IN THE COURT OF JUDGE BANKING COURT, MULTAN.

Suit No. _________/2001

House Building Finance Corporation, Head Office 3rd Floor, Finance

and Trade Centre, Shahrah-e-Faisal, Karachi, through its District
Manager, H.B.F.C. District Ofifce, Vehari.
PLAINTIFF
VERSUS
Ghulam Asghar S/o Ghulam Sarwar, R/o House No. 538/3, Yaqoob
Abad, Burewala, District Vehari.
DEFENDANT

Suit for recovery of account of Rs.

168,683/- and also rental share, insurance
premium and demand charges etc. of the
H.B.FC. till full and final payment of
recovery of outstanding balance by sale of
mortgaged/assigned property mentioned
in para No. 3 of the plaint and from the
present and other assets of the defendant.

Respectfully Sheweth: -

1. That plaintiff’s corporation is a statutory body constituted

under House Building Finance Corporation Act, XVIII, 1952
and is a financial institution as defined in Financial
Institutions (Recovery of Finances) Ordinance 2001, presently
having its Head Office at Karachi and District Offices at other
places of Pakistan including one of its office at Vehari. The
District Manager, Vehari being its District Manager is
authorised to institute the present suit signed, verify pleadings,
to do such acts which are necessary and incidental thereto
 being conversant with the facts of the case and is able to
depose about the fate.

2. That the plaintiff provides financial facilities on partnership

basis for the construction and purchase of house/building in
Pakistan in terms of Act XVIII, 1952 and Rules & Regulations
made thereunder.

3. That the defendant availed investment of original Rs.

100,000/- on 6.2.89 from the plaintiff to construct the house
on Khasra No. 59/8, Khewat No. 43/41, Khatooni No. 182 to
190, measuring 6 Marlas situated in Chak No. 439/EB,
Burewala, through case file No. HFS. VEH 946, Account No.
43100152-79 on the terms and conditions as set out in
Registered Deed of assigned and Partnership (hereinafter
called “Assignment Deed”) executed by the defendant on
6.2.1989 in the office of Sub-Registrar Burewala under the
provision of H.B.F.C. Act XVIII, 1952 and the Rules and
Regulations made thereunder. An attested copy of Registered
Assignment Deeds are filed herewith and marked as Annexes
“A & B”. The assigned property is bounded as under: -
North: Street
South: House of Fazal Hussain
East: Self land
West: House of Dur Muhammad

4. That the defendant had to pay the said investment to the

plaintiff in monthly installments of Rs. 1103/- per month
initially, regularly and terms of the said Registered Deed of
Assignment and Partnership, but he did not regularly pay the
same inspite of issuance of legal notices by the plaintiff and
till 31.8.2001 has paid only Rs. 71,109/-, detail of which is as
follows: -
Date Amount
31.1.1994 Rs. 10,000/-
13.11.1994 Rs. 28,109/-
28.3.1996 Rs. 23,000/-
17.2.1999 Rs. 10,000/-
5. That on account of breach of terms and conditions of the said
Registered Assignment Deed, the plaintiff has become entitled
to recall the entire balance of investment including share of
the corporation, insurance premium and demand charges from
the defendant, which comes to Rs. 168,683/- till 31.8.2001
and this outstanding amount consists of Rs. 55,244/- rental
share, Rs. 2,883/- insurance premium, Rs. 10,556/- Demand
charges Rs, 100,000/- principal, outstanding against the
defendant.

6. That the defendant has failed to repay the above balance

amount to the plaintiff whereby he has committed breach of
the terms & conditions of the Registered Assignment Deed in
the payment of monthly installments with a share of the
Corporation and Demand charges and as stated above amount
of Rs. 168,683/- till 31.8.2001 outstanding against the
defendant.

7. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on when the period
of final notice dated expired and the defendant
failed to repay the above said investment and share of the
Corporation of the plaintiff.

8. That the value for the purpose of court fee and jurisdiction is
Rs. 168,683/- and a court fee of Rs. 12,652/- has been affixed
and paid.
It is therefore, respectfully prayed that: -
a) A decree be passed in favour of the plaintiff against the
defendant for the recovery of Rs. 379,686/- along-with
Demand Charges, Insurance premium and rental share
etc. of H.B.F.C. from July 2000 till full and final
recovery by the delivery of vacant possession and sale
of the house/building construction on the aforesaid
property/plot on Khasra No. 59/8, Khewat No. 43/41,
Khatooni No. 182 to 190, measuring 6 Marlas situated
in Chak No. 439/EB, Tehsil Burewala District Vehari
 mentioned in the registered Deeds of Assignment and
Partnership, having Book No. 212, Book No. 1, Volume
74, page 64 dated 6.2.1989 executed before the Sub-
Registrar Burewala, which is already assigned with the
plaintiff under terms and conditions of the above-
mentioned Deed of Assignment and partnership.
b) In case the decretal amount is not satisfied by the sale
of mortgaged/assigned property, a decree for the
balance amount may also be passed in favour of the
plaintiff H.B.F.C. against the person and other assets/
properties of the defendant.
c) An injunction restraining the defendant and every body
claiming through from or under him in any manner,
transferring or dispossessing of the same above
mentioned property.
d) Ad-interim attachment of the said property and the plot
mentioned above.
e) Cost of the suit also be awarded.
Any other relief warranted by the facts and
circumstances of the case, may also be granted.
Plaintiff,
Dated: ________
H.B.F.C.
Through: - its District Manager,
Vehari

Through: -
(SAEED HASSAN HASHMI),
Advocate High Court,
40-Aziz Block,
District Courts, Multan.

VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff
 IN THE COURT OF JUDGE BANKING COURT, MULTAN.

Suit No. _________/2001

House Building Finance Corporation, Head Office 3rd Floor, Finance

and Trade Centre, Shahrah-e-Faisal, Karachi, through its District
Manager, H.B.F.C. District Ofifce, Vehari.
PLAINTIFF
VERSUS
Abdul Raoof S/o Muhammad Jamil, R/o (i) Nalee Cotton Factory,
Burewala, (ii) Chak no. 439/EB, Shadman Colony, Burewala.
DEFENDANT

Suit for recovery of Rs. 116,204/- and also

rental share, insurance premium and
demand charges etc. of the H.B.FC. till full
and final payment of recovery of
outstanding balance by sale of
mortgaged/assigned property mentioned
in para No. 3 of the plaint and from the
present and other assets of the defendant.

Respectfully Sheweth: -
1. That plaintiff’s corporation is a statutory body constituted under
House Building Finance Corporation Act, XVIII, 1952 and is a
financial institution as defined in Financial Institutions (Recovery
of Finances) Ordinance 2001, presently having its Head Office at
Karachi and District Offices at other places of Pakistan including
one of its office at Vheari. The District Manager, Vehari being its
District Manager is authorised to institute the present suit signed,
verify pleadings, to do such acts which are necessary and
 incidental thereto being conversant with the facts of the case and
is able to depose about the fate.

2. That the plaintiff provides financial facilities on partnership basis

for the construction and purchase of house/building in Pakistan in
terms of Act XVIII, 1952 and Rules & Regulations made
thereunder.

3. That the defendant availed investment of Rs. 60,000/- on 14.5.89

from the plaintiff to construct the house on Khasra No. 65/6,
Khewat No. 16/13, Khatooni No. 47, measuring 1995 Sq. feet,
situated in Shadman Colony, Burewala, through case file No.
HFS-VEH-995. Account No. 34100194-95 on the terms and
conditions as set out in Registered Deed of assigned and
Partnership (hereinafter called “Assignment Deed”) executed by
the defendant on 14.5.1989 in the office of Sub-Registrar
Burewala under the provision of H.B.F.C. Act XVIII, 1952 and
the Rules and Regulations made thereunder. An attested copy of
Registered Assignment Deeds are filed herewith and marked as
Annexes “A & B”. The assigned property is bounded as under: -
North: Street
South: Plot of Abbas S/o Nazar Muhammad
East: Main Street
West: House of Muhammad Iftikhar

4. That the defendant had to pay the said investment to the plaintiff
in monthly installments of Rs. 619/- per month initially, regularly
and terms of the said Registered Deed of Assignment and
Partnership, but he did not regularly pay the same inspite of
issuance of legal notices by the plaintiff. The defendant has made
the payment of Rs. 16,000/- till 31.8.2001, detail of which is as
follows: -

Date Amount
23.5.1991 Rs. 5,000/-
28.11.1996.1Rs. 6,000/-
14.1.1997 Rs. 5,000/-
5. That on account of breach of terms and conditions of the said
Registered Assignment Deed, the plaintiff has become entitled to
 recall the entire balance of investment including share of the
corporation, insurance premium and demand charges from the
defendant, which comes to Rs. 114,160/- till 31.5.2001 and this
amount includes Rs. 44,248/- towards rental income Rs. 3082/-
for insurance premium Rs. 7,040/- for Demand dcharges and Rs.
5997901 for principal amount till 31.5.2001.
6. That the defendant has failed to repay the above balance amount
to the plaintiff whereby he has committed breach of the terms &
conditions of the Registered Assignment Deed in the payment of
monthly installments with a share of the Corporation and
Demand charges and as stated above amount of Rs. 116,209/- till
31.8.2001 are outstanding against the defendant and this amounts
consists of Rs. 46,036/- rental shares Rs. 3,163/- insurance
premium, Rs. 7,220/- demand charges and Rs. 59,790/- principal
amount, outstanding against the defendnat.
7. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on 2.7.2000 when the period of
final notice dated expired and the defendant failed to
repay the above said investment and share of the Corporation of
the plaintiff.
8. That the value for the purpose of court fee and jurisdiction is Rs.
116,209/- and a court fee of Rs. 8,720/- has been affixed and
paid.
It is therefore, respectfully prayed that: -
a) A decree be passed in favour of the plaintiff against the
defendant for the recovery of Rs. 116,209/- along-with
Demand Charges, Insurance premium and rental share etc.
of H.B.F.C. from 31.8.2001 till full and final recovery by
the delivery of vacant possession and sale of the
house/building construction on the aforesaid property/plot
on Khasra No. 65/6, Khewat No. 16/13, Khatooni No. 47,
measuring 1995 Sq. feet situated in Chak No. 439/EB,
Tehsil Burewala, District Vehari, mentioned in the
registered Deeds of Assignment and Partnership, Deed No.
904, Book No. 1, Volume 74, dated 14.5.89 executed
 before the Sub-Registrar Burewala, which is already
assigned with the plaintiff under terms and conditions of
the above-mentioned Deed of Assignment and partnership.
b) In case the decretal amount is not satisfied by the sale of
mortgaged/assigned property, a decree for the balance
amount may also be passed in favour of the plaintiff
H.B.F.C. against the person and other assets/ properties of
the defendant.
c) An injunction restraining the defendant and every body
claiming through from or under him in any manner,
transferring or dispossessing of the same above mentioned
property.
d) Ad-interim attachment of the said property and the plot
mentioned above.
e) Cost of the suit also be awarded.
Any other relief warranted by the facts and
circumstances of the case, may also be granted.
Plaintiff,
Dated: ________
H.B.F.C.
Through: - its District Manager,
Vehari

Through: -
(SAEED HASSAN HASHMI),
Advocate High Court,
40-Aziz Block,
District Courts, Multan.

VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff
IN THE COURT OF JUDGE BANKING COURT, MULTAN.
 Suit No. _________/2001

House Building Finance Corporation, Head Office 3rd Floor, Finance

and Trade Centre, Shahrah-e-Faisal, Karachi, through its District
Manager, H.B.F.C. District Ofifce, Vehari.
PLAINTIFF
VERSUS
Abdul Jabbar S/o Mahmood-ul-Hassan R/o House No. 137, Chak
No. 41-WB, Danewal District Vehari.
DEFENDANT

Suit for recovery of Rs. 188,656/- upto Rs.

31.8.2001 and also rental share, insurance
premium and demand charges etc. of the
H.B.FC. till full and final payment of
recovery of outstanding balance by sale of
mortgaged/assigned property mentioned
in para No. 3 of the plaint and from the
present and other assets of the defendant.

Respectfully Sheweth: -

1. That plaintiff’s corporation is a statutory body constituted under

House Building Finance Corporation Act, XVIII, 1952 and is a
financial institution as defined in Financial Institutions (Recovery
of Finances) Ordinance 2001, presently having its Head Office at
Karachi and District Offices at other places of Pakistan including
one of its office at Multan. The District Manager, Multan being
its District Manager is authorised to institute the present suit
signed, verify pleadings, to do such acts which are necessary and
incidental thereto being conversant with the facts of the case and
is able to depose about the fate.
2. That the plaintiff provides financial facilities on partnership basis
for the construction and purchase of house/building in Pakistan in
terms of Act XVIII, 1952 and Rules & Regulations made
thereunder.

3. That the defendant availed investment of Rs. 90,000/- on

15.5.1990 from the plaintiff to construct the house on plot No.
137, Khewat No. 34, Khatooni No. 34, measuring 4 Marlas
situated in Chak No. 41WB Danewal Vehari, through case file
No. HFS-VEH-1105. Account No. 74100289-75 on the terms and
conditions as set out in Registered Deed of assigned and
Partnership (hereinafter called “Assignment Deed”) executed by
the defendant on 15.5.1990 in the office of Sub-Registrar Vehari
under the provision of H.B.F.C. Act XVIII, 1952 and the Rules
and Regulations made thereunder. An attested copy of Registered
Assignment Deeds are filed herewith and marked as Annexes “A
& B”. The assigned property is bounded as under: -

North: Self House

South: Plot of Talib Hussain, Tahir Hussain
East: Self house
West: Road

4. That the defendant had to pay the said investment to the plaintiff
in monthly installments of original Rs. 1229/- per month initially,
regularly and terms of the said Registered Deed of Assignment
and Partnership, but he did not regularly pay the same inspite of
issuance of legal notices by the plaintiff. The defendant made
only the payment of Rs. 54,800/- till 31.8.2001 and the detail of
which is as follows: -

Date Amount
29.12.94 Rs. 10,000/-
8.1.95 Rs. 2,500/-
18.12.95 Rs. 2,000/-
2.6.96 Rs. 3,000/-
18.11.97 Rs. 2,000/-
15.12.97 Rs. 1,500/-
 16.7.98 Rs. 1,500/-
26.9.98 Rs. 5,000/-
27.1.99 Rs. 1,000/-
20.2.99 Rs. 1,800/-
19.3.99 Rs. 1,500/-
13.4.99 Rs. 1,500/-
26.5.99 Rs. 1,500/-
1.7.99 Rs. 1,000/-
23.9.99 Rs. 5,000/-
12.7.2000 Rs. 5,000/-
23.8.2000 Rs. 1,500/-
14.9.2000 Rs. 1,000/-
18.10.2000 Rs. 1,500/-
20.12.2000 Rs. 1,500/-
10.2.2001 Rs. 1,000/-
18.3.2001 Rs. 1,000/-

5. That on account of breach of terms and conditions of the said

Registered Assignment Deed, the plaintiff has become entitled to
recall the entire balance of investment including share of the
corporation, insurance premium and demand charges from the
defendant, which comes to Rs. 188,656/- till 31.8.2001 and this
amount consists of Rs. 70,414/- rental share, Rs. 5,754/-
principal, outstanding against the defedant.

6. That the defendant has failed to repay the above balance amount
to the plaintiff whereby he has committed breach of the terms &
conditions of the Registered Assignment Deed in the payment of
monthly installments with a share of the Corporation and
Demand charges and as stated above amount of Rs. 188,656/-
still outstanding against the defendants till 31.8.2001.

7. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on when the period
of final notice dated expired and the defendant failed to
repay the above said investment and share of the Corporation of
the plaintiff.

8. That the value for the purpose of court fee and jurisdiction is Rs.
188,656/- and a court fee of Rs. 1450/- has been affixed and paid.
 It is therefore, respectfully prayed that: -

a) A decree be passed in favour of the plaintiff against the

defendant for the recovery of Rs. 188,656/- along-with
Demand Charges, Insurance premium and rental share etc.
of H.B.F.C. from 31.8.2001 till full and final recovery by
the delivery of vacant possession and sale of the
house/building construction on the aforesaid property/plot
on Plot No. 137, Khewat No. 34, Khatooni No. 34,
measuring 4 Marlas situated in Chak No. 41-WB, Danewal
Vehari mentioned in the registered Deeds of Assignment
Partnership Deed No. 587, Book No. 1, Volume 182, page
227, dated 15.5.1990, executed before the Sub-Registrar
Vehari, which is already assigned with the plaintiff under
terms and conditions of the above-mentioned Deed of
Assignment and partnership.

b) In case the decretal amount is not satisfied by the sale of

mortgaged/assigned property, a decree for the balance
amount may also be passed in favour of the plaintiff
H.B.F.C. against the person and other assets/ properties of
the defendant.

c) An injunction restraining the defendant and every body

claiming through from or under him in any manner,
transferring or dispossessing of the same above mentioned
property.

d) Ad-interim attachment of the said property and the plot

mentioned above.

e) Cost of the suit also be awarded.

Any other relief warranted by the facts and

circumstances of the case, may also be granted.

Plaintiff,
Dated: ________
H.B.F.C.
 Through: - its District Manager,
Vehari

Through: -
(SAEED HASSAN HASHMI),
Advocate High Court,
40-Aziz Block,
District Courts, Multan.

VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff

IN THE COURT OF JUDGE BANKING COURT, MULTAN.

Suit No. _________/2001

House Building Finance Corporation, Head Office 3rd Floor, Finance
and Trade Centre, Shahrah-e-Faisal, Karachi, through its District
Manager, H.B.F.C. District Ofifce, Vehari.
PLAINTIFF
VERSUS
Muhammad Ramzan S/o Islam-ud-Din, R/o Ward No. 5, Mohallah
Tillo Pura, Mailsi, District Vehari.
DEFENDANT

Suit for recovery of Rs. 123,998/- upto

31.8.2001 and also rental share, insurance
premium and demand charges etc. of the
H.B.FC. till full and final payment of
recovery of outstanding balance by sale of
mortgaged/assigned property mentioned
in para No. 3 of the plaint and from the
present and other assets of the defendant.

Respectfully Sheweth: -
1. That plaintiff’s corporation is a statutory body constituted under
House Building Finance Corporation Act, XVIII, 1952 and is a
financial institution as defined in Financial Institutions (Recovery
of Finances) Ordinance 2001, presently having its Head Office at
Karachi and District Offices at other places of Pakistan including
one of its office at Vehari. The District Manager, Vehari being its
District Manager is authorised to institute the present suit signed,
verify pleadings, to do such acts which are necessary and
incidental thereto being conversant with the facts of the case and
is able to depose about the fate.
2. That the plaintiff provides financial facilities on partnership basis
for the construction and purchase of house/building in Pakistan in
terms of Act XVIII, 1952 and Rules & Regulations made
thereunder.
3. That the defendant availed investment of Rs. 60,000/- on
16.12.87 from the plaintiff to construct the house of Khasra No.
58/14/1, Khewat No. 103 black, 97 red, Khatooni No. 138,
 measuring 12 Marlas situated in Ward No. 5, Mailsi, through case
file No. HFS/VEH-796. Account No. 34100003-12 on the terms
and conditions as set out in Registered Deed of assigned and
Partnership (hereinafter called “Assignment Deed”) executed by
the defendant on 21.12.1987 in the office of Sub-Registrar Mailsi
under the provision of H.B.F.C. Act XVIII, 1952 and the Rules
and Regulations made thereunder. An attested copy of Registered
Assignment Deeds are filed herewith and marked as Annexes “A
& B”. The assigned property is bounded as under: -
North: Street
South: Old Bhatta
East: Vacant plot
West: Agricultural land
4. That the defendant had to pay the said investment to the plaintiff
in monthly installments of Rs. 608/- per month initially, regularly
and terms of the said Registered Deed of Assignment and
Partnership, but he did not regularly pay the same inspite of
issuance of legal notices by the plaintiff. The defendant made the
payment of Rs. 18,000/- till 31.8.2001, detail of which is as
follows: -
Date Amount
27.2.91 Rs. 4,000/-
22.5.91 Rs. 4,000/-
22.12.91 Rs. 4,000/-
23.12.92 Rs. 4,000/-
21.1.97 Rs. 2,000/-
5. That on account of breach of terms and conditions of the said
Registered Assignment Deed, the plaintiff has become entitled to
recall the entire balance of investment including share of the
corporation, insurance premium and demand charges from the
defendant, which comes to Rs. 123,998/- till 31.8.2001 and this
amount includes Rs. 51,380/- rental share, Rs. 3,888/- insurance
premium, Rs. 8,730/- demand charges and Rs. 60,000/- principal
amount, outstanding against the defendant.
6. That the defendant has failed to repay the above balance amount
to the plaintiff whereby he has committed breach of the terms &
conditions of the Registered Assignment Deed in the payment of
monthly installments with a share of the Corporation and
 Demand charges and as stated above amount of Rs. 123,998/- till
31.8.2001.
7. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on when the period
of final notice dated expired and the defendant failed to
repay the above said investment and share of the Corporation of
the plaintiff.
8. That the value for the purpose of court fee and jurisdiction is Rs.
123,998/- and a court fee of Rs. 9,300/- has been affixed and
paid.
It is therefore, respectfully prayed that: -
a) A decree be passed in favour of the plaintiff against the
defendant for the recovery of Rs. 123,998/- along-with
Demand Charges, Insurance premium and rental share etc.
of H.B.F.C. from 31.8.2001 till full and final recovery by
the delivery of vacant possession and sale of the
house/building construction on the aforesaid property/plot
on Khasra No. 58/14/1, Khewat No. 103 black, 97 red,
Khatooni No. 138, measuring 12 Marlas situated in Ward
No. 5, Mohallah Tillo Pura, Mailsi, mentioned in the
registered Deeds of Assignment and Partnership Deed No.
1831, Book No. 1, Volume 200, dated 21.12.87, executed
before the Sub-Registrar Mailsi, which is already assigned
with the plaintiff under terms and conditions of the above-
mentioned Deed of Assignment and partnership.
b) In case the decretal amount is not satisfied by the sale of
mortgaged/assigned property, a decree for the balance
amount may also be passed in favour of the plaintiff
H.B.F.C. against the person and other assets/ properties of
the defendant.
c) An injunction restraining the defendant and every body
claiming through from or under him in any manner,
transferring or dispossessing of the same above mentioned
property.
 d) Ad-interim attachment of the said property and the plot
mentioned above.
e) Cost of the suit also be awarded.
Any other relief warranted by the facts and
circumstances of the case, may also be granted.
Plaintiff,
Dated: ________
H.B.F.C.
Through: - its District Manager,
Vehari

Through: -
(SAEED HASSAN HASHMI),
Advocate High Court,
40-Aziz Block,
District Courts, Multan.

VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff

IN THE COURT OF JUDGE BANKING COURT, MULTAN.

Suit No. _________/2001

House Building Finance Corporation, Head Office 3rd Floor, Finance

and Trade Centre, Shahrah-e-Faisal, Karachi, through its District
Manager, H.B.F.C. District Ofifce, Suleman Plaza, near Chungi
No. 9, Multan.
PLAINTIFF
 VERSUS
Mumtaz Ahmad S/o Haji Khuda Bakhsh, R/o House No. 538/91,
Mohallah Islam Pura, Mailsi, District Vehari.
DEFENDANT

Suit for recovery of Rs. 348,613/- upto

31.8.2001 and also rental share, insurance
premium and demand charges etc. of the
H.B.FC. till full and final payment of
recovery of outstanding balance by sale of
mortgaged/assigned property mentioned
in para No. 3 of the plaint and from the
present and other assets of the defendant.

Respectfully Sheweth: -
1. That plaintiff’s corporation is a statutory body constituted under
House Building Finance Corporation Act, XVIII, 1952 and is a
financial institution as defined in Financial Institutions (Recovery
of Finances) Ordinance 2001, presently having its Head Office at
Karachi and District Offices at other places of Pakistan including
one of its office at Vehari. The District Manager, Vehari being its
District Manager is authorised to institute the present suit signed,
verify pleadings, to do such acts which are necessary and
incidental thereto being conversant with the facts of the case and
is able to depose about the fate.
2. That the plaintiff provides financial facilities on partnership basis
for the construction and purchase of house/building in Pakistan in
terms of Act XVIII, 1952 and Rules & Regulations made
thereunder.
3. That the defendant availed investment of original Rs. 200,000/-
on 9.2.1994 from the plaintiff to construct the house on plot
having Khewat No. 471/448, Khatooni No. 557 to 583,
measuring 0—15 Marlas situated in Mohallah Islam Pura, Mailsi
District Vehari, through case file No. VEH-1344, Account No.
74100484-45 on the terms and conditions as set out in Registered
Deed of assigned and Partnership (hereinafter called
 “Assignment Deed”) executed by the defendant on 10.2.1994 in
the office of Sub-Registrar Mailsi, under the provision of
H.B.F.C. Act XVIII, 1952 and the Rules and Regulations made
thereunder. An attested copy of Registered Assignment Deeds are
filed herewith and marked as Annexes “A & B”. The assigned
property is bounded as under: -
North: Street
South: House of Haji Akhtar Gul Muhammad
East: Street
West: Street
4. That the defendant had to pay the said investment to the plaintiff
in monthly installments of Rs. 3295/- per month initially,
regularly and terms of the said Registered Deed of Assignment
and Partnership, but he did not regularly pay the same inspite of
issuance of legal notices by the plaintiff. The defendant has made
the payment of Rs. 70,300/- till 31.8.2001, detail of which is as
follows: -
Date Amount
28.3.95 Rs. 3,300/-
12.6.95 Rs. 6,700/-
22.6.95 Rs. 3,300/-
31.7.95 Rs. 5,000/-
30.11.96 Rs. 10,000/-
20.12.97 Rs. 30,000/-
7.10.98 Rs. 12,000/-
5. That on account of breach of terms and conditions of the said
Registered Assignment Deed, the plaintiff has become entitled to
recall the entire balance of investment including share of the
corporation, insurance premium and demand charges from the
defendant, which comes to Rs. 348,613/- till 31.8.2001 and this
outstanding amount includes Rs. 131,825/- renatal share, Rs.
6,930/- insurance, Rs. 8,600/- demand charges, Rs. 12,393/-
service charges and Rs. 188,865/- principal.
6. That the defendant has failed to repay the above balance amount
to the plaintiff whereby he has committed breach of the terms &
conditions of the Registered Assignment Deed in the payment of
monthly installments with a share of the Corporation and
 Demand charges and as stated above amount of Rs. 348,613/- till
31.8.2001.
7. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on 2.7.2000 when the period of
final notice expired defendant failed to repay the above said
investment and share of the Corporation of the plaintiff.
8. That the value for the purpose of court fee and jurisdiction is Rs.
348,613/- and a court fee of Rs. 15,000/- has been affixed and
paid.
It is therefore, respectfully prayed that: -
a) A decree be passed in favour of the plaintiff against the
defendant for the recovery of Rs. 348,613/- along-with
Demand Charges, Insurance premium and rental share etc.
of H.B.F.C. from 31.8.2001 till full and final recovery by
the delivery of vacant possession and sale of the
house/building construction on the aforesaid property/plot
on Khewat No. 471/448 Khatooni No. 577 to 583,
measuring 0—15 Marlas situated in Mohallah Islam Pura,
Mailsi, District Vehari, mentioned in the registered Deeds
of Assignment and Partnership Deed No. 254, Book No. 1,
Volume 208, dated 10.2.94 executed before the Sub-
Registrar Mailsi, which is already assigned with the
plaintiff under terms and conditions of the above-
mentioned Deed of Assignment and partnership.
b) In case the decretal amount is not satisfied by the sale of
mortgaged/assigned property, a decree for the balance
amount may also be passed in favour of the plaintiff
H.B.F.C. against the person and other assets/ properties of
the defendant.
c) An injunction restraining the defendant and every body
claiming through from or under him in any manner,
transferring or dispossessing of the same above mentioned
property.
 d) Ad-interim attachment of the said property and the plot
mentioned above.
e) Cost of the suit also be awarded.
Any other relief warranted by the facts and
circumstances of the case, may also be granted.
Plaintiff,
Dated: ________
H.B.F.C.
Through: - its District Manager,
Vehari

Through: -
(SAEED HASSAN HASHMI),
Advocate High Court,
40-Aziz Block,
District Courts, Multan.

VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff

TO WHOM IT MAY CONCERN.

It is certified that in case titled H.B.F.C. Vs.

H.B.F.C. case file No.

A/c No. which will be filed

before the Judge Banking Court, Multan, fee with Mr. SAEED

HASSAN HASHMI Advocate High Court/Legal Advisor

H.B.F.C. is settled as Rs. 4,000/- + Rs. 500/- (miscellaneous

expenses charges) total Rs. 4,500/-.

District Manager,
H.B.F.C.
District Office _________