IN THE COURT OF MIAN RIAZ KHURRAM, CIVIL JUDGE

MUTLAN.

AMENDED PLAINT

Suit No. ____________/2001

Malik Sagheeruddin S/o Malik Shabbir Ahmad, caste Khokhar, R/o

6-A, Sughran Haveli, Mall Godown Road, Chowk Shaheedan,
Multan.
……Plaintiff
VERSUS

1. Mst. Meena Begum W/o Liaqat Hussain D/o Taj Muhammad,

caste Jat Chaughatta, R/o Walayatabad Colony, Multan.

2. Liaqat Hussain S/o unknown caste Jat Chaughatta, R/o

Walayatabad Colony, Multan.

……Defendants

Suit for possession by way of specific

performance of contract with respect to
agricultural land located in Khewat No. 520
in black ink and 500 in red ink, Khatooni
numbers 993 to 999, total Qitat 166, area
transferred 40K—17M situated at Mauza
Sher Shah Tehsil & District Multan,
according to Register Haqdaran-e-Zameen
pertaining to the year 1994-95 (hereinafter
called the disputed property for the sake of
brevity) and suit for permanent injunction
as a consequential relief restraining the
defendants from interfering into the lawful
, ownership, alienating the
possession, use and enjoyment of plaintiff
over and in respect of the suit land for all
time to come.

Respectfully Sheweth: -
1. That the plaintiff is owner-in-possession of the suit property
according to agreement dated 21.7.97 in between the parties
and defendants have no concern whatsoever with the suit land.
1-A. That the amended plaint is submitted by the orders of this
Hon’ble Court vide order dated 13.9.2002.
2. That briefly stated the facts of the case, which are relevant for
the rightful decision of this case in hand are that the parties are
relatives and relation in between the two are very cordial and
friendly and they visit each others residence off and on. The
defendants desired to dispose of the disputed property and on
their persuation, the plaintiff agreed to purchase the disputed
land from defendant No. 1 and finally on 25.8.95 a bargain
was struck in between the parties, which is as follows: -
a) That the total price of the disputed land measuring 40K
—17M was fixed as Rs. 445,500/- and out of which
defendants received Rs. 376,500/- through two different
cheques No. C-31/A 644858 Account No. 2551 dated
4.9.95 Branch United Bank Ltd. Old Sabzi Mandi Road,
Multan, amounting to Rs. 40,000/- (forty thousand
rupees only) and another cheque No. C-31 64461A of
A/c No. 2551 dated 30.11.95 of U.B.L. of Old Sabzi
Mandi Road Branch, Multan amounting to Rs.
336,500/-. It is worthwhile to mention here that the
defendants received Rs. 376,500/- through cheques and
at that time the agreement in between the parties was
oral. After that on 21.7.97 the defendant No. 1 received
the remaining balance amount of Rs. 69,000/- net cash
from the plaintiff in the presence of witnesses and wrote
an agreement in favour of plaintiff. It is pertinent to
mention over here that defendant No. 1 requested the
plaintiff to issue the cheques in the name of defendant
No. 2 her husband, because as she is a purdanasheen
lady and cannot collect the money from the bank, on
her request the plaintiff issued two cheques amounting
to Rs. 376,500/- in the name of defendant No. 2 her
husband, which fact is duly acknowledged by her in the
agreement so the defendant is being made a party in the
instant suit.
b) That it was agreed between the parties that some land of
the Mauza is under acquisition and also of the parties,
the defendants are duty bound and under legal
 obligation to get the disputed property transferred in the
name of plaintiff after the completion of acquisition
proceedings.
3. That the possession of the disputed property was handed over
to the plaintiff by the defendants at the time when the bargain
was struck in between the parties and the plaintiff is in
continuous possession thereof.
4. That as above said some of the land out of the total land
belonging to defendant No. 1 was under acquisition by the
Government and in this way a ban was imposed for transfer of
the land in dispute, so it was agreed in between the parties that
after the finalization of acquisition proceeding the transfer of
disputed property shall be concluded after eight months of
finalization of acquisition and in this respect it was incumbent
upon the defendants to inform the plaintiff through a written
notice, but unfortunately inspite of the fact that acquisition
proceedings came to an end on 19.1.98, when the award was
announced regarding the required land of the defendant No. 1.
And uptill now no notice as said supra has been served to the
plaintiff by the defendants. However, the plaintiff repeatedly
apprised of this fact to the defendants but to no effect.
5. That the plaintiff tried his level’s best to get the sale deed
registered in his favour, but unfortunately, the defendants
refused to do so uptill today.
6. That the defendants have been asked time and again that the
plaintiff is owner-in-possession with respect to an agricultural
land mentioned in the head note of the suit and the defendants
have no concern whatsoever with the suit property and
defendant No. 1 is under legal obligation to get the same
transferred in the name of plaintiff, but they are using dilly
dally tactics and a week ago they have flatly refused to accede
to the request of the plaintiff, hence, the necessity to file
instant suit has arisen.
7. That the cause of action accrued to the plaintiff against the
defendants a week ago from the flat refusal of the defendants.
8. That the parties reside in Multan, disputed property is situated
in Multan and cause of action also accrued to the plaintiff
 against the defendants in Multan, therefore, this Hon’ble
Court at Multan has got the jurisdiction to try the suit.
9. That the value of the suit for the purpose of court fee and
jurisdiction is fixed at Rs. 445,500/-.
PRAYER: -

In view of the above circumstances, it is humbly

prayed that a decree for possession by way of specific
performance of contract with respect to agricultural land
located in Khewat No. 520 in black ink and 500 in red ink,
Khatooni numbers 993 to 999, total Qitat 166, area
transferred 40K—17M situated at Mauza Sher Shah Tehsil
& District Multan, according to Register Haqdaran-e-
Zameen pertaining to the year 1994-95 (hereinafter called
the disputed property for the sake of brevity) and decree
for permanent injunction as a consequential relief
restraining the defendants from interfering into the lawful
, ownership, alienating the possession, use
and enjoyment of plaintiff over and in respect of the suit
land for all time to come may kindly be passed in favour
of the plaintiff against the defendants with costs.
Humble Plaintiff,
Dated: _________
Through: -
Aamer Aziz Qazi,
Advocate High Court,
123-District Courts,
Multan.
Verification: -
Verified on oath at Multan that the
contents of all paras of this plaint are
correct and true to the best of my
knowledge and belief.
Plaintiff