SUIT FOR RECOVERY OF AMOUNT

IN THE COURT OF DISTRICT & SESSION JUDGE GHOTKI

Letter of Administration Petition NO:/2015

Muhammad MithalPanhwar

Byprofessionan Advocate,

Resident of Village Abdul RehmanPanhwar

(Jalbani law chamber, lawyer’s street)

TalukaMiprurMathelo District Ghotki ……………………………Petitioner

VERSUS

1                    abc

2                    def

allmuslims, adult, by caste soomro

r/omirpurtalukamirpurdistricGhotki…………………. .… Respondents

SUIT FOR RECOVERY OF AMOUNT RS 150340-00 ONLY

The plaintiff above named respectfully begs to submit as under:

1.                  That the plaintiff is proprietor of M/S Iqbal service station, mirpurmathelo.

2.                  That the plaintiff has supply the POL to government vehicle no. E-0165 as per letter bearing no -------- dated ------ issued by the defendant no.1

3.                  That the since 31.3.2009 to 28.10.2011 the defendant no.1 had taken the petrol and Mobil, oil total rs 522829 out of where defendant no.1 paid the bill rs.372489- in the shape of different cheques of nbpmirpurmathelo, further complete detailed is given below.

4.                  That after last payment the defendant no.1 had not paid the remaining due amount rs 150340- to the plaintiff and kept the plaintiff on false hopes.

5.                  That due to nonpayment the plaintiff stopped to supply the pol to the defendant no.1 and request to the defendant no.1  that when defendant no.1  paid the full amount after that further fuel will be supply as settled terms and conditions, on that defendant no.1 requested that as the fund will be released by his higher officer that total bill be paid.

6.                  That the plaintiff approached time to time to the office of the defendant no.1 and requested to him who was on the seat that due amount rs 150340- may be paid on that defendant no.2 repeated requested that some time may be granted to them as they approached to the higher authorities and after release of amount that total bill will be cleared, but defendant no.1 not paid the due amount rs 150340 and kept the plaintiff on false hopes.

7.                  That on 9.6.2012 the legal notice has been issued by the advocate of the plaintiff and requested for payment of due amount rs 150340- but the defendant no.1 had not pay in intention and had not made reply of legal notice and such copies of legal notice also send to the defendant no.2 to 4 head of defendant no.1 for information and taking legal action but no fruitful result became.

8.                  That in august 2013 plaintiff once again went to office of the defendant no.1 and requested to the defendant no.1 that plaintiff is facing many problems due to nonpayment of the amount that defendant no.1 flatly refused to the plaintiff that due amount will not be paid in any manner.

9.                  That on 5.3.2014 the reminders of legal notice has been issued by the counsel for the plaintiff to the defendant no.1 but till time no any reply has been submitted by the defendant no.1

10.               That the defendants no. 2 to 4 are performing duty as head of the defendant no.1

11.              That the cause of action accrued to the plaintiff for filling of the present suit firstly on 28.10.2011 when defendant has paid last payment, secondly on dated----- when defendant no.1 flatly refused from payment of due amount rs 150340- and lastly on 5.3.2014 when reminder of legal notice has been issued and no reply has been submitted by the defendant no.1 , it will remain continue till the grievances are over.

12.              That the suit for the purpose of court fee i-e rs 150340 for the relief of recovery, hence required court fees stamp worth rs 4200 is attached herewith.

13.              That the plaintiff, therefore prays for judgment and decree as under:-

P R A Y E R S

a.             To direct the defendant no.1 through the decree of this honorable court to pay the remaining due amount rs 150340-alogn with markup as per law to the plaintiff without any further inordinate delay or process procrassumation

b.            To award the cost for the suit.

c.             To grant any other relief which this honorable court deems fit and proper in the circumstances of the case.

--------------------

P L A I N T I FF

                 

VERIFICATION

I haji  mm s/o mmm bycaste mughul r/o town mpm district ghotki, do hereby verify on oath that contents of the contents of the plaint from Para no.1 to 15 is true and  correct to the best of knowledge , belief and information.

                  Verified and signed by me at mmathelo

                  This 7 day of feb 2015.

D E P O N E N T

Identified by me

Advocate

DOCUMENTS FILED.

1.                  Ps copy of legal notice dated

2.                  PS copy of reminder of legal notice dated.

3.                  Ps copies of receipts of tcs

4.                  Ps copies of bills and slips of tcs issued by the defendant no.1( 13 in numbers)

DOCUMENTS RELIED UPON.

Any other relevant documents in right of the suit

Drawn and drafted by me under the instructions of plaintiff and signed by me.

Muhammad MithalPanhwar

Advocate High Court

Office: MirpurMathelo.

IN THE COURT OF SENIOR CIVIL JUDGE MIRPUR MATHELO

FCS NO:/2015

Muhammad MithalPanhwar……………………   Plaintiff

VERSUS

Chief Executive Engineer

Irrigation Division Ghotki& others   …………………. .…  Defendents

List of legal heirs of the plaintiff

1.      Asif     son adult

2.      Aaf

3.      Asfasf

In case of death of the plaintiff, his legal heirs will inform to this honorable court

Postal address

Haji s/o afs

Proprietor m/s iqbalservie station mirpurmathelo

Dated.25.25.2014                                                                   Advocate

For The Plaintiff