Application Under Oder 1 Rule 10 Saif-Ur-Rehman Vs Robina Ka

 

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 Ambreen Gul D/o Saif-u Saif-ur-Reh r-Rehman man Khan R/o R/o House No. No. 385/1 Street Street No. 2 Jaranwal Jaranwalaa Faisalabad. 2. Rashid Rashid Salman Salman Khan S/o S/o Saif-ur-R Saif-ur-Rehman ehman Khan Khan R/o House House No. No. 19 Brichkhi Brichkhi No. 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. Tha Thatt cap captio tioned ned Suit is pen pendin ding g for adjud adjudica icatio tion n bef before ore this learn learned ed court and next date is fixed 30.01.2010.

2. Tha Thatt the main Suit fil filed ed by the fathe fatherr of the appl applica icants nts rega regardi rding ng 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. Tha Thatt the defen defendan dantt is a rea reall mothe motherr of the ap appli plican cants ts who had nev never  er  any source to construct or buy such property.

4. Tha Thatt the defendan defendantt lod lodge ge FIR agai against nst the Pla Plaint intiff iff (Saif (Saif-ur -ur-Re -Rehma hman n Khan) Kha n) wh where ere in the the def defend endant ant for forces ces the app applic licant antss to sin sinee fal false se 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 Pla Plaintif intifff (Saif-ur(Saif-ur-Rehma Rehman n Khan) be being ing bus busy y in earni earning ng bread &  butter, made a benami registry in defendant’s favor so she could in  plaintiff’s 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. Th That at now the De Defe fend ndan antt rub rubin inaa ka kama mall is incl inclie iene ned d to sale out the  property in suit because she wants to deprive the applicants from their  shares whereas the applicants are not not willing to giving false ev evidence idence against agai nst thei theirr fathe fatherr plain plaintiff tiff hence this applicati application on 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 Saif-ur-Rehm an Khan

Vs

Robina Kamal

(Suit for Declaration and Permanent Injection)

3. 4.

Ambr Ambreen een Gul D/o Saif-urSaif-ur-Reh Rehman man Khan R/o House House No. 385 385/1 /1 Street Street No. 2 Jaranwala Jaranwala Faisalaba Faisalabad. d. Rash Rashid id Salman Salman Kh Khan an S/o S Saifaif-ur-R ur-Rehma ehman n Khan R R/o /o Hous Housee No. 19 B Brich richkhi khi No. 1 Umar Colony Colony Green Town, Lahore.

  Petitioners Vs Robina Kamal D/o Dilwar Dilwar Khan R/o Hou House se No. 19 Brich No.1 Umer Colony Green 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;  

Thatt the Contents Tha Contents of the ac accom compan panyin ying g petiti petition on are corre correct ct and true to the best of  dependant’s 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 Ambreen Gul D/o Saif-u Saif-ur-Reh r-Rehman man Khan R/o R/o House No. No. 385/1 Street Street No. 2 Jaranwal Jaranwalaa Faisalabad. 6. Rashid Rashid Salman Salman Khan S/o S/o Saif-ur-R Saif-ur-Rehman ehman Khan Khan R/o House House No. No. 19 Brichkhi Brichkhi No. 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 appli applicant cant has toda today y fi filled lled an aappli pplicatio cation n u under nder order 1 ru rule le 1 10in 0in

captio cap tioned ned sui suitt whi which ch is fix fixed ed for 3030-0101-201 2010 0 be before fore this hono honorab rable le court court,, the contents of which may kindly be read as an integral part of this application.

2)

Th That at tthe he ap appl plic ican antt has g got ot a pr prim imaa fac facie ie an and d go good od aarg rgua uabl blee ca case se in iits ts fa favo vor  r  and there is every likelihood of its success in the main suit.

3)

Tha Thatt the b bala alance nce o off con conven venien ience ce al also so li lies es in fav favor or of tthe he ap appli plican cant/p t/plai lainti ntiff. ff.

 

4)

Th That at in ccas ase, e, pe pend ndin ing g dec decis isio ion n of the ti titl tled ed su suit it,, if th thee app appli lica cant nt ma may y not b bee 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, th thee de defe fend ndan ant/ t/re resp spon onde dent nt ma may y kind kindly ly be rest restra rain ined ed fro from m ha haras rassi sing ng th thee  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 Saif-ur-Rehm an Khan

Vs

Robina Kamal

(Suit for Declaration and Permanent Injection)

7. 8.

Ambr Ambreen een Gul D/o Saif-urSaif-ur-Reh Rehman man Khan R/o House House No. 385 385/1 /1 Street Street No. 2 Jaranwala Jaranwala Faisalaba Faisalabad. d. Rash Rashid id Salman Salman Kh Khan an S/o S Saifaif-ur-R ur-Rehma ehman n Khan R R/o /o Hous Housee No. 19 B Brich richkhi khi No. 1 Umar Colony Colony Green Town, Lahore.

 

Petitioners Vs Robina Kamal D/o Dilwar Dilwar Khan R/o Hou House se No. 19 Brich No.1 Umer Colony Green 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;  

Thatt the Contents Tha Contents of the ac accom compan panyin ying g petiti petition on are corre correct ct and true to the best of  dependant’s 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