IN THE COURT OF MR.
MOEEN KHOKHAR CIVIL
JUDGE FEROZEWALA DISTRICT SHEIKHUPURA.
Sui Northern Gas Pipeline Limited.
VERSUS
Muhammad Manzoor
(Suit for Recovery of Rs. 3,02,035/-)
APPLICATION FOR LEAVE TO
DEFEND/CONTENTS ON BEHALF OF
RESPONDENT
Respectfully sheweth:-
Preliminary Objections:-
1. That the plaintiff has got no cause of
action to file the suit.
2. That there is no locus standi available
to the plaintiff.
3. That the suit of the plaintiff is barred
by law.
4. That the suit has been filed with
malafide intention only to tease and
black mail the answering defendant and
to deprive him from precious rights to
use the gas connection.
5. That the plaintiff has filed the instant
suit by concealment of major facts and
deposing imaginary suppositions.
6. That the suit is full of contradictions
based on surmises and self supposed mal
indented gossip.
7. That the suit is against the realities
so not maintainable in present form.
8. That suit is liable to be rejected under
order VII rule 11 CPC.
9. That the plaintiff is intending to
damage the rights and interests of the
defendant and is habitual litigants.
10. That the plaintiff is court birds and
their multiple cases/suits are gleaning
and un-rebutted self proved evidence.
“ON MERITS/PARAWISE COMMENTS”.
1. Para No. 1 needs no reply.
2. That the para No. 2 needs no reply.
3. That the para No. 3 is correct. Needs no
reply
4. That the para No. 4 is correct. Needs no
reply.
5. That the para No. 5 is correct. Needs no
reply.
6. That the para No. 6 is correct to the
extent that the defendant pay monthly
bills regularly after getting the gas
connection, remaining para is incorrect,
hence vehemently denied that the house
where the gas connection installed was
not in use of anyone since longtime due
to this the connection also not in use.
During this period the defendant living
any other address with his family. The
defendant came at the house for the look
after of the house in the month of March
2016 then the defendant seen that the
gas meter was not present outside the
house. The defendant asked from the
local peoples about the said sui gas
meter but all in vain. After that the
defendant complaint to the concern
authority for theft of the said sui gas
meter but the concerned authority
replied that the said sui gas meter of
defendant is uninstalled due to
nonpayment of due amount on which
defendant said that the disputed
connection was in use since long time,
the plaintiff issue a bill of March 2014
Rs. 3,12,035/- to the defendant and said
that pay the said bill in the bank and
the plaintiff again reinstalled the gas
connection of the defendant but the
defendant protested against due said
illegal, unlawful bill after that the
plaintiff correct the bill of March 2014
Rs. 10,000/- which was paid by the
defendant and again after that the
defendant contact with the plaintiff for
reinstallation of defendant’s gas
connection but the plaintiff lingering
on the matter on one pretext or the
other and after some time totally denied
to correct the disputed amount and then
the defendant filed a declaration suit
against the plaintiff which is pending
before Additional District & sessions
Judge Ferozewala District Sheikhupura.
7. That the para No. 7 is incorrect, hence
denied. The defendant has no receive any
notice from the plaintiff side and the
plaintiff has no any right to sent any
notice to the defendant and also not any
right to receive disputed amount from
the plaintiff.
8. That the para No. 8 is incorrect, hence
denied. The defendant has no receive any
notice from the plaintiff side and the
plaintiff has no any right to sent any
notice to the defendant and also not any
right to receive disputed amount from
the plaintiff.
9. That the para No. 9 is incorrect hence
denied. That the plaintiffs have no
cause of action against the defendant.
10. That the para No. 10 is correct to the
extent of valuation of the court fee,
remaining para is incorrect hence denied
the plaintiff intentionally not affixed
the proper court fees which is clearly
shows the malafide intention of the
plaintiff.
PRAYER
It is therefore most humbly prayed
that the application in hand may
kindly be accepted and gave the
opportunity to the respondent for
filing written statement.
It is further prayed that the suit
of the plaintiff being false and
frivolous and baseless may
dismissed with cost.
RESPONDENT
Through:
MIAN MUHAMMAD RAMZAN
Advocate High Court
RANA MUNEEB-UR-REHMAN
Advocate High Court
RIZWAN ASGHAR KAMBOH
Advocate High Court
VERIFICATION:
Verified on Oath at Ferozewala
on this 20th day of February 2017,
that the contents of written reply
are true and correct to the best
of my knowledge.
IN THE COURT OF MR. MOEEN KHOKHAR CIVIL
JUDGE FEROZEWALA DISTRICT SHEIKHUPURA.
Sui Northern Gas Pipeline Limited.
VERSUS
Muhammad Manzoor
(Suit for Recovery of Rs. 3,02,035/-)
APPLICATION FOR LEAVE TO DEFEND/CONTENTS
ON BEHALF OF RESPONDENT
AFFIDAVIT OF Muhammad Manzoor S/o Muhammad
Nawaz, R/o Mohallah Latif Park, Purana Narng
Road Muridke, Tehsil Muridke District
Sheikhupura.
I, the above named deponent to hereby
solemnly affirm/declare that the contents of
accompanying application are true and correct
with the best of my knowledge and believe.
DEPONENT
VERIFICATION:-
Verified on Oath at Ferozewala this 20th
day of February 2017 that all the contents of
above affidavit are true and correct to the
best of my knowledge and belief.
DEPONENT
