IN THE COURT OF LEARNED DISTRICT JUDGE,

MULTAN.

Civil Suit No. ___________/2002

Qazi Zahid Hussain S/o Abdul Qayyum, caste Rajput, R/o H. No.
86-A/13X, Gali Qazianwali, Mohallah Amirabad, Multan.

PLAINTIFF

VERSUS

Niaz Ahmad S/o Muhammad Ramzan, caste Mughal, R/o H. No.

888/92, Mohallah Usman Abad, Multan.

DEFENDANT

Suit under order xxxvii, rule 2-3 C.P.C.

for recovery of Rs. 24,000/- on the
bases of Pronote.

Respectfully Sheweth: -

The plaintiff submits as under: -

1. That the relations in between the parties were cordial and

intimate, the defendant in view of this close intimacy,
borrowed a sum of Rs. 24,000/- on 15.7.1997 from the
plaintiff in order to start his business. The plaintiff obliged
him and paid Rs. 24,000/- in the presence of witnesses and the
defendant on that very day executed a pronote and a receipt in
 favour of the plaintiff, copy whereof is attached herewith for
kind perusal of this Hon’ble Court. Original pronote and
receipt will be produced at the time of recording evidence.

2. That the defendant at the time of executing pronote and

receipt, promised that whenever the plaintiff would demand,
he would return/repay the borrowed amount of Rs. 24,000/- to
the plaintiff.

3. That previously the plaintiff filed a suit, but the defendant

assured that he would pay the borrowed amount, on which the
plaintiff did not pursue the suit, which was dismissed due to
non-deposit of process fee. But till today the defendant did not
pay a single penny to plaintiff and using dilly-dally tactics.
Hence, this fresh suit is being filed because previous suit was
not decided on merits as required by law.

4. That the defendant has been asked time and again for return of
the borrowed amount of Rs. 24,000/- to the plaintiff but the
defendant by using dilly dally tactics a week ago flatly refused
to acceded to the request of the plaintiff. Hence, this suit.

5. That the cause of action accrued to the plaintiff against the

defendant a week back from the flat refusal of the defendant
to pay the borrowed amount.

6. That the parties reside in Multan, cause of action accrued to

the plaintiff against the defendant in Multan, the disputed
amount was also paid in Multan and pronote and receipt were
also paid in Multan, therefore, this Hon’ble Court has got
jurisdiction to try the suit.

7. That the value of suit for the purpose of court fee and
jurisdiction is fixed at Rs. 24,000/-.
 In the light of above respectful submissions, it is
humbly prayed that this suit of the plaintiff of the
recovery of Rs. 24,000/- as envisage by order xxxvii,
rules 2-3 C.P.C. may graciously be decreed in favour of
the plaintiff against the defendant with cost.
Humble Plaintiff,
Dated: _______
(Qazi Zahid Hussain)

Through: -
Aimer Asia Qazi,
Advocate High Court,
123-District Courts,
Multan.

Verification: -

Verified on oath at Multan this 6th day

of July 2002 that all the contents of
the above-titled suit are true and
correct to the best of my knowledge
and belief.

Plaintiff