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MULTAN.
3. Mst. Mumtaz Elahi W/o Faiz Bakhsh, caste Sudhani, R/o near
Masjid Rehmania, Eidgah Road, Multan.
…DEFENDANTS
Suit for Perpetual injunction restraining
the defendants from interfering illegally
and without restoring to partition, into the
land owned and possessed by the plaintiffs
out of joint khatas and further restraining
them from changing the existing
complexion of the land by digging earth, by
construction and by selling specific Khasra
numbers and forcibly taking the possession
other than their due share and possessed by
the plaintiffs.
DETAILS OF LAND: -
(i) Khewat No. 1370 in black ink, 1398
in red ink, Khatooni No.’s 1898 to
1909, Qitat 29, total share 78840 total
area of Khewat No13K—8M.
(ii) Khewat No. 1396 in black ink, 1371
in red ink, Khatooni No. 1930, Qita 1,
total share 15510, total area of
Khewat 25K—17M.
Respectfully Sheweth: -
1. That briefly stated the fact of the case in hand are that the
disputed property is owned by Allah Yar the predecessor-in-
interest of the plaintiffs and defendants No. 5 to 9. After his
death, the property was devolved to his legal heirs i.e.
plaintiffs and defendants No. 5 to 9. The disputed property is
joint and has not so far been partitioned. The plaintiffs and
defendants are co-sharers of the disputed property upto their
shares.
5. That the defendants have been asked time and again that they
should refrain from illegally taking possession of the disputed
land and also restrain from interfering into the possession of
the plaintiffs over the disputed land except by means of
partition, but they use dilly dally tactics and are adamant not
to accede to the request of the plaintiffs, hence, this suit.
6. That the parties reside in Multan, the disputed land is also
situated in Tehsil Multan and cause of action has also arisen to
the plaintiffs against the defendants in Multan, therefore, this
Hon’ble Court has got jurisdiction to try this suit.
7. That the value of the suit for the purpose of court fee and
jurisdiction is fixed at Rs. 400/-, which is immune from the
levy of court fee.
Humble Plaintiffs,
Dated: ________
Through: -
AAMER AZIZ QAZI,
Advocate High Court,
123-District Courts,
Multan.
Verification: -
Verified on oath this 10th day of May
2003 at Multan that all the contents of
the above titled suit are true and
correct to the best of my knowledge
and belief.
Plaintiffs
IN THE COURT OF LEARNED SENIOR CIVIL JUDGE,
MULTAN.
VERSUS
Mst. Irshad Khatoon etc.
Respectfully Sheweth: -
1. That the subject noted suit is being filed today in this Hon’ble
Court. The contents of the plaint be considered as part &
parcel of this application.
3. That all the factors necessary for grant of stay order exist on
record in favour of the applicants/plaintiffs.
Affidavit is attached.
In view of above respectful submissions, it is
therefore, prayed that pende lite the
respondents/defendants are restrained from selling the
disputed property without restoring to the legal partition
and interfering into the possession of the plaintiffs over
the disputed land; and also be restrained form changing
the complexion of the disputed land by construction
over the disputed property.
Humble applicants,
Dated: _______
Through: -
STAY APPLICATION
AFFIDAVIT of: -
DEPONENT
Verification: -
Verified on oath at Multan, this _____ day
of May 2003 that the contents of this affidavit are
true & correct to the best of my knowledge and
belief.
DEPONENT