Saturday, March 21, 2015

DIRECTOR HUMAN RIGHTS ,TO KEEP ENTRY IN REVENUE RECORD OF PROPERTY






IN THE COURT OF DISTRICT JUDGE / DIRECTOR HUMAN RIGHTS GHOTKI
Misc: App: No.         2015


Muhammad Mithal S/o Abdul Rehman Panhwar
By profession an Advocate,
Resident of Village Abdul Rehman Panhwar near Ice Factory,
(Jalbani law chamber, lawyer’s street)
Taluka Miprur Mathelo District Ghotki ……………………………Applicant

V E R S U S

1.      Assistant Commissioner ( Revenue )
MiprurMathelo

2.      Mukhtiarkar,
MiprurMathelo

3.   Tapedar @ Tapa Miprur Deh Mirpur
  Taluka Mirpur Mathelo ………………………. Respondents


APPLICATION TO KEEP ENTRY IN REVENUE RECORD OF PROPERTY ADMEASURING 1-14 ACRES OUT OF S.NO: 126 (2-28) IN DEH MIRPUR TALUKA MIRPUR MATHELO AND ISSUANCE OF DEH FORM VII-B AS PER SALE DEED.



I the undersigned applicant state as under,

1.                  That I am the law abiding citizen of Pakistan and residing @ above address within this Honorable Court's jurisdiction.


2.         That we namely A. Mr. Muhammad Mithal S/o Abdul Rehman,                B)  Mr. Dilbar Hussain S/o Abdul Rehman & C) Mst. Ghulam Fatima w/o Abdul Rehman all by-caste Panhwar R/o village Abdul Rehman Panhwar Near By-pass Mirpur Mathelo were purchased the Property Admeasuring 1-14 Acres Out Of S.No: 126 (2-28) in Deh Mirpur Taluka Mirpur Mathelo from Mr.Abdul Rehman S/o Khamiso Khan by-caste Panhwar in the year 1999 through registered Sale Deed Entry Serial no. 2011 hours of 11 and 12 as on dated 24-12-1999& Registered No. 1833 at pages 168 to 175 volumes 370 book No. 1 Additional, Sub-Registrar Mirpur Mathelo as on dated 24-12-1999..

2.                  That I have approached too many times to the above all respondents for the entry of  property as per sale deed and issuance of Deh form VII-B  but every time I was returned back without keeping entry in revenue record because the respondents called for the bribe, for which I was & am unable to pay to above respondents. At least I moved the written application to the respondent 02 as on dated 04.02.2015 and respondent 02 forwarded my application to respondent 03 to keep entry in revenue record and issuance of Deh Form VII-b to me, but unfortunately respondent 03 after 20 days as on dated 23.02.2015 using his fun to collect bribe from me and he put note on my application that the sale deed is registered in old dates so the sale deed may be got verified from the concerned authorities. I went back to responded 02 for removing objection of respondent 03, respondent 02 moved letter to Sub Registrar Mirpur Mathelo for the verification as on dated 24.02.2015 as per letter no. ___________________ as on dated 2 .02.2015 Sub Registrar verified the sale deed and also confirm its genuineness.

3.                  That on dated 24.02.2015 I also moved the application to respondent 01 for the matter subject cited above, he forwarded my application to respondent no.02 to keep entry in revenue record.  

4.                  That on dated 04.03.2015 I got visit to respondents 02 and 03 to collect the Deh form VII-B of my property, but the respondent 03 given hopes. After that I went to respondent 02 and complained about this, he called respondent 03 and asked about this but respondent 03 arose many other objections before the respondent 02 to collect bribe from me against law, on that I asked and on my asking respondent no. 02 & 03 said for next day. I went back to the office of the respondent 02 & 03 as on dated 05.03.2015 but both flatly refused to keep entry without bribe. Same day as on dated 05.03.2015 I went back to respondent no.01 and complained for the said matter but he said that what I can do? I shocked on his answer and having hopeless.      


5.                  That the applicant has no other alternate remedy available except to appear before this Honorable Court and pray for the justice.

6.                  That the applicant therefore prays for the judgment, decree and directions to concerned authorities as under,

A.    This Honorable Court may be pleased issue directions/orders to respondent no.01 to 03 for issuance of Deh Form VII-B and to keep entry in revenue record as per verified registered Sale Deed.

B.     To award the other costs of the applicant for this case.

C.     Any other relief which this Honorable Court may deems fit and proper under the circumstances of this application.




Dated:                                              APPLICANT & ADVOCATE IN PERSON

Documents Filed
1. P.S copy of registered Sale Deed
2. P.S Copies of Applications to all respondents
3. P.S copy of verification of registered Sale Deed and its genuineness















IN THE COURT OF DISTRICT JUDGE / DIRECTOR HUMAN RIGHTS GHOTKI
Misc: App: No.         2015


Muhammad Mithal Panhwar     …………………………           Applicant

V E R S U S

Assistant Commissioner (Revenue)
Mirpur Mathelo & Others               ………………………         Respondents



A F F I D A V I T


I, Muhammad Mithal Panhwar s/o Abdul Rehman     by – caste Panhwar, by profession an Advocate, Resident of Village Abdul Rehman Panhwar, (Jalbani law chamber, lawyer’s street), near Ice Factory bypass, Taluka Miprur Mathelo District Ghotki do hereby state on oath as under,

1.                  That I am deponent in this affidavit and also applicant, hence well conversant with the facts of the case.

2.                  That the proposed respondents named in the application having influential persons and have committed to do not make entry as per registered Sale Deed.

3.                  That I am stated on oath that for the sake of brevity the contents of the application may kindly be treated as part of this affidavit.

4.                  That whatever is stated above is true and correct to the best of my knowledge and belief.


Verified and signed by me at Ghotki as on dated _____ day of March 2015






                                                                        D E P O N E N T



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