MANAGER,

NATIONAL BANK OF PAKISTAN,

CHOWK DERA ADDA,
MULTAN. 1495,

SUBJECT:- LEGAL OPINION OF SUCCESSION

CERTIFICATE UNDER SUCCESSION
ACT IN CASE MUHAMMAD JAMEEL
ETC.
VS. PUBLIC AT LARGE.

Dear Sir,
On my earlier pointation, the applicants have got
corrected the succession certificate from the competent court
according to Quranic shares. The amount may be disbursed to the
legal heirs according to succession certificate. Taking precautionary
measures the amount may be deposited/transferred in their respective
Bank accounts.
The amount or Rs.7,790.34 may be disbursed as under:-
1. Muhammad Jameel 14/40 =Rs.2724.62
2. Muhammad Shakeel 14/40 =Rs.2724.62
3. Mst. Razia Sultana 7/40 =Rs.1363.31
4. Mst. Waziran Begum 1/8 =Rs.973.79
And the amount of Rs.140,000/- may be distributed as under:-
1. Muhammad Jameel 14/40 =Rs.49,000/-
2. Muhammad Shakeel 14/40 =Rs.49,000/-
3. Mst. Razia Sultana 7/40 =Rs.24,500/-
4. Mst. Waziran Begum 1/8 =Rs.17,500/-
Hence presented for your kind perusal and necessary action.
Thanking you.

(SAEED HASSAN HASHMI)

ADVOCATE HIGH COURT
BANK LEGAL ADVISOR
 In the Court of Mr. Muhammad Javed-ul-Hassnan Chishti
Magistrate 1st Class, Multan.

Shabbir Ahmad @ Shiba s/o Ghulam Muhammad caste Mughal

r/o Chak No.271/W.B Tehsil Duniapur, District Lodhran.

(Accused/Petitioner)
Versus

The State. (Respondent)

In case FIR No.137/95 dated 23-3-95

Offence u/s 379/411 P.P.C. Police Station
Cantt, Multan.

Application under Section 249-A Cr.P.C.

for the acquittal of accused/Petitioner.

Respectfully Sheweth:-
1. That the above captioned case is pending adjudication before
this Hon’ble Court and is fixed for 10/6/99 for recording of
prosecution evidence.

1. That brief facts giving rise to the instant application are that the
above captioned case initially was got registered against
unknown person and later on in local police planned a fake case
and subsequently also shown a fake recovery from the accused/
Petitioner.

2. That the accused/Petitioner pray for his acquittal under section

249-A Cr.P.C. inter alia on following
GROUNDS

a) That the charge against the accused/Petitioner is

groundless.
b) That there is nothing on the record to connect the
accused/Petitioner with the commission of alleged
offence. Moreover, the local police have shown a faked
recovery from the Petitioner and actually nothing had
been recovered from the Petitioner.
c) That the complainant has failed to produce his evidence
before this Hon’ble Court. This factum is also evident on
the face of record that repeated summons of bailable and
non-bailable were issued to the complainant as well as to
 the witnesses but non of them appeared before this court.
This aspect of this case shows the insignificance and
negligence on the part of the complainant and inference
can very easily be drawn that he is not willing to
prosecute the accused/Petitioner.
d) That the accused/Petitioner is facing the agonies and
worries of the case for about last 1-1/2 years without any
fault on his part and the case is based on concoction and
falsehood, as such the complainant has abused the process
of the court.
e) That strange enough to say that all the prosecution
witnesses are not only related to each other rather they are
inimical towards the accused/Petitioner and are very
much interested to the complainant party for the
prosecution of the accused/Petitioner in this false case.
f) That the present case is outcome of malafide and ulterior
motives and that the accused/Petitioner has been falsely
implicated in this case on account of enmity. Moreover,
he is innocent as it has been proved from the evidence
available on record.

Under the above circumstances and

submissions, it is most respectfully prayed that this
application may kindly be accepted and that the accused/
Petitioner may very graciously be acquitted of the charge at
this stage, in the supreme interest of justice.

Humble Accused/Petitioner

(Shabbir Ahmad)

Dated: 08/06/99

Through:
SAEED HASSAN HASHMI
Advocate High Court
40-Aziz Block, District
Courts, Multan.
 In the Court of Mr. Muhammad Naeem Sheikh Civil Judge,
Multan.

In re:-
Ghulam Mustafa Vs. Sui Northern Gas etc.

Suit for Declaration

Application for the Grant of Stay

Written Reply on behalf of the Respondents.

Respectfully Sheweth:-
Preliminary objections.

1. That the application is not maintainable in its present

form.

2. That the plaintiff/applicant has no cause of action to bring

this application under reply.

3. That the applicant has no locus standi to bring this

application. Moreover, the applicant has not come in court
with clean hands.

4. That the balance of convenience does not lean in favour

of the applicant.

5. That the applicant is a defaulter of Rs.20,098.75 and has

brought this application so as to digest the outstanding
amount due against him and also to avoid the legal
consequences in respect of outstanding amount due
against him. Details of outstanding against the applicant
has been given in the preliminary objections of he Written
Statement.

Reply on Facts:-

1. That Para No.1 of the application is formal.

2. That para No.2 of the application is also formal.

3. That para No. 3 of the application is incorrect, balance of

convenience does not lean in favour of the applicant,
moreover is based on presumptions.
 4. That para No. 4 of the application is absolutely incorrect,
applicant is a defaulter of the Respondent’s department
details have been given in the Preliminary Objections of
the Written Statement.

Prayer of the applicant is absolutely incorrect, based

on malafide and ulterior motive therefore is liable to be
dismissed with special costs.

Humble Respondents.

Through:-

Dated:- 22/06/99

Through:-
SAEED HASSAN HASHMI
Advocate High Court,
Seat No. 40-Aziz Block,
District Courts, Multan.
To,
General Manager (Legal),
S.N.G.P.L., 21-Kashmir Road,
Lahore.

Subject: - Information regarding Court Cases.

Dear Sir,
I was astonished to hear that you are not receiving requisite
information regarding the proceeding in the Court Cases. It is humbly
submitted that I have been given 15 Court Cases, including one recovery
suit and at this moment there is not a single case pending before any
court in which a stay has been granted against S.N.G.P.L. This is because
all the stays have been vacated and regarding the vacation of stays, it was
duly informed to the office of S.N.G.P.L at Multan and was promptly
implemented by the company also.
It is also worth mentioning here that due to the rejection of stay orders,
the Plaintiffs of those suits had no option except to deposit the disputed
amount to the office. In this way, it is stated with due apologies, your
complaint regarding my efficiency has no force at all. Detail of cases
pending in the Courts or dismissed is given on a separate sheet.
Thanking you.
Yours faithfully,

Saeed Hassan Hashmi,

Advocate High Court,
40-Aziz Block District
Courts, Multan.
HLC/MTN/09/2000
Dated 18/4/2000

To,
International Relation Committee
C/o The Law Society of Singapore
39-South Bridge Road,
Singapore 058673

Subject: -

The undersigned is law graduate and is practising as a

lawyer in High Courts as well as district Courts of Pakistan. I
have the experience of six years in conducting cases in baking,
criminal and civil sides. I have visited almost all the courts of
Pakistan and want to visit the courts as well as jails/
imprisonment of your country to know the style, procedure and
working of courts in Singapore. I shall be very thankful if you
provide me this opportunity.
Looking forward for your co-operation in this regard.
Thanking you in anticipation.
Yours Sincerely,

Saeed Hassan Hashmi

Advocate High Court,
40-Aziz Block District
Courts, Multan. PAKISTAN.
Ph # 061-521253, 0300-639296
E-mail: Wajid-apr-13 @ hotmail.com.
MANAGER,
NATIONAL BANK OF PAKISTAN,
Ghalla Mandi Branch,
MULTAN.

SUBJECT: - LEGAL CLEARANCE CERTIFICATE.

Dear Sir,
With reference to above subject, it is submitted that M/s Al-
Rehman Enterprises Head Office 477-B, Chowk B.C.G. Multan, is a
partnership concern consisting of following partners (i) Mr.
Muhammad Akhtar Bhutta, (ii) Muhammad Shahid Bhutta & (iii)
Muhammad Mujahid Akhtar Bhutta (changed partner). The above
referred party has been availing cash finance facility form the Bank
since 1995 and subsequently the limit was enhanced during the Cotton
Season 1998-99 against the additional mortgage of the property
owned by Mst. Saeeda Akhtar daughter of Malik Abu Bakar (wife of
Malik Muhammad Akhtar Bhutta), caste Bhutta. The same was again
renewed in the year 1999-2000, later on. Now, the party has once
again requested for the renewal of the same for the year 2000-01
against the securities already mortgaged with the bank. The
description of mortgaged property is as follows: -
1. Property bearing Khewat No. 722 (black ink) 711 (red ink) Khewat
No. 953 share owned 8228/32910 measuring 13 kanals 14 marlas
08 yards situated in Mauza Taraf Ravi, Multan owned by Mr.
Ahmad Bakhsh S/o Ahmad Yar registered with Sub-Registrar
(Urban) Multan vide Mortgage Deed No. 9216 Book No. 1
Volume No. 1 dated 19.11.1995 according to the Register
Haqdaran Zamin of Mauza Taraf Ravi (within Municipal limits of
Multan) for the year 1995-96 issued by the Halqa Patwari dated
4.7.2000.
2. Property bearing Khewat No. 349 (black ink) 347 (red ink)
Khewat No. 454 to 458 share owned 3214/51930 measuring 05
kanals 07 marlas 04 yards situated in Mauza Taraf Daira, Multan
owned by Mst. Saeeda Akhtar D/o Malik Abu Bakar Bhutta
registered with Sub-Registrar (Urban) Multan vide Mortgage Deed
No. 7380 Book No. 1 Volume No. 2096 dated 2.10.98 executed by
Mst. Saeeda Akhtar D/o Abu Bakar Bhutta wife of Malik
Muhammad Akhtar Bhutta according to the Register Haqdaran
Zamin of Mauza Taraf Daira (within Municipal limits of Multan)
for the year 1995-96 issued by Halqa Patwari dated 4.7.2000,
according to which the charge of the National Bank of Pakistan
has been incorporated therein.
I am of the view that the properties mentioned above are
already mortgaged with the National Bank of Pakistan. Incharge of
the Bank has already been incorporated in Revenue record, which is
still valid for consideration, as such the interest of the bank is safe
in all respects. The Bank may allow the renewal of the above-
referred facility to the party. However, it is advised that an
agreement for continuity of liability in respect of mortgage deed
mentioned above, be obtained by the party and also look into the
new partnership deed as per rules of the bank.
Submitted for your further necessary action in this regard.
Thanks.

(SAEED HASSAN HASHMI)

ADVOCATE HIGH COURT
BANK LEGAL ADVISOR