LETTER HEAD

SANGLE LAW ASSOCIATES

Chamber # 96-97 District Courts Complex Kasur…

Contact:

                                                                                       0300-492 7744

0321-492 7744

falaksherbhatti.blogspot.com

FALAK SHER BHATTI

ADVOCATE HIGH COURT

Ref:__________________                                                                             Date: __________________

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Keep Smiling..
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LETTER PAID

SANGLE LAW ASSOCIATES

Chamber # 96-97 District Courts Complex Kasur…

Contact:

0300-492 7744

0321-492 7744

falaksherbhatti.blogspot.com

FALAK SHER BHATTI

ADVOCATE HIGH COURT

Ref:__________________                                                                             Date: __________________

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 3^rd 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 06^th 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'> � p n ��h h h font:7.0pt "Times New Roman"'>                   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