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Tuesday, 29 October 2013
LETTER HEAD
Contact:
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ADVOCATE HIGH COURT
Ref:__________________ Date:
__________________
Tuesday, 22 October 2013
Close ur eyes and make a wish….
Angelz will b there to blow u a kiss…
They'll guide u and make all ur dreams come true …
Just like they did for me when I asked for a friend
like u...
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Keep Smiling..
desire success for you !!
very happinesses !
Angelz will b there to blow u a kiss…
They'll guide u and make all ur dreams come true …
Just like they did for me when I asked for a friend
like u...
.......{\......._____.....,
......{*.\.....(*~*~*).../}
.....{.~.*\....////^^\../~}
.....{*....\..(((/.6.6./.*}
.....{..*.~.\.)))c..=.)*..}
......{*...*.////'_/~`.~.}
.......{~.*.((((.`.`\.*}'
........`{.~.)))`\.\))_.-:<*>
...........`{.(()..`\_.-'`.`:
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...............\....\ .\
........._ .__\...| / ........|` `'...``Y;
.........|./``-../../
.........`'......|./
................./.`-._
.................`-----
Keep Smiling..
desire success for you !!
very happinesses !
Sunday, 6 October 2013
LETTER PAID
Contact:
0300-492 7744
0321-492 7744
falaksherbhatti.blogspot.com
ADVOCATE HIGH COURT
Ref:__________________ Date:
__________________
Thursday, 3 October 2013
SUIT FOR DECLARATION WITH CONSEQUENTIAL RELIEF
IN THE COURT OF SENIOR CIVIL JUDGE, KASUR
In the
matter of:
KARAMAT ALI
S/O NIAMAT ALI CAST KAMBOO R/O BASTI WANIKHAN WALI SHEIKH BHAGO ROAD DISTRIC T
KASUR
PLAINTIFF…
VERSUS
1.
WAPDA
THROUGH CHAIRMAN WAPDA, WAPDA HOUSE LAHORE.
2.
S.E WAPDA HOUSE LESCO KASUR
3.
X.E.N
WAPDA SUB DIVISION RURAL AREA , KASUR DIVISION KASUR- RURAL
4.
S.D.O
SUB DIVISION RURAL AREA , KASUR DIVISION KASUR- RURAL
5.
THE
CONCERNED METER READER SUB
DIVISION RURAL AREA , KASUR
DIVISION KASUR- RURAL
6.
REVENUE
OFFICER(R.O) RURAL AREA , KASUR
DIVISION KASUR- RURAL
DEFENDEN….
SUIT FOR DECLARATION WITH
CONSEQUENTIAL RELIEF
Respectfully
Sheweth,
1. That the plaintiff is a permanent
consumer of the Electricity Meter Reference No. 14117121262001U and
paying regularly electricity bill.
2. That the plaintiff is a poor and
respectable person of the locality while the defendants are authorized and
powerful persons who are trying to illegally disturb plaintiff physically,
mentally and monetary through over-reading for the last few months 2012 to till
now.
3. That the plaintiff time and again
requested the defendants not to harass the plaintiff through over-reading but
the defendants did not abstain from their habitual routine activities. Hence
this suit.
4. That the cause of action firstly
arose against the defendants in the month of March 2012 when the defendants
issued the electricity bill with an amount of Rs18426/-with accumulated units
601 to the plaintiff which was wrong and illegal, hence the plaintiff requested
the defendants to correct the aforesaid E/bill as per actual consumed units but
they did not do so.
5. That the 2ndly cause of action arose
in the month of May 2012 when the defendants issued the electricity bill with
an amount of Rs25032/= to the plaintiff which was wrong and illegal, hence the plaintiff
requested the defendants to correct the aforesaid E/bill as per actual consumed
units and they corrected the E/Bill with an amount of Rs 11157/= so plaintiff
paid …
6. That the 3rd cause of
action arose in the month of Jun 2012 when the defendants issued the
electricity bill with an amount of Rs4563/= to the plaintiff which was wrong
and illegal, hence the plaintiff requested the defendants to correct the
aforesaid E/bill as per actual consumed units and they corrected the E/Bill
with an amount of Rs 2343/= so plaintiff paid.
7. That again in the month of July 2012
when the defendants declared plaintiff`s aforesaid E/Meter as defective and
replaced while plaintiff`s aforesaid meter was working correct.
8. That the cause of action again arose against
the defendants in the month of Sep 2012 when the defendants issued the
electricity bill with an amount of Rs33328/-with accumulated units 1943 to the
plaintiff which was wrong and illegal, hence the plaintiff requested the
defendants to correct the aforesaid E/bill as per actual consumed units but
they did not do so.
9. That the cause of action again arose
against the defendants in the month of Oct.2012 when the defendants issued the
electricity bill with an amount of Rs38769/-to the plaintiff which was wrong and
illegal, hence the plaintiff requested the defendants to correct the aforesaid
E/bill as per actual consumed units but they did not do so.
10. That the cause of action again arose
against the defendants in the month of Nov.2012 when the defendants issued the
electricity bill with an amount of Rs43536/-to the plaintiff which was wrong
and illegal, hence the plaintiff requested the defendants to correct the
aforesaid E/bill as per actual consumed units after setting-aside arrear amount
Rs/33288/-which was wrong and illegal but they did not do so.
11. That the cause of action again arose
against the defendants in the month of Dec.2012 when the defendants issued the
electricity bill with an amount of Rs47079/-to the plaintiff which was wrong
and illegal, hence the plaintiff requested the defendants to correct the
aforesaid E/bill as per actual consumed units after setting-aside arrear amount
Rs/37092/-which was wrong and illegal but they did not do so.
12. That the cause of action again arose
against the defendants in the month of Jan.2013 when the defendants issued the
electricity bill with an amount of Rs50099/-to the plaintiff which was wrong
and illegal, hence the plaintiff requested the defendants to correct the
aforesaid E/bill as per actual consumed units after setting-aside arrear amount
Rs/47324/-which was wrong and illegal but they not only flatly denied but
disconnected the plaintiff`s above said E9meter.
13. Then plaintiff has filed a suit for
declaration in this honorable court on dated 18-02-2013 in which next date of
hearing is fixed for 24-06-2013 and in the meanwhile the defendants again
issued the E/Bill of the Month of May
2013with an amount of Rs62204/-after including arrear amount Rs62108/- to the plaintiff which is wrong and illegal because
the plaintiff has regularly paying his current E/Bill as per courts order and there
is nothing any arrear amount towards plaintiff.
14. That the plaintiff several times
requested the defendants not to harass the plaintiff and corrected the aforesaid
bill but they denied and are about to disconnected the plaintiffs meter which
is wrong and illegal.
15. That the plaintiff has his residence
in kasur and defendant’s office also in kasur and cause of action also arose in
kasur, so this honorable court has jurisdiction to entertain this suit.
16. That the prescribed court fee has
been affixed by the plaintiff at this plaint.
PRAYERS
In view of the above narrated facts, it is most respectfully
prayed that
a. A decree of declaration may kindly be
passed in favor of the plaintiff and against the defendants regarding setting
aside the disputed amount Rs=
b. That the defendants are to be
graciously directed not to disconnect the plaintiff`s Electric Meter Power
Supply Meter Reference No. 14117121262001U and
also restrain from over-billing in future.
c. Heavy cost may also be awarded to the
plaintiff.
d. Any other relief deemed possible by
this honorable court may also be granted to the plaintiff.
VERIFICATION
Verified
on oath at Kasur on this 06th day of September 2013 that the
contents of my said Affidavit are true and correct to the best of my knowledge,
information and belief and nothing has been concealed there from.
PLAINTIFF THROUGH
COUNSEL,
SUIT FOR DECLARATION WITH CONSEQUENTIAL RELIEF REGARDING DISPUTED AMOUNT Rs.15137/-
IN THE COURT OF SENIOR CIVIL JUDGE, KASUR
MUHAMMAD LATIEF S/O KHUDA BAKSH CAST BHATTI
R/O GENERAL BUS STAND SARDAR COLONY STREET NO 3 KASUR.
Plaintiff…
VERSUS
1.
WAPDA THROUGH CHAIRMAN WAPDA, WAPDA
HOUSE LAHORE.
2.
X.E.N WAPDA SUB
DIVISION CIVIL AREA , KASUR- CITY
3.
S.D.O SUB DIVISION CIVIL AREA, KASUR-
CITY
4.
REVENUE OFFICER(R.O) CIVIL AREA , KASUR- CITY
Defendants…
SUIT FOR
DECLARATION WITH CONSEQUENTIAL RELIEF REGARDING DISPUTED AMOUNT Rs.15137/-
Respectfully Sheweth,
1. That the plaintiff is a permanent consumer of the electricity meter
reference no 09117111422500U and paying regularly electricity bill.
2. That the plaintiff is a poor and respectable person of the
locality while the defendants are authorized and powerful persons who are
trying to illegally disturb plaintiff physically, mentally and monetary.
3. That the defendants issued electricity meter bill to the plaintiff
for the month of March 2013 with total amount including L.P.SURCHARGE =17575/-
Rs. In which an arrear amount =15137/- Rs. has been included which is wrong and
illegal.
4. That the plaintiff has moved an application dated 31-01-2013 to
the XEN wapda on behalf of defect of electricity meter due to rain but the
defendants instead of replacing plaintiff’s electricity meter issued plaintiff
an arrear amount =15137/- Rs. which is wrong and illegal. Hence this suit.
5. That the cause of action firstly arose against the defendants in
the month of March 2013 when the defendants issued the electricity bill with an
arrear amount of =15137/- Rs. to the plaintiff which was wrong and illegal,
hence the plaintiff requested the defendants to correct the aforesaid E/bill
but they did not do so and instead of correcting the aforesaid E/bill they harassing
the plaintiff.
6. That the 2ndly and last cause of action arose on dated 25-03-2013
when defendants flatly refused to correct the aforesaid electricity bill.
7. That the plaintiff has his residence in kasur and defendant’s
office also in kasur and cause of action also arose in kasur, so this honorable
court has jurisdiction to entertain this suit.
8. That the prescribed court fee has been affixed by the plaintiff at
this plaint.
PRAYER
In view of the above narrated facts, it is most respectfully
prayed that A decree of declaration may kindly be passed in favor of the
plaintiff and against the defendants regarding setting aside the disputed
amount Rs=15137/- and the defendants may kindly be directed to restrain from disconnecting
the electricity connection reference no 09117111422500u and also restrain from
over-billing in future till the final disposal of the above titled case.
Any
other relief deemed possible by this honorable court may also be granted to the
plaintiff.
VERIFICATION
Verified on oath at this 27 March 2013 at kasur that the contents
of Para no 1 to 6 are correct and the remaining paras are correct to my
knowledge and belief.
PLAINTIFF THROUGH
COUNSEL,
APPLICATION UNDER ORDER 39 RULE1, 2 READ WITH SECTION 151 OF C.P.C 1908 FOR DIRECTING THE DEFENDANTS/RESPONDANTS TO CONNECTIONPOWER SUPPLY ELECTRIC METER REFRENCE NO: 14117121262001 U
IN THE COURT OF SENIOR CIVIL JUDGE,
KASUR
KARAMAT ALI S/O
NIAMAT ALI CAST KAMBOO R/O BASTI
WANIKHAN WALI SHEIKH BHAGO ROAD
KASUR
Plaintiff…
VERSUS
1.
WAPDA THROUGH CHAIRMAN WAPDA, WAPDA
HOUSE LAHORE etc.
Respondent…
SUIT FOR DECLARATION WITH CONSEQUENTIAL RELIEF
APPLICATION
UNDER ORDER 39 RULE1, 2 READ WITH SECTION 151 OF C.P.C 1908 FOR DIRECTING THE
DEFENDANTS/RESPONDANTS TO CONNECTIONPOWER SUPPLY ELECTRIC METER REFRENCE NO: 14117121262001
U
Respectfully Sheweth,
1.
That the petitioner has filed the
above titled application in the above titled main plaint today in this
honorable court in which no date of hearing has yet been fixed
2
That the contents of the titled
application are correct and true to my knowledge and may kindly be read as an integral part of the contents of the
main plaint.
3
That the petitioner /plaintiff has strong
prima-facie arguable case and balance of convenience also lies in favor of the
plaintiff/petitioner.
4
That the respondents may kindly be
directed to restore the plaintiff`s Electric Meter Reference No. 14117121262001U
for the interest of justice.
5
That if the respondents/defendants
are not directed to restore the disconnected electric meter, the
petitioner/plaintiff shall suffer irreparable loss and injury.
PRAYERS
In view of the above narrated facts, it is most respectfully
prayer that the above titled application may kindly be accepted and the
contents of main plaint may kindly be read as an integral part of this
application. And the respondents be graciously directed to restore the Electric
Power Supply Meter Reference No. 1411712126001U and also restrain from overbilling
in future.
PETITIONER Through Counsel:
Karamat Ali S/O Niamat Ali
BAIL PERFORMA
Title
as: Muahammad
Abbas Vs State
Case FIR# 379/13 Dated:29.05.2013
Offence: 39-A Electricity Act 1910
P.S Raja Jang District Kasur
(CERTIFICATE)
(as required vide judgmentdated
16.07.2001 Hon’ble Lahore High Court ,
In cr.Misc. No 6066-B-2001 Titled
Hakeem Mumtaz Ahmad V/S The State)
|
1)
|
Whther the accused or any of his co-accused had earlier filed any bail
petition before any such court or any other court & what was the result
of the same.
|
No
|
|
A
|
Name of Court
|
Nil
|
|
B
|
Title of Application
|
Nil
|
|
C
|
Next Date of Hearing
|
Nil
|
|
D
|
Date of decision
|
Nil
|
|
2)
|
Whether the accused person seeking bail had filed any higher court and
if so then whether the same is pending or stood decided.
|
No
|
|
3)
|
The Name and Address of the person on whose instruction the learned
counsel supplies the information as required by this certificate.
|
Petitioner Himself.
|
Note: No
Bail Application shall be entertained by the court which does not carry such a
certificate & does not disclose the identity of the person on whose instructions
such a certificate was given.
Signature
of person
Signature
of counsel
Objection by the jail authorities
on Release Orders(Robkar).
ore'>
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Samina,
(Real Sisters of the Petitioner).
xi.
Sheema,
(Mother of the Petitioner).
xii.
Nazia
,(Wife of the Petitioner).
xiii.
Rabia
W/O Yasir
xiv.
Aisha
W/O Sunny, (Wives of Accused Brothers).
and all kith and kin of the
petitioner are named in the FIR along with 2 more unknown persons.
The widest net is thrown and none of
the family and kith and kin are spared.
3.
That
the role attributed to the petitioner is that he inflicted a TOKA blow on the
left leg of deceased Ishaque.
4.
That
the medical account does not bear out injuries with a sharp edged weapon like
TOKA on the leg of the deceased.
5.
That
the inquiry report reveals one injury on the calf of right leg while in post
mortem report, injury No.5 is a lacerated wound measuring 2cm*0.5cm present on front
of (R) lower leg 11cm below knee. Injuries No. 6 and 7 on the leg are
abrasions. Though the nature of injuries attracting certain penal provision is
not stated, however the description positively suggests that these are simple
in nature. That injury attributed to the petitioner is not particularly attributed
to the petitioner.
6.
That
the petitioner is behind the bars since 22.12.2012.
7.
That
in Crl.Misc No. 2451-B-2013, His lordship Mr. Justice Shahid Hameed Dar of the
Lahore High Court Lahore. While granting bail to Muhammad Tanvir and Abdul
Qayyum observed on 08.05.2013 in Para No.6. Annex. A
PARA No.6 “According to the contents of the FIR, the alleged
crime was committed by a mob consisting of 26 persons and in such a tumultuous
situation. Its look pretty hard that the individual act of any of the rioters
could be noticed by the complainant and other witnesses. The particular aspect
of the case however, can be better taken care of by the learned trail court
after recording of evidence of the parties during trial.”
8.
That
his lordship Mr. Justice Muhammad Farrakh Irfan Khan of the Lahore High court Lahore,
while granting bail to co-accused Arslam Ali and Yasir Ali observed on
30.07.2013 in of Cr.Misc No. 9084-B-2013 in Para No.5 Annexed. B, “the
unfortunate accordance turned into melee. As regards the petitioners they are
behind the bar since 22.12.2012 and 4.10.2013 repeatedly and in the facts and
circumstances of the case cannot be incarcerated for in definite period of
time. Their further detention would hardly serve any useful purpose for the prosecution.
Co-accused of the petitioner with somewhat identical role have already been granted
bail by the court. Mere reading of examination in chief of 9pws nowhere disentitled
the petitioners and can be treated a valid ground to withhold the grant of
bail. Investigation is complete. Challan has been submitted. Both the
petitioners are real brothers. They are no more required by investigation
agency for purpose of any further investigation.
For the afore going facts and reasons,
aparts from the applicability of role of consistency petitioners case also falls
with the ambit of provision 2 to section 497.
9.
(a).
that the present petitioner is also brother of the accused who have been
granted bail mentioned above. That on the body of deceased Muhammad Ishaque
there are seven injuries in the post mortem report and out of these 3 are on
the right leg one is lacerated wound and two are the abrasions, one injury is
attributed on the right legal of sharp edged weapon to the petitioner. Firstly
the injury is not supported by medical account and account of injuries as given
in FIR leads to the observation dated 08.05.2013 in Para No. 6 of Annex A, by
his lordship Mr. Justice Shahid Hameed Dar that crime was committed by mob
consisting of 26 persons and in such a tumultuous situation, it looks pretty
hard that the individual acts of any of the rioter could be notice by the
complainant and other witnesses.
10. That the case against the petitioner
is one of further inquiry.
11. That petitioner is not previous convict.
It is, therefore, respectfully prayed that the instant bail
petition may kindly be accepted and petitioner may kindly be granted bail after
arrest till the final disposal of the case.
Petitioner: Through Counsel
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