IN THE COURT OF SYED FARRUKH HUSSAIN SHAMSI, CIVIL JUDGE, RAWALPINDI
Farrukh Waseem V/s Mst. Surriya Perveen etc
(Suit for Recovery of Possession)
WRITTEN STATEMENT ON BEHALF OF DEFENDANT NO.6
PRELIMINARY OBJECTIONS
1. That the plaintiff has got no cause of action to file the instant suit, because the house in dispute bearing No.382-B Sector I, Khayaban-e-Sirsyed was in the name of Mehmood Ahmed who mortgaged the said house to answering defendant and gave away possession of said house to answering defendant and now the tenants of answering defendant are in possession of the said house.
2. That the present suit is not maintainable under Sec 10 CPC and it must be stayed because a suit for specific performance for the said house is pending adjudication in Civil Court, Rawalpindi.
3. That the plaintiff has not come to the court with clean hands hence he is not entitled for any relief.
4. That proper court fee has not been affixed hence the suit be returned.
ON FACTS
1. Para No.1 is incorrect hence denied, in fact suit property was allotted vide No.382-B/SI/1374 dated 08-05-79 issued at 13-02-82 (Copy is attached herewith)
2. Para No.2 is incorrect hence denied.
3. Para No.3 denied being want of knowledge.
4. Para No.4 is incorrect hence denied, allotment letter dated 13-02-82 in name of Mehmood Ahmed is still in force.
5. Para No.5 is incorrect being want of knowledge.
6. Para No.6 is denied being want of knowledge.
7. Para No.7 is incorrect hence denied.
8. Para No.8 is incorrect hence denied.
9. Para No.9 is incorrect hence denied.
10. Para No10 is incorrect hence denied.
11. Para No.11 is incorrect hence denied.
12. Para No.12 is incorrect hence denied. Plaintiff has no cause of action to file the instant suit.
13. Para No.13 is legal.
14. Para No.14 is incorrect, the suit land is not properly assessed hence the maximum court should be affixed.
PRAYER
Under the above mentioned circumstances, It is, therefore, respectfully prayed that suit of the plaintiff may very kindly be dismissed with cost.
Defendant No.6
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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