SUIT FOR DECLARATION, RENDITION OF ACCOUNTS, PERMANENT & MANDATORY INJUNCTION (In Pakistan)

IN THE COURT OF JUDGE BANKING COURT, RAWALPINDI


Ghulam Nabi s/o Ghulam Rasool, r/o House No.AA-1001 Mohallah Workshapi, Rawalpindi.
…Plaintiff
VERSUS

1. City Bank through its Manager, Blue Area, Islamabad.
2. Collection Officer, City Bank Blue Area,, Islamabad.

…Defendants

SUIT FOR DECLARATION, RENDITION OF ACCOUNTS, PERMANENT & MANDATORY INJUNCTION


Respectfully Sheweth!


1. That the plaintiff is the resident of above mentioned address.
2. That the plaintiff used facility of Credit Card bearing No. 5428314003406004 from the defendant’s bank in 2008 loan limits Rs.425,000/-
3. That the plaintiff paid regular installments before and after business loss to the defendants and no more outstanding principle amount against the plaintiff is due.
4. That the plaintiff’s business fully destroyed.
5. That the defendants changed the schedule of interest yearly with malafide and ulterior motives.
6. That the plaintiff’s children are school going and the plaintiff is now not able to afford the fee and expenditure of them and the other expenditures of house hold matters.
7. That the plaintiff paid principle amount to the defendants take borrow to the friends and relatives.
8. That in spite of repeated requests to the defendants on behalf of the plaintiff, the defendants are not giving detail of the deposited amount and are bent upon to forcible recovery of alleged loan amount and flatly refused to accede to the genuine request of the plaintiff.
9. That the business of the plaintiff flopped and now plaintiff is not able to refund the huge interest to the defendants.
10. That a week ago, the defendants extended threats for dire consequences including adopting of coercive measures against the plaintiff hence this suit.
11. That the cause of action finally accrued to the plaintiff yesterday, when defendant’s staff members visited the resident and business place of the plaintiff and extended threats to the plaintiff and flatly refused to exceed to the genuine request of the plaintiff.
12. That the plaintiff is the resident of Rawalpindi hence this Honourable Court has the jurisdiction to adjudicate upon the matter.
13. That the value of the suit for the purposes of the court fee and jurisdiction is assessed at Rs.15000/- which is exempted from the court fee.

PRAYER

In the circumstances, it is therefore, very humbly prayed that the following decrees may kindly be passed in favour of the plaintiff and against the defendants.
a. Declaration to the effect that the plaintiff has paid the principal loan amount to the defendants and their claim of huge markup is against the law and rights of the plaintiff.
b. A decree of rendition of accounts may kindly be passed in favour of the plaintiff.
c. A decree of permanent and mandatory injunction restraining the defendants from threatening and harassing and pressurizing the plaintiff or adopting the coercive measures against the plaintiff or with malafide and ulterior motives demanding illegal money or forcibly recover the amount from the plaintiff or sending their officials at the business place / resident of the plaintiff without due process of law till final decision of the suit. It is further prayed that defendants to be directed to negotiate with the plaintiff and not recover interest amount to the plaintiff, if any interest due against the plaintiff. Because the plaintiff business has been destroyed.
d. Any other relief which this Honourable Court deems just and proper may also be awarded.

Plaintiff
Through

COUNSEL