IN THE COURT OF MR SIKANDER JAVAID CIVIL JUDGE LAHORE.

In the matter of: Saif-ur-Rehman Khan Vs Robina Kamal

(Suit for Declaration and Permanent Injection)

1. Ambreen Gul D/o Saif-ur-Rehman Khan R/o House No. 385/1 Street No. 2 Jaranwala Faisalabad. 2. Rashid Salman Khan S/o Saif-ur-Rehman Khan R/o House No. 19 Brichkhi No. 1 Umar Colony Green Town, Lahore.

Petitioner

Vs
Robina Kamal D/o Dilwar Khan R/o House No. 19 Brich No.1 Umer Colony Green Town, Lahore.

Respondent

Application Under Order1, Rule 10 of C P C Read with Section 151 CPC

Respectfully Sheweth: 1. That captioned Suit is pending for adjudication before this learned court and next date is fixed 30.01.2010.

2. That the main Suit filed by the father of the applicants regarding the property House No. 19 Brick Kiln No.1 Umer Colony Green Town, ___, wherein Father of the applicants seeks declaration in the property

stated already n this Para i.e. House No.19 Brick Kiln No.1 Umer Colony Green Town, Lahore.

3. That the defendant is a real mother of the applicants who had never any source to construct or buy such property.

4. That the defendant lodge FIR against the Plaintiff (Saif-ur-Rehman Khan) where in the defendant forces the applicants to sine false evidence against the Plaintiff (Saif-ur-Rehman Khan). On their reply in negative the Defendant has threatened the applicant in failing to comply her illegal demand, she shall deprive the applicant from their Legal and Sharia shares in the property which has been constructed and purchased by their father (Saif-ur-Rehman Khan) from his own expenses.

5. That Plaintiff (Saif-ur-Rehman Khan) being busy in earning bread & butter, made a benami registry in defendants favor so she could in plaintiffs absence look after the property. But the Plaintiff had no knowledge of the mal behavior and devilish attitude of the defendant, she could play against plaintiff and applicants.

6. That now the Defendant rubina kamal is incliened to sale out the property in suit because she wants to deprive the applicants from their shares whereas the applicants are not willing to giving false evidence against their father plaintiff hence this application for imp lead them as party to a suit.

Prayer
In view of above stated facts in hand It is therefore, respectfully prayed that this application may kindly be accepted and applicants may please be imp leaded as necessary party to a suit to defend their legal and sharia shares from which the defendant is depriving them. It is further prayed that the defendant rubina kamal may kindly be restrained from alienating or selling out the suit property.

Petitioner

Through

Muhammad Kamran Siddiquei Advocate High Court

Zahid Law Associates 2nd Floor Nawa-I-Waqt Building Shahra-e- Fatima Jinnah Lahore

IN THE COURT OF MR SIKANDER JAVAID CIVIL JUDGE LAHORE.

In the matter of: Saif-ur-Rehman Khan Vs Robina Kamal (Suit for Declaration and Permanent Injection)

3. 4.

Ambreen Gul D/o Saif-ur-Rehman Khan R/o House No. 385/1 Street No. 2 Jaranwala Faisalabad. Rashid Salman Khan S/o Saif-ur-Rehman Khan R/o House No. 19 Brichkhi No. 1 Umar Colony Green Town, Lahore. Petitioners Vs Robina Kamal D/o Dilwar Khan R/o House No. 19 Brich No.1 Umer Colony Green Town, Lahore. Respondent

Application Under Order1, Rule 10 of C P C Read with Section 151 CPC APPLICATION UNDER ORDER 39 RULE 1 READ WITH SECTION 151 CPC FOR THE GRANT OF INTERIM INJUCTION:

AFFIDAVIT OF

Rashid Salman Khan S/o Saif-urRehman Khan R/o House No. 19 Brichkhi No. 1 Umar Colony Green Town, Lahore

I, the above named deponent solemnly affirm and declare as under; That the Contents of the accompanying petition are correct and true to the best of dependants knowledge and belief and nothing has been concealed there from. Moreover, the deponent has not filed any other petition except the instant petition in any other Court.
DEPONENT

Rashid Salman Khan verification

Verified on oath at Lahore on this 30th day of jan2010

that all the contents of the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT Rashid Salman Khan

IN THE COURT OF MR SIKANDER JAVAID CIVIL JUDGE LAHORE.

In the matter of: Saif-ur-Rehman Khan Vs Robina Kamal

(Suit for Declaration and Permanent Injection)

5. Ambreen Gul D/o Saif-ur-Rehman Khan R/o House No. 385/1 Street No. 2 Jaranwala Faisalabad. 6. Rashid Salman Khan S/o Saif-ur-Rehman Khan R/o House No. 19 Brichkhi No. 1 Umar Colony Green Town, Lahore.

Petitioners

Vs
Robina Kamal D/o Dilwar Khan R/o House No. 19 Brich No.1 Umer Colony Green Town, Lahore.

Respondent

Application Under Order1, Rule 10 of C P C Read with Section 151 CPC

APPLICATION UNDER ORDER 39 RULE 1 READ WITH SECTION 151 CPC FOR THE GRANT OF INTERIM INJUCTION:

RESPECTFULLY SHEWETH:

1)

That the applicant has today filled an application under order 1 rule 10in

captioned suit which is fixed for 30-01-2010 before this honorable court, the contents of which may kindly be read as an integral part of this application. 2) 3) That the applicant has got a prima facie and good arguable case in its favor and there is every likelihood of its success in the main suit. That the balance of convenience also lies in favor of the applicant/plaintiff.

4)

That in case, pending decision of the titled suit, if the applicant may not be imp leaded as necessary party to a suit to defend their legal and sharia shares from which the defendant is depriving them. Harassing the applicants, the applicants shall suffer irreparable loss and injury. It is therefore most respectfully prayed that pending decision of the titled suit, the defendant/respondent may kindly be restrained from harassing the petitioner, alienating or selling their property in any manner what so ever, for the sake of justice and equity.

Any other relief deemed appropriate by this Honorable Court may also be granted to thee plaintiff.

Ad-interim injunction may also be passed.

APPLICANT THROUGH:

MUHAMMAD KAMRAN SIDDIQUIE Advocate High Court

IN THE COURT OF MR SIKANDER JAVAID CIVIL JUDGE LAHORE.

In the matter of: Saif-ur-Rehman Khan Vs Robina Kamal (Suit for Declaration and Permanent Injection)

7. 8.

Ambreen Gul D/o Saif-ur-Rehman Khan R/o House No. 385/1 Street No. 2 Jaranwala Faisalabad. Rashid Salman Khan S/o Saif-ur-Rehman Khan R/o House No. 19 Brichkhi No. 1 Umar Colony Green Town, Lahore. Petitioners Vs Robina Kamal D/o Dilwar Khan R/o House No. 19 Brich No.1 Umer Colony Green Town, Lahore. Respondent

Application Under Order1, Rule 10 of C P C Read with Section 151 CPC

AFFIDAVIT OF

Rashid Salman Khan S/o Saif-urRehman Khan R/o House No. 19 Brichkhi No. 1 Umar Colony Green Town, Lahore

I, the above named deponent solemnly affirm and declare as under; That the Contents of the accompanying petition are correct and true to the best of dependants knowledge and belief and nothing has been concealed there from. Moreover, the deponent has not filed any other petition except the instant petition in any other Court.
DEPONENT

Rashid Salman Khan

Verified on oath at Lahore on this 30th day of jan2010

that all the contents of the above affidavit are correct and true to the best of my knowledge and belief.

DEPONENT Rashid Salman Khan