BEFORE THE GAS UTILITY COURT, LAHORE
Civil Suit No._____________ / 2024
Sui Northern Gas Pipeline Limited (SNGPL)
Versus
[insert]
INDEX
Sr. Description of Documents Annexures
No
1. Plaint along with Application for the attachment of the
Respondent’s property to the suit
2. Annexures
3. Power of Attorney
Detail of Annexures
4. Gas (Theft Control & Recovery) Act 2016 A
5. Authority Letter B
6. Connection Details C
7. Gas Utility Bill for the month of [insert], Statement of D, D/1 and
Accounts and the Defendant’s Billing History D/2
8. Letter dated [insert] E
9. Letter dated [insert] F
PLAINTIFF
Through Counsel(s):
Sarmad Sattar
LL. B Hons. London
Advocate High Court
Sarmad Sattar & Co.
Advocates & Corporate Counsels
13 Fane Road, Lahore
BEFORE THE GAS UTILITY COURT, LAHORE
Civil Suit No._________________ / 2024
Sui Northern Gas Pipeline Limited, through its General Manager Mr. Shahzad Iqbal
Laun, having its office at 21–Industrial Area, Gurumangat Road, Gulberg III, Lahore.
…Plaintiff
Versus
[insert], resident of [insert]
…Defendant
SUIT FOR THE RECOVERY OF PKR. [insert]/- UNDER THE RELAVENT
SECTIONS OF THE GAS (THEFT CONTROL AND RECOVERY) ACT 2016, ALONG
WITH COSTS
Respectfully Stated: -
I. That the above-given addresses are correct and sufficient for purposes of the
process and all other communications issued by this honorable Court in respect of
this Suit and all other proceedings arising from it.
II. That the Plaintiff is a Gas Utility Company as defined under Sec 2(h) of the Gas
(Theft Control & Recovery) Act 2016, (hereinafter the “Act, 2016”, a copy of
which is attached herewith as Annexure A) and is engaged in the business of
transmission and distribution of sui-gas for domestic and commercial use.
III. That this suit has been filed by the Plaintiff through its General Manager, Lahore,
namely [insert], who is well conversant with the facts of instant matter and has
been duly authorized to depose the same. A copy of the general power of
attorney, along with the Authority Letter of [insert], who has been authorized to
act on behalf of the Plaintiff, has been attached herewith as Annexure B.
IV. That by way of background, a gas meter (hereinafter the “Meter”) was installed
at aforementioned address of the Defendant (hereinafter the “Premises”), in
respect of consumer No. [insert]. Hereinafter, the “Connection”, the details of
the Connection has been attached herewith as Annexure C.
V. That, it is significant to note here, that the Defendant was using the gas for the
purposes of frying (hereinafter the “Commercial Use”) i.e. Slanty fry,
(hereinafter the “Factory”) since its installation on [insert].
VI. That consequently, due to non-payment on [insert], (hereinafter the
“Disconnection Date”) the Meter was disconnected and a sum of [insert]/- was
calculated (hereinafter the “Defrauded Amount”).
VII. That afterwards, bill for the month of [insert], amounting to PKR. [insert]
(hereinafter the “Outstanding Amount”) was sent by plaintiff; however, the
Defendant did not pay the Outstanding Amount within the prescribed due date.
Copy of the Gas Utility Bill for the month of [insert], along with Statement of
Accounts and the Defendant’s Billing History, evidencing the Outstanding
Amount, has been attached herewith as Annexure D, D/1 and D/2.
VIII. That owing to the Defendant’s non-payment, the Plaintiff sent a letter dated
[insert] (hereinafter the “Letter dated [insert]”, copy of which, along with
invoice, has been attached herewith as Annexure E and E/1), requesting the
Defendant to pay the Outstanding Amount on or before [insert], but in vain.
IX. That consequently, due to non-payment on [insert], the Plaintiff vide notice for
payment of last gas bill (hereinafter the “Letter dated [insert]”, copy of which
has been attached herewith as Annexure F), intimated the Defendant that the
Outstanding Amount is still pending. So, the Defendant was requested to pay the
Outstanding Amount by or before [insert]. But of no use.
X. That, after expiry of the due date provided in the last letter (hereinafter the
“Letter dated [insert]”) by the plaintiff, an official of the Plaintiff visited the
premises of the Defendant and inquired about the payment of Outstanding
amount/dues payable by the Defendant.
XI. That, since then the Plaintiff has, time and again, requested the Defendant to pay
the Outstanding Amount but the Defendant kept on lingering the matter and flatly
refused to pay the Outstanding Amount on one pretext or another. Hence, the
Plaintiff was left with no option but to file this suit.
XII. That the first cause of action accrued on the date of Detection. Secondly, on
[insert], as a result of the Defendant’s failure to pay the Outstanding Amount, as
required in the Letter dated [insert]. Thirdly, on [insert], when the second notice
was served. And lastly, when the Plaintiff approached the Defendant for payment
of the Outstanding Amount, but the Defendant flatly refused to accede to the said,
reasonable and lawful request of the Plaintiff, without providing any cogent
reasons.
XIII. That the Plaintiff carries on business in Lahore and, the Defendant also resides in
Lahore, so, this honorable Court has the jurisdiction to adjudicate upon this
matter.
XIV. That the value of this suit for calculation of court fee, and determination of
jurisdiction is calculated as PKR. [insert]/-
PRAYER
Considering the afore-mentioned facts and circumstances, it is most respectfully prayed
as under:
a. To direct the Defendant to pay the Outstanding Amount to the Plaintiff;
b. To direct the Defendant to pay costs suffered by the Plaintiff to recover the
Outstanding Amount through this honorable Court;
Any other relief deemed fit by this Honorable Court may also be granted.
PLAINTIFF
Through Counsel(s):
Sarmad Sattar
LL. B Hons. London
Advocate High Court
Sarmad Sattar & Co.
Advocates & Corporate Counsels
13 Fane Road, Lahore
VERIFICATION
Verified on oath at Lahore on this ______ day of [insert], that the contents of paragraphs
I to XIV are correct to the best of my knowledge and belief, and that paragraphs XIII to
XIV are true to the best of my information.
PLAINTIFF
BEFORE THE GAS UTILITY COURT, LAHORE
Civil Suit No._____________ / 2024
SUI NORTHERN GAS PIPELINE LIMITED, through its General Manager Mr.
Shahzad Iqbal Laun, having its office at 21-Industrial Area, Gurumangat Road, Gulberg
III, Lahore.
...Plaintiff
Versus
[insert], resident of [insert]
...Defendant
FARD PATA
Address for service of the Plaint
(Under Order VII/VIII of the Code of Civil Procedure, 1908)
The address for the service on the plaintiff is as follows:
[insert], resident of [insert]
PLAINTIFF
Through Counsel(s):
Sarmad Sattar
LL. B Hons. London
Advocate High Court
Sarmad Sattar & Co.
Advocates & Corporate Counsels
13 Fane Road, Lahore
BEFORE THE GAS UTILITY COURT, LAHORE
Civil Suit No.____________ / 2024
SUI NORTHERN GAS PIPELINE LIMITED, through its General Manager [insert],
having its office at 21-Industrial Area, Gurumangat Road, Gulberg III, Lahore.
…Plaintiff
Versus
[insert], resident of [insert]
…Defendant
LIST OF DOCUMENTS PRODUCED
(Under Order XIII, Rule 1 of the Civil Procedure Code, 1908)
Sr Description of Documents Annexures
.
N
o
1. Gas (Theft Control & Recovery) Act 2016 A
2. Authority Letter B
3. Connection Details C
4. Gas Utility Bill for the month of September 2018 E & E/1
and Statement of Accounts
5. Letter dated [insert] F
6. Letter dated [insert] G
PLAINTIFF
Through Counsel(s):
Sarmad Sattar
LL. B Hons. London
Advocate High Court
Sarmad Sattar & Co.
Advocates & Corporate Counsels
13 Fane Road, Lahore
BEFORE THE GAS UTILITY COURT, LAHORE
Civil Suit No.______________ / 2024
SUI NORTHERN GAS PIPELINE LIMITED, through its General Manager [insert],
having its office at 21-Industrial Area, Gurumangat Road, Gulberg III, Lahore.
Plaintiff
Versus
[insert], resident of [insert]
Defendant
LIST OF RELIANCE
(Under Order VII, Rule 14 of the Civil Procedure Code, 1908)
Seria Questions Answers
l No.
1. Have you presented any documents with the As per index attached with the
Suit? If yes, identify? Plaint and list of documents
under order XIII, rule 1 of
Code of Civil Procedure, 1908,
which is attached with this
Plaint.
2. Will you present any other documents that Yes, if needed, after issues are
are in your possession? If yes, identify? framed.
3. Do you intend to rely on any other Yes, if needed, after issues are
documents? If yes, identify? framed.
PLAINTIFF
Through Counsel(s):
Sarmad Sattar
LL. B Hons. London
Advocate High Court
Sarmad Sattar & Co.
Advocates & Corporate Counsels
13 Fane Road, Lahore
BEFORE THE GAS UTILITY COURT, LAHORE
Civil Suit No.________________ / 2024
SUI NORTHERN GAS PIPELINE LIMITED through its General Manager, Lahore,
[insert], having its office at 21 – Industrial Area, Gurumangat Road, Gulberg III, Lahore
…Plaintiff
Versus
[insert], resident of [insert]
…Defendant
APPLICATION UNDER ORDER 38(5) READ WITH SECTION 151 OF THE CIVIL
PROCEDURE CODE TO ATTACH THE PROPERTY OF THE DEFENDANT TO THE
INSTANT SUIT
Respectfully Sheweth:
1. That the Plaintiff has filed the above-titled Suit against the Defendant for the
recovery of Subject Amount i.e. PKR. [insert]/- along with costs, under the
relevant sections of the Gas (Theft Control & Recovery) Act, 2016. The titled Suit
has not yet been fixed for hearing. The contents of the Suit may kindly be read as
an integral part of this Application.
2. That the Plaintiff has a good prima facie case, and the Plaintiff is likely to succeed
per averments/grounds contained in the Suit, which may be read as an integral
part of this Application.
3. That the interest of justice demands that, during the pendency of the main Suit
and for the reasons stated in the accompanying affidavit, this honorable Court
may be pleased to order attachment of the immovable property belonging to the
Defendant until the final disposal of the Suit, otherwise the Plaintiff will suffer
irreparable loss and hardship. Hence, the Application.
PRAYER
It is, therefore, most respectfully prayed that the instant Application may kindly be
accepted, and, during the pendency of the Suit, this honorable Court passes an order in
favor of the Plaintiff concerning the attachment of the Defendant’s immovable property,
in the best interests of justice, equity and fair play.
Dated: ______________
Lahore
PLAINTIFF
Through Counsel(s):
Sarmad Sattar
LL. B Hons. London
Advocate High Court
Sarmad Sattar & Co.
Advocates & Corporate Counsels
13 Fane Road, Lahore
BEFORE THE GAS UTILITY COURT
Civil Suit No. ________________ / 2024
SUI NORTHERN GAS PIPELINE LIMITED through its General Manager, Mr.
Shahzad Iqbal Laun, having its office at 21-Industrial Area, Gurumanget Road, Gulberg
III, Lahore.
…Plaintiff
Versus
[insert], resident of [insert]
…Defendant
APPLICATION FOR ATTACHMENT OF PROPERTY UNDER ORDER 38(5) READ
WITH SECTION 151 OF THE CODE OF CIVIL PROCEDURE, 1908
Affidavit of: [insert], authorized representative of Sui Northern Gas Pipelines Limited,
having its office at 21-Industrial Area, Gurumanget Road, Gulberg III, Lahore.
I, the above-named deponent do hereby solemnly affirm and declare as under:
1. That I am the Plaintiff in the above titled Suit as well as the Interlocutory
Application.
2. That the suit is filed for recovery of money amounting to a sum of Rs. [insert]/-
(hereinafter the “Subject Amount”), for provision of the gas utility services
provide by the Plaintiff to the Defendant.
3. That the Plaintiff has provided its uninterrupted utility services to the Defendant.
However, the Defendant has failed to pay for the said services, despite repeated
verbal and written reminders, including letter dated [insert], and letter dated
[insert].
4. That the Plaintiff demanded the Subject Amount several times. However, the
Defendant has delayed the payment on one pretext or the other, till date.
5. That it is a known fact that the Defendant is in a good financial position and there
are reasonable grounds to believe that he has completely forgotten the liability
towards the Plaintiff.
6. That the Plaintiff has an apprehension that the Defendant may succeed in selling
his property, with the intent to flee from his current residence/locality in order to
avoid the payment of Subject Amount. Hence for the interests of justice the
property of the defendant may be attached and for that purpose the Plaintiff has
also filed a separate Application herewith.
7. That the contents of the accompanying application under Order 38(5) read with
Section 151 of the Code of Civil Procedure, 1908, for attachment of property are
true and correct to the best of my knowledge and belief and nothing has been
concealed thereof.
DEPONENT
VERIFICATION
Verified on oath at Lahore on ______ day of _____________, 2024, that the contents of my
affidavit are true to the best of my knowledge and belief.
DEPONENT
