IN THE
COURT OF MISS UZMA AHSIN, CIVIL JUDGE, RAWALPINDI
In the matter of:
Sheikh Muhammad Tariq V/s Saher Mehmood
(Suit for the Recovery of Rs.90,000/-)
WRITTEN STATEMENT ON BEHALF OF DEFENDANT
Respectfully Sheweth!
PRELIMINARY OBJECTIONS
1. That the plaintiff has not come to the court with clean hands hence the suit filed by the plaintiff be dismissed.
2. That the plaintiff has suppressed material facts from this Honourable Court and wants to gain undue benefits hence the suit is liable to be dismissed.
3. That the plaintiff has filed the instant suit just to pressurize, humiliate and harass the answering defendant hence the instant suit is liable to be dismissed.
4. That the affidavit annexed by the plaintiff with the instant suit is totally bogus, frivolous, fake and self made document and having no value in the eyes of law.
5. That the defendant never ever affixed any kind of thumb impression on the affidavit given by the plaintiff before this Honourable Court and actually the plaintiff himself affixed the thumb impression and wrongly stated that the same was done by the defendant.
6. That the defendant is liable to get special cost U/S 35-A of CPC.
ON FACTS
1. Para No. 1 is admitted to the extent that the defendant was sent through Al-Qasim Recruitment Agency but neither he knows Sheikh Tariq / defendant nor taken any money from said Sheikh Tariq, hence denied.
2. Para No.2 is not admitted, hence denied.
3. Para No.3 is not admitted. Actually the owner of Al-Qasim Recruitment Center sent the defendant on work visa to Malaysia, he took away Rs.250,000/- from the defendant hence the instant para is totally incorrect and denied.
4. Para No.4 is not admitted. The plaintiff never asked the defendant to pay the said amount and the alleged affidavit was actually made by the plaintiff himself and the defendant has no concern whatsoever with the plaintiff at all.
5. Para No.5 is incorrect hence denied. The plaintiff never asked the defendant to pay the said amount so the suit of the plaintiff is false, frivolous and self contradictory, the defendant has never threatened the plaintiff at all.
6. Para No.6 is incorrect hence denied. There is no question of damages whatsoever.
7. Para No.7 is not admitted. The plaintiff has no cause of action to file the instant suit against the defendant.
8. Para No.8 is admitted to the extent of jurisdiction, rest is denied.
9. Para No.9 is admitted to the extent of court fee, rest is denied.
PRAYER
In the above mentioned facts and circumstances, it is therefore, most respectfully prayed that the suit filed by the plaintiff may kindly be dismissed with cost.
Defendant
Through
COUNSEL
In the matter of:
Sheikh Muhammad Tariq V/s Saher Mehmood
(Suit for the Recovery of Rs.90,000/-)
WRITTEN STATEMENT ON BEHALF OF DEFENDANT
Respectfully Sheweth!
PRELIMINARY OBJECTIONS
1. That the plaintiff has not come to the court with clean hands hence the suit filed by the plaintiff be dismissed.
2. That the plaintiff has suppressed material facts from this Honourable Court and wants to gain undue benefits hence the suit is liable to be dismissed.
3. That the plaintiff has filed the instant suit just to pressurize, humiliate and harass the answering defendant hence the instant suit is liable to be dismissed.
4. That the affidavit annexed by the plaintiff with the instant suit is totally bogus, frivolous, fake and self made document and having no value in the eyes of law.
5. That the defendant never ever affixed any kind of thumb impression on the affidavit given by the plaintiff before this Honourable Court and actually the plaintiff himself affixed the thumb impression and wrongly stated that the same was done by the defendant.
6. That the defendant is liable to get special cost U/S 35-A of CPC.
ON FACTS
1. Para No. 1 is admitted to the extent that the defendant was sent through Al-Qasim Recruitment Agency but neither he knows Sheikh Tariq / defendant nor taken any money from said Sheikh Tariq, hence denied.
2. Para No.2 is not admitted, hence denied.
3. Para No.3 is not admitted. Actually the owner of Al-Qasim Recruitment Center sent the defendant on work visa to Malaysia, he took away Rs.250,000/- from the defendant hence the instant para is totally incorrect and denied.
4. Para No.4 is not admitted. The plaintiff never asked the defendant to pay the said amount and the alleged affidavit was actually made by the plaintiff himself and the defendant has no concern whatsoever with the plaintiff at all.
5. Para No.5 is incorrect hence denied. The plaintiff never asked the defendant to pay the said amount so the suit of the plaintiff is false, frivolous and self contradictory, the defendant has never threatened the plaintiff at all.
6. Para No.6 is incorrect hence denied. There is no question of damages whatsoever.
7. Para No.7 is not admitted. The plaintiff has no cause of action to file the instant suit against the defendant.
8. Para No.8 is admitted to the extent of jurisdiction, rest is denied.
9. Para No.9 is admitted to the extent of court fee, rest is denied.
PRAYER
In the above mentioned facts and circumstances, it is therefore, most respectfully prayed that the suit filed by the plaintiff may kindly be dismissed with cost.
Defendant
Through
COUNSEL
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