IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

Civil Suit No.___________/2012

Muhammad Naveed son of Kamran Baig, resident of House

No.-- Street No. Samay Bakers Badami Bagh, Lahore.

Plaintif

VERSUS

Malik Ramzan son of Malik Javed resident of House No. -

Street No. -- Near Wadi Masjid, Mohala Rajpootan, Shadi

Pura, Band Road, Lahore.

Defendant

***

SUIT FOR PERMANENT INJUNCTION

RESTRAINING THE RESPONDENT FROM

INTERFERING INTO THE LAWFUL POSSESSION OF

THE PLAINTIFF.

Respectfully Sheweth:-

1. That the names and addresses of the parties have

been given completely and correctly for effecting

service upon the parties.

2. That the plaintiff is bona fide purchaser of land

measuring 2 Kanals 2 Marlas & 4 Kanals situated

in Mohala Islampura Aalia Town, Sukh Nahar, Mouza

Mehmood Booti, Near Band Road, Lahore vide

agreement dated 05-12-1984 & 28-12-1984 and since

than the plaintiff is enjoying the possession of the

land without any interfering.

3. That some day ago the defendant alongwith some

persons approached to the plaintiff at site and

threatened the plaintiff to dispossessed the plaintiff

forcibly. The plaintiff showed his agreement

/entitlement documents to the defendants.

4. That the plaintiff has been enjoying the possession for

the last 26 years without any interference, the

defendant has not adopted the legal process to resolve

the matter.

5. That the plaintiff has invested a huge amount on the

said land from his own pocket and if the defendant

has succeeded in his nefarious design the plaintiff

suffer an irreparable loss and injury, hence this suit.

6. That the cause of action accrued, in favour of the

plaintiff and against the defendant some days ago

when the defendant tried to dispose the plaintiff from

his owned land without any document, cogent reason

and justification and still is continuing.

7. That the parties reside in Lahore and cause of action

has also arisen here, therefore this learned court has

got jurisdiction to try and adjudicate upon this

matter.

8. That the prescribed court-fee has duly been affix on

the petition.

PRAYER:

Under the circumstances and submission

expounded above, it is therefore, humbly prayed that a

preliminary decree may very graciously be passed in favour

of the plaintiff and against the defendant, with a direction

to restrain the defendant to dispossessing the plaintiff from

the suit property/ land measuring 2 Kanals 2 Marlas &

4 Kanals situated in Sukh Nahar, Mouza Mehmood Booti,

Near Band Road, Lahore

 It is further prayed that during the pendency of

this suit, the defendant be permanently restrained from

disposing the plaintiff from the suit property/ land

measuring 2 Kanals 2 Marlas & 4 Kanals situated in

Mohala Islampura Aalia Town, Sukh Nahar, Mouza

Mehmood Booti, Near Band Road, Lahore.

Ad-interim status quo may also be ordered to be

maintained till the final decision of this suit.

Any other relief which this honourable court

deems fit and appropriate in favour of the plaintiff may also

be awarded. Cost of the suit may also be awarded.

Plaintif

Through:-

Mudaber Hussain Qureshi

Advocate High Court
127 - District Courts Lahore

VERIFICATION:
Verified on oath at Lahore on this 16th day of January
2012 that the contents of the Suit are true and correct to
the best of my knowledge, information and belief and
nothing has been concealed so far.
Plaintif