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,