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,
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