8/16/2019 THE ADVOCATE: Permanent Injunction

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THE ADVOCATE
CONVEYANCING, PLEADING AND DRAFTING

Thursday, October 4, 2012 Labels

10 (3) (1)

Permanent Injunction 12(2) (1)

17 (A) MFLO (1)
188 (1)
23-A (1) A.O (2)

IN THE COURT OF SR. CIVIL JUDGE 23-A A.O. (2)

249-A Dismissal of (1)

AT KARACHI EAST 324 (3)

34 PPC (2)
Civil Suit # /2012. 34 PPC. (1)
353 (2)
354 (2)
ASIM ALI ……………………………… PLAINTIFF 392/34 (1)
394 (2)
406 (2)
VERSUS 414 PPC (1)
416 (1)

1). Federation of Pakistan through 420 (2)

448/34 PPC (1)
Ministry of Defence, Pak 452 (1)

Secretariat-II, Rawalpindi. 468 (1)

471 (1)
506-B (4)
2). President Cantonment Board, Adoption Deed (1)
Faisal Cantt, Shahra.e. Faisal, Affidavit in Support of
APPLICATION U/O. 1
Karachi. RULE 10 CPC (2)
Affidavit in Support of
3). Cantonment Executive Offier, Application U/S. 12 (2)
CPC (2)
Cantonment Board Faisal Cantt, Affidavit in support of
Application U/S. 12(2)
Shahra.e. Faisal Karachi. CPC (1)
Agreement To Sell (1)

4). Syed AKBAR HUSSAIN and Permanent Injunction

(1)
son of Safdhar H. Zaidi, Appeal U/S. 22 of
Financial Institutions (1)
Muslim adult, resident of Flat #. 53,
Application for (1)
National Complex, Block 10-A, Application For
Amendment in Plaint (1)
Gulshan-e-Iqbal,
Application For
Karachi. ………..…………………… DEFENDANTS Amendment in The Plaint
(1)
Application for Ante-Date
Hearing (1)
Application for Issuance Of
SUIT FOR PERMANENT INJUNCTION No Objection Certificate
and Issuance of Form VII
(1)

The plaintiff, above named, submits as under:- Application for Restoration

of Service (1)
1. That the defendant No. 1 is Performa party and is constitutional Application for Status Quo
(1)
requirement to be cited, having controlling authority and Application for Substitute
Service (1)
supervising the affairs of the Cantonment Boards in all over the
Application For
country. Suspension of Judgment n
Decree (1)
Application for Validation of
2. That Mrs. Shamim Asghar Abbas w/o. Asghar Abbas who is Cheque (1)
Application To Exempt
exclusive owner of the Flat #. E-207, 2nd. Floor, Shamail Garden, Filling Certified FIR (2)
Application U/R. 110 Sindh
Gulistan-e-Johar, Block 19, Matan Road, Karachi, is relative of the Chief Court Ruled (1)

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8/16/2019 THE ADVOCATE: Permanent Injunction

plaintiff handed over the physical possession of the said FLAT Application U/S 345 (6)
Cr.P.C (1)
inducted the plaintiff to reside to look after, supervision, because Application U/S. 10(3)
SRPO 1979 (1)
she is residing abroad. The plaintiff is residing since June 2010, APPLICATION U/S. 12 (2)
CPC (1)
and regularly paying the utility bills of the said FLAT. Photocopy of
Application U/S. 12(2)
Utility Bills is annexed herewith and marked as Annexure “A” to “B”. CPC (1)
Application U/S. 17 (A) OF
THE MFL (1)
3. That since last one week from 20th. day of September 2012, the Application U/S. 17-A
Family Laws (1)
officials of defendant # 1 and 2 are coming at the door of plaintiff Application U/S. 249-A
Cr.PC (1)
along with defendant # 3 and directing to vacate the flat as the
Application U/S. 25 of
same belongs to the defendant # 4. Guardian and Ward Act
1890 (1)
Application U/S. 345 (2)
4. That the plaintiff showed all his documents regarding the flat but Cr.P.C (1)
Application U/S. 5 of
officials of defendant # 1 and 2 are not ready to understand the Limitation Act (1)
position but are bent upon to eject the plaintiff and his family from Application U/S. 7 & 8 G &
W Act (1)
the flat in question with the pretext that defendant #.4 is the owner Application Under Section
491 Cr.P.C (1)
and has right to get its possession as the officials are saying that Application under section 5
they have instruction from their Superior/Higher authorities and of Limitaion Act (1)
Arguments for
this task has been assigned to them. The plaintiff has sever Confirmation of Bail Before
Arrest (1)
apprehension that defendant # 3 on the bayonet of defendant # 1 B.A. 489-F (1)
and 2 will eject him for which they are not legally entitled. BA IN 452 (1)
Bail Appeal (1)
Bail Application (2)
5. That on 25-09-2012, defendant # 3 again came at the flat and
Bail Application in 13-D (1)
threatened that he has managed to out him with the help of Bail Application in 302
Case (1)
officials of the Cantonment Board. The defendant 1 and 2 in the Bail Application in
area have only powers on municipal point of view but the law has 324/384/511/506-B/ 34
PPC (1)
not delegated them judicial powers to be exercised and such Bail Application in 381A (2)
Bail Before Application in
directions are absolutely ab initio and liable to be struck down by 420 (1)
judicial verdict. Bail Before Arrest
Application in 489-F (1)
Bail Before Arrest
6. That the defendant # 3 along with staff of defendant # 1 and 2 Application in 504 (2)
Bail Before Arrest in 302
are coming to the site and harassing the plaintiff and his family (1)
and making attempts to get the possession of flat in question by Bail Before Arrest in 420
(1)
force. BBA IN 302/201/34/109
PPC (1)
C.P (1)
7. That the defendant # 1 to 3 have no authority under the law to
C.P. Salim (1)
take possession of the flat in question by force on gun point and Cancellation of Bail (1)

their act is liable to be checked and restrained being illegal. Cancellation of Documents
(2)
Civil Appeal (1)
8. That the defendant # 1 to 3 are permanently harassing and Civil Revision (1)

threatening the plaintiff to give possession of the flat in fact for Complaint against
Obnoxious Caller (1)
which no decree for handing over the possession has been Confirmation of Bail Before
Arrest (1)
passed from court of law but they are using illegal manners for Constitution Petition (4)
which law does not permit them. Constitution Petition
Mohsin (1)
CP For Demolishing Illegal
9. That the plaintiff rushed to the Town Police Officer but all efforts of Construction (1)
CP FRA (1)
the plaintiff ended in smoke when the Town Police Officer did not
Declaration (1)
pay any heed and replied to sue the responsible, hence present Dissolution of Marriage By
Way of Khula and
suit having no alternate. Maitenance Fatima (1)
Divorced Deed/Talaqnama
(1)
10. That the cause of action accused to the plaintiff against the
Dowry Articles (1)
defendants firstly on 20-09-2002, when officials of defendant # 1 Ex-Parte Proof (1)

and 2 came at flat along with defendant # 3 and attempted to take Execution Form (1)
Exempt Filling Certified
over the possession of the flat in question and the same remained Copy of FIR (1)

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to continue day to day till the filing of this civil suit within the local Exemption Filling Original
Document (1)
limits of police station Shahra-e-Faisal as the office as the office Family Appeal U/S. 14
SFCA (1)
of defendant # 1 and 2 situates therein and the same is within the General Power Of Attorney
(1)
territorial jurisdiction of this court.
Habeas Corpus Petition (1)
Injunction against
11. That suit for the purpose of jurisdiction the suit is valued at RS. Harassing (1)
Injunction for Due process
400/- and for the purpose of injunction is valued of RS. 200/-, for of law (1)

which no court fee is required to be affixed but this will be 1st Injunction vs KCBA (1)
Inspection of Nazir (1)
Class Civil Suit being a Government party. Intimation U/S. 7 MFLO
1961 (1)
Juvenile To Be Declared
PRAYER (1)
Khula (6)
The plaintiff, therefore, pray for judgment and decree in his favor and against the defendants as Khula and Dowry (1)
under:- Kula (1)
Lawyer’s Office for Sale (1)
a) To grant permanent injunction against the defendants their agents,
LEGAL NOTICE (3)
attorneys representative, assigns and all other person(s) working for Letter of
Administration/SMA (1)
them and on their behalf have no authority and power under the law
Maintenance (2)
to harass and black mail the plaintiff in any manner and use force for Maintenance And Dowry
Articles (1)
taking possession of Flat #. E-207, 2nd. Floor, Shamail Garden, Millat Town (1)

Gulistan-e-Johar, Block 19, Matan Road, Karachi, with out due Misc. CITATIONS (1)
MUBARAAT (1)
course of law. My Pictures (1)
O 37 (1)
b) To restrain the defendants, their agents, attorneys, representatives, O. 18 (1)
O. 37 (1)
assigns and all other person(s) working for them and on their behalf
O. 9 R. 4 (1)
perpetually from harassing and black mailing the plaintiff for taking O.1 (1)
Objections On Revocation
possession of Flat #. E-207, 2nd. Floor, Shamail Garden, Gulistan-e- Of SMA (1)

Johar, Block 19, Matan Road, Karachi, on gun point without due Objections on SMA (1)
Partnership Deed (2)
course of law. Permanent Inj.
Cantonment Board (1)

c) Any other equitable relief(s) which this Honorable Court deems fit Permanent Inj. Declaration
(1)
and proper under the circumstances of this suit. Permanent Inj. Tenancy (1)

Karachi. Permanent Injunction Asim

(1)
Dated : 29- 09-2012. Permission To Adduce
Evidence/Witnesses (1)
PLAINTIFF Private Complaint For
Registeration of FIR (1)
Proposed Issues (4)
Protective Bail Application
ADVOCATE (1)
R 2 (2)
R. 18 (1)
APPLICATION UNDER ORDER XXXIX RULE 1 & 2 R.10 CPC (1)
Recalling of Order (1)
R/W SECTION 151 CODE OF CIVIL PROCEDURE Recovery of Dowry Articles
and Maintenance (1)
On consideration of facts and grounds, incorporated in the accompanying affidavit, it is most Recovery of Gold
respect fully prayed on behalf of the plaintiff above named that this Honorable Court may be please to Ornaments (1)
restrain the defendants, their agents, attorneys, representatives, assigns and all other person(s) Reduction Of Surety
Amount (1)
working for them and on their behalf from harassing and black mailing the plaintiff for taking
Residential House for
possession of Flat #. E-207, 2nd. Floor,Shamail Garden, Gulistan-e-Johar, Block 19, Matan SALE (1)
Road, Karachi, on gun point without due course of law pending disposal of this suit. Restitution of Conjugal
Rights (1)
An ad interim injunction is to be solicited mean while in terms of Restraining To Transfer (1)
Sale Agreement Between
main prayer. Jamiluddin and Khadim (1)

Prayer is made most earnestly with clean hands in the interest of justice and equity. SALE DEED (1)
SMA (8)
Karachi. SMA Nephew (1)
Dated: 29-09-2012. Stay Against Sui S Gas
Co. (1)
ADVOCATE FOR THE PLAINTIFF SUCCESSION
CERTIFICATE Masih (1)

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Suit for Specific
Performance and
AFFIDAVIT Cancellation and
Permanent Injunction (1)
I, ASIM ALI son of Hashim Ali Naz , Muslim, adult, resident of Flat #. E-207, 2nd. Suit for Cancellation of
Floor,Shamail Garden, Gulistan-e-Johar, Block 19, Matan Road, Karachi, do hereby state on oath as Documents (1)
under:- Suit for Compensation of
Breach Of Contract And
1. That I am plaintiff in the above matter and am fully conversant with the Damages (1)
Suit for Declaration and
facts of this case and able to depose the same. Possession (1)
Suit for Dissolution of
2. That accompanying application for injunction under order 39 rule 1 & 2 Marriage By Way of Khula
(1)
Code of civil procedure has been drafted and filed by may counsel Suit For Dissolution Of
Marriage By Way Of Khula
under my specific instructions, contents there in are true and correct to (4)

the best of my knowledge, information and belief. Suit for Maintenance (2)
Suit for Recovery of
Amount (1)
3. That I have good prima facie case and balance of convenience lies in Suit for Recovery of
my favor and there is likelihood that, I shall win the case incarceration. Maintenance (1)
Suit for Recovery of
Maintenance and Dowery
4. That for the sake of brevity, I adopt the contents of accompanying Articles (1)

application as well as main plaint, as an integral part and parcel of this Suit for Recovery: Banking
Court (1)
affidavit and in order to avoid duplication do not repeat the same. Suit for Restitution of
Conjugal Rights (1)

5. That until the application is granted, I shall be seriously prejudiced and Suit for
Settlment/Rendition of
suffer an irreparable loss. Account (1)
Suit for Specific
Performance (1)
6. That whatever stated above is true and correct to the best of my SUMMON (1)
knowledge and belief. Suspension/Stay of
Auction (2)

Karachi. Tenancy Agreement (1)

TERMINATING AN
Dated: 29-09-2012. AGREEMENT:
UNSATISFACTORY
Deponent PRODUCT (1)
Undertaking (1)
The deponent above name is identified by me. Urgent Hearing During
Vacations (1)
Urgent Hearing in HC (3)
Vakalatnama (1)

ADVOCATE W/A 23-A (1) A.O. (2)

W/A 23-A (1) A.O. Toora
(1)
W/A 353 (1)
Will/Wasiat (1)
Posted by S.M. Zubair at 10:14 AM WILL/WASIATNAMA (1)
Labels: Permanent Injunction Asim Written Arguements B.B.A.
(1)
Written Arguements on
Application U/S. 12(2)
1 comment: CPC (2)
Written Arguments For
Criminal Trial (1)
Ali Awan February 10, 2018 at 2:12 AM ZUBAIR LAW
ASSOCIATES (1)
where is aplication of temporary injunction ??? kindly attached it sepretly. thankx
Reply
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