its all utilities.
6. That it is principle of natural justice that no person should be condemned unheard.
7. That if the present applicant is not impleaded as party/ defendant, there is large apprehension
that the applicant would suffer irreparable loss, furthermore in the absence of present
 applicant, the affective judgment could not be passed and that would ultimately defect the spirit
of justice.
8. That if the application in hand is not accepted and the applicant is not arrayed as defendant in
the title suit the applicant shall be bound to suffer an irreparable loss and injury to its
magnetite.

In view of the above submission, it is most respectfully prayed that the application in hand may
kindly be accepted the applicant Shoaib Farooq son of Allau Ud Din Khawaja resident of House No.
178, Mohalla Riwaz Garden Lahore, may kindly be arrayed as defendant in the titled suit to secure
the ends of justice, fair play and equity.

Any other relief which this honourable court deem fit and proper may also be awarded.

Applicant

Through.

Mian arfan ghani

Advocate high court

Dated