Suit for Demarcation of Property in Revenue Department
Civil Case No: /2020
In Re:
Riaz Mehmood son of Khursheed Ahmad resident of House No. 21 Mouza Niaz Baig near Hamdard Chowk Lahore.
PLAINTIFF
VERSES
1.Deputy Commissioner Officer (DCO), Lahore
2.Assistant Commissioner, Model Town Area, Lahore
3.Tehsildar, Mouza Pindi Rajputta, Model Town, Lahore
4.Halqa Patwari, Mouza Pindi Rajputta Model Town, Lahore
DEFENDANTS
SUIT FOR COMMENCING DEMARCATION OF THE PROPERTY MEASURING 3-KANALS 14-MARLAS 125-SQFT. KHEWAT NO. 2145 KHASRA NO. 23654/23690 SITUATED AT HADBAST, MOUZA PINDI RAJPUTTAN, TEHSIL MODEL TOWN, DISTRICT LAHORE.
Respectfully Sheweth,
1.That the addresses of the parties are correct for summoning /notice for this Honorable Court.
2.That the concise facts which giving rise to this instant suit are that the plaintiff purchased the property measuring 3-Kanals 13-Marlasa and 34-Sqft, situated at Hadbast Mouza Pindi Rajputta Tehsil Model Town Lahore through registered sale deed No. 2145 Book No. 365 Volume No. 89 Dated 21.5.2009 registered with Sub-Registrar Model Town Lahore. Copy of sale deed and Fard-e-Malkiyat is attached for the kind perusal of this Honorable Court.
3.That it is pertinent to mention here that the demarcation of the above said property is still not commence and it is necessary that the suit property be demarcated.
4.That since the purchased of the said land the plaintiff approached the concerned authorities many time for demarcation of the above said property and also gave the written application to defendants No. 3 and 4 for demarcation but up till now no demarcation has been commenced and stated to the plaintiff that if the plaintiff wants to commence demarcation, then the plaintiff will obtain a decree in this regard.
5.That the plaintiff intends to commence demarcation to the extent of his property which is exclusively owned by the plaintiff and his ownership is exclusive without interruption at any quarter, hence it may be appropriate and conductive if an order may be passed while directing the Revenue Authorities to commence demarcation of the said land in question description of which has been mentioned in supra paragraphs of this plaint for the redressal of his grievance, hence this suit.
6.That the cause of action arose in favour of the plaintiff and against the defendants when the plaintiff had purchased the said property out the specific khasra numbers and secondly when he intends to use the property form his own wish and desire for which a demarcation is needed to be done and plaintiff applied for the same before the Revenue Authorities who refused to do so, which is still continuing.
7.That the plaintiff is residing at Lahore, officials of the defendants and functioning and working at Lahore, cause of action also accrued at Lahore, Electricity Meter in question are also installed at the premises of the plaintiff at Lahore, therefore, this Honorable Court has got the jurisdiction to adjudicate upon this matter.
8.That the value of the suit for the purposes of Court Fee and jurisdiction is fixed Rs. 920/- which is exempted from the payment of Court Fee under law.
PRAYER:-
In the view of above submission, it is, therefore most respectfully prayed that an order may very kindly be passed with the direction for commencing demarcation of the said property description of which has been given in supra paragraph to the plaint in the supreme interest of justice.
It is further prayed that the defendants may very kindly be directed to commence demarcation as early as possible so as to make convenience for the plaintiff and to submit report of the demarcation to the Honorable Court.
Any other relief which this honorable court deems fit and appropriate in the circumstances of the case may also be awarded.
PETITIONER / PLAINTIFF
Through
CH MUHAMMAD SHAHID BHALLI
Advocate High Court
Mob: 0301-6001125
Chamber No. 3 First Floor Adnan Center,
Model Town Link Road Lahore
Verification
Verified on oath at Lahore on the 31st day of October, 2016 that the contents of paras No. 1 to 5 are correct to the best of my knowledge and those of paras No. 6 to 8 are correct to the best of my information and belief.
PALINTIFF