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
SAMPLE OF AFFIDAVIT USED IN COURTS OF PAKISTAN
AFFIDAVIT
I, Ghulam Nabi s/o Ghulam Rasool, r/o House No.AA-1001 Mohallah Workshapi, Rawalpindi, do hereby solemnly affirm and declare that the contents of the accompanying application are true and correct to the best of my knowledge and belief.
…Deponent
The above mentioned affidavit is also using in legal consultancy of Pakistan.
VERIFICATION
Verified on oath at Rawalpindi on this 15th day of March 2010 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 therefrom.
…Deponent
I, Ghulam Nabi s/o Ghulam Rasool, r/o House No.AA-1001 Mohallah Workshapi, Rawalpindi, do hereby solemnly affirm and declare that the contents of the accompanying application are true and correct to the best of my knowledge and belief.
…Deponent
The above mentioned affidavit is also using in legal consultancy of Pakistan.
VERIFICATION
Verified on oath at Rawalpindi on this 15th day of March 2010 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 therefrom.
…Deponent
BRANCHES OF LAW
Administrative.
Bankruptcy.
Business.
Communications.
Constitutional.
Consumer.
Criminal law.
Cyberspace.
Disabilities.
Employment.
Entertainment.
Environmental.
Family.
Immigration.
Intellectual property.
International.
Personal injury.
Product liability.
Property.
Public Benefits.
Qui Tam.
Real Estate Law.
Torts.
Traffic.
Trust & Estate Law.
The abvoe mentioned are the branches of law and same are using in legal consultancy in Pakistan.
Bankruptcy.
Business.
Communications.
Constitutional.
Consumer.
Criminal law.
Cyberspace.
Disabilities.
Employment.
Entertainment.
Environmental.
Family.
Immigration.
Intellectual property.
International.
Personal injury.
Product liability.
Property.
Public Benefits.
Qui Tam.
Real Estate Law.
Torts.
Traffic.
Trust & Estate Law.
The abvoe mentioned are the branches of law and same are using in legal consultancy in Pakistan.
DIFFERENT DEFINITIONS OF LAW
In general, a rule of being or of conduct, established by an authority able to enforce its will; a controlling regulation; the mode or order according to which an agent or a power acts.
In morals: The will of God as the rule for the disposition and conduct of all responsible beings toward him and toward each other; a rule of living, conformable to righteousness; the rule of action as obligatory on the conscience or moral nature.
The Jewish or Mosaic code, and that part of Scripture where it is written, in distinction from the gospel; hence, also, the Old Testament. ·
An organic rule, as a constitution or charter, establishing and defining the conditions of the existence of a state or other organized community. · Any edict, decree, order, ordinance, statute, resolution, judicial, decision, usage, etc., or recognized, and enforced, by the controlling authority.
In philosophy and physics: A rule of being, operation, or change, so certain and constant that it is conceived of as imposed by the will of God or by some controlling authority; as, the law of gravitation; the laws of motion; the law heredity; the laws of thought; the laws of cause and effect; law of self-preservation.
In mathematics: The rule according to which anything, as the change of value of a variable, or the value of the terms of a series, proceeds; mode or order of sequence. · In arts, works, games, etc.:
The rules of construction, or of procedure, conforming to the conditions of success; a principle, maxim; or usage; as, the laws of poetry, of architecture, of courtesy, or of whist.
Collectively, the whole body of rules relating to one subject, or emanating from one source; including usually the writings pertaining to them, and judicial proceedings under them; as, divine law; English law; Roman law; the law of real property; insurance law.
Legal science; jurisprudence; the principles of equity; applied justice.
Trial by the laws of the land; judicial remedy; litigation; as, to go law.
An oath, as in the presence of a court.
An exclamation of mild surprise.
The learned profession that is mastered by graduate study in a law school and that is responsible for the judicial system; "he studied law at Yale"
A rule or body of rules of conduct inherent in human nature and essential to or binding upon human society.
A generalization that describes recurring facts or events in nature; "the laws of thermodynamics" · The branch of philosophy concerned with the law and the principles that lead courts to make the decisions they do·
Legal document setting forth rules governing a particular kind of activity; "there is a law against kidnapping"
The force of policemen and officers; "the law came looking for him"
The collection of rules imposed by authority; "civilization presupposes respect for the law"; "the great problem for jurisprudence to allow freedom while enforcing order"
The above mentioned definitions are also using in legal consultancy of Pakistan.
In morals: The will of God as the rule for the disposition and conduct of all responsible beings toward him and toward each other; a rule of living, conformable to righteousness; the rule of action as obligatory on the conscience or moral nature.
The Jewish or Mosaic code, and that part of Scripture where it is written, in distinction from the gospel; hence, also, the Old Testament. ·
An organic rule, as a constitution or charter, establishing and defining the conditions of the existence of a state or other organized community. · Any edict, decree, order, ordinance, statute, resolution, judicial, decision, usage, etc., or recognized, and enforced, by the controlling authority.
In philosophy and physics: A rule of being, operation, or change, so certain and constant that it is conceived of as imposed by the will of God or by some controlling authority; as, the law of gravitation; the laws of motion; the law heredity; the laws of thought; the laws of cause and effect; law of self-preservation.
In mathematics: The rule according to which anything, as the change of value of a variable, or the value of the terms of a series, proceeds; mode or order of sequence. · In arts, works, games, etc.:
The rules of construction, or of procedure, conforming to the conditions of success; a principle, maxim; or usage; as, the laws of poetry, of architecture, of courtesy, or of whist.
Collectively, the whole body of rules relating to one subject, or emanating from one source; including usually the writings pertaining to them, and judicial proceedings under them; as, divine law; English law; Roman law; the law of real property; insurance law.
Legal science; jurisprudence; the principles of equity; applied justice.
Trial by the laws of the land; judicial remedy; litigation; as, to go law.
An oath, as in the presence of a court.
An exclamation of mild surprise.
The learned profession that is mastered by graduate study in a law school and that is responsible for the judicial system; "he studied law at Yale"
A rule or body of rules of conduct inherent in human nature and essential to or binding upon human society.
A generalization that describes recurring facts or events in nature; "the laws of thermodynamics" · The branch of philosophy concerned with the law and the principles that lead courts to make the decisions they do·
Legal document setting forth rules governing a particular kind of activity; "there is a law against kidnapping"
The force of policemen and officers; "the law came looking for him"
The collection of rules imposed by authority; "civilization presupposes respect for the law"; "the great problem for jurisprudence to allow freedom while enforcing order"
The above mentioned definitions are also using in legal consultancy of Pakistan.
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