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In re:
Wazeer Ahmad Vs. Small Business Finance
Corporation Vehari etc.
Respectfully Sheweth:-
Humble Respondent.
Through: -
Through:-
SAEED HASSAN HASHMI MANAGER (SBFC)
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
IN THE COURT OF MALIK AHMAD BAKHSH BHAPA, JUDGE
BANKING COURT NO-I, MULTAN.
In re:
Wazeer Ahmad Vs. Small Business Finance
Corporation Vehari etc.
AFFIDAVIT of: -
Mushtaq Sarwar District Manager Small Business
Finance Corporation, Vehari.
Deponent.
Verification: -
Verified on oath at Multan, this_____
day of July, 1999 that the contents of this affidavit
are true to the best of my knowledge and belief.
Deponent
IN THE COURT OF MALIK AHMAD BAKHSH BHAPA, JUDGE
BANKING COURT NO-I, MULTAN.
In re:
Wazeer Ahmad Vs. Small Business Finance
Corporation Vehari etc.
Memo of Appearance
Respectfully Sheweth:-
1. That the above titled suit is pending adjudication before this
Hon’ble Court and is fixed for today.
Through:-
In re:
M/s Union Straw Paper Industries (Pvt) Limited and another.
Versus
National Bank of Pakistan and others.
Respectfully Sheweth:-
1. That the above titled suit is pending adjudication before this
Hon’ble Court and is fixed for 21.09.99.
3. That the brief facts giving rise to the instant application are that the
National Bank of Pakistan brought a suit for recovery of loan of
Rs. 9527954/- against the M/s Union Straw Papers (Pvt) Limited
through Ch. Muhammad Saleem, the Managing Director and
Ch. Ali Ahmad Tariq, the Director. The above-referred suit was
brought before the Court on 08.10.97 and the suit is pending
adjudication and is fixed for 21.09.99 for recording of ex-parte
evidence of the Plaintiff Bank.
9. That the suit is not maintainable in the eye of law and that the
Plaintiffs have no cause of action or locus standi for bringing the
instant suit.
11.That the Plaintiffs have filed the titled suit without any cogent and
convincing reasons. They intend to ususrp the loan amount
obtained by them. The valuable rights of the applicant are involved
in the matter which require necessary probe for the purpose of
determination their rights in the matter so as to bring on record the
relevant agreement, papers, factual position and description of loan
in a shape of evidence. It shall only be possible in case if the
applicants are given an opportunity of being heard. The titled suit
is also badly time barred.
Under the above circumstances and submissions, it
is most respectfully prayed that this application
may kindly be allowed and that the applicants/
defendants No. 1 & 2 may kindly be afforded an
opportunity to defend the titled suit, in the supreme
interest of justice.
An affidavit is attached.
Humble applicants
1. Defendant No. 1
Through: - Zonal Chief
2. Defendant No. 2
Through: - Manager
National Bank of Pakistan
Dera Adda Branch, Multan.
Through:-
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
IN THE COURT OF CHAUDHARY MUHAMMAD KHALIL,
JUDGE BANKING COURT NO-II, MULTAN.
In re:
M/s Union Straw Paper Industries (Pvt) Limited and another.
Versus
National Bank of Pakistan and others.
AFFIDAVIT
Deponent
Verification: -
Verified on oath at Multan, this_____
day of August, 1999 that the contents of this
affidavit are true to the best of my knowledge and
belief.
Deponent
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.
IN RE:
W.P. No.4884/1999
PARAWISE COMMENTS ON
BEHALF OF THE RESPONDENTS.
Respectfully Sheweth: -
1. That Para No. 1 of the Writ Petition is not known to the replying
Respondent.
3. That Para No. 3 of the Writ Petition is correct to the extent that
the Petitioner obtained Rs. 100,000/- from the Respondent but
loan amount was disbursed in 1994, rest of the Para is incorrect.
The Petitioner himself winded up the said business without prior
permission of Respondents and has misappropriated the loan
amount.
Prayer: -
Prayer clause of the Petitioner under reply is
unwarranted by law and facts of the case, as such is
absolutely incorrect, under the above circumstances and
terms, it is most respectfully prayed that this Petition may
very graciously be dismissed with costs.
Dated: __________
Humble Respondent
Through: -
Manager,
Small Business Finance
Corporation, Vehari.
Through: -
IN RE:
W.P. No.4884/1999
Respectfully Sheweth: -
1. That the Respondent is filing the photo state copies of the
Annexures “A & B” with the Writ Petition as the certified copies
of the same are not readily available with the Respondent. The
same shall be submitted as and when this August Court directs.
Respondent
Through: -
Manager,
Small Business Finance
Corporation, Vehari.
Through:-
IN RE:
W.P. No.4884/1999
AFFIDAVIT of:-
Manager Small Business Finance Corporation,
Vehari.
DEPONENT
Manager,
Small Business Finance
Corporation, Vehari.
Verification: -
Verified on oath at Multan, this_____
day of September, 1999 that the contents of this
affidavit are true to the best of my knowledge and
belief.
DEPONENT
Manager,
Small Business Finance
Corporation, Vehari.
IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN.
VERSUS
Abdul Hameed S/o Haji Abdul Aziz, Nan Farosh, Shop No. 1485/8,
Chowk Lakkar Mandi, Multan.
DEFENDANT
Respectfully Sheweth: -
1. That the Plaintiff is a Public Limited Company duly incorporated
under the Companies Act, 1913 (Now Companies Ordinance
1984) having its registered office at Gas House, 21-Kashmir
Road Lahore and Regional office situated at Piran Ghaib Road,
Multan.
8. That the cause of action in favour of the Plaintiff and against the
defendant accrued at the time of commencement of original
agreement for the supply of gas when the gas was commissioned
and thereafter when the supply of gas was disconnected on
28.4.98 and was advised to pay the outstanding gas bill but the
defendant failed to clear the same and finally a week ago when
the defendant refused to make payment of the total outstanding
amount of Rs. 44,341/-.
9. That the cause of action arose within the limits of Tehsil &
District Multan as the defendant resides in Multan; therefore, this
Court has jurisdiction to adjudicate upon this suit.
10. That the value of the suit for the purpose of Court fee and
jurisdiction is fixed as Rs. 53,440/- for which, Court fee of Rs.
4010/- is fixed under this law.
HUMBLE PLAINTIFF
Through: -
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
Verification: -
Verified on oath at Multan this _____
day of ________ 2001 that para No. 1
to 6 are correct to the best of my
knowledge and remaining paras are
true to the best of my information.
PLAINTIFF
IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN.
VERSUS
Respectfully Sheweth: -
1. That the Plaintiff is a Public Limited Company duly incorporated
under the Companies Act, 1913 (Now Companies Ordinance
1984) having its registered office at Gas House, 21-Kashmir
Road Lahore and Regional office situated at Piran Ghaib Road,
Multan.
8. That the cause of action in favour of the Plaintiff and against the
defendant accrued at the time of commencement of original
agreement for the supply of gas when the gas was commissioned
and thereafter when the supply of gas was disconnected on
29.07.97 and was advised to pay the outstanding gas bill but the
defendant failed to clear the same and finally a week ago when
the defendant refused to make payment of the outstanding
amount of Rs. 104,232.76.
9. That the cause of action arose within the limits of Tehsil &
District Multan as the defendant resides in Multan; therefore, this
Court has jurisdiction to adjudicate upon this suit.
10.That the value of the suit for the purpose of Court fee and
jurisdiction is fixed as Rs. 104,232.76 for which Court fee of
Rs.__________ has been paid according to law.
HUMBLE PLAINTIFF
Through: -
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
Verification: -
Verified on oath at Multan this _____
day of ________ 2000 that para No. 1
to 6 are correct to the best of my
knowledge and remaining paras are
true to the best of my information.
PLAINTIFF
Respctfully Sheweth: -
1. That brief facts giving rise to the instant bail Petition are that
Abdul Razzaq, lodged a report in Police Station City Mailsi on
16.4.1997 Under Sections 302/324/148/149/109 P.P.C wherein he
alleged that Naveed, Mukhtar, Adil, Muhammad Muneer and
Muhammad Hussain along with three unknown persons fired
upon Mushtaq Ahmad as well as at the Jeep carrying other
victims which resulted in the death of Mushtaq Ahmad, Noor
Muhammad and Muhammad Arif. Hence, this case against the
accused/Petitioner.
GROUNDS
PRAYER: -
In the light of the above cricumstances, it is most
respectfully prayed that this petition may kindly be accepted
and the accused/petitioner may kindly be enlarged on bail, in
the supreme interest of justice.
Humble Petitioner
Through:-
Dear Sir,
With reference to your letter No. LD (lit) 4 (43)/99/821 dated
2.12.99, it is humbly submitted that I have been practicing as an advocate
of High Court as well as Lower Courts since 1994. I have sufficient
experience regarding Banking matters and High Court cases. I ensure that
I would conduct the court cases on behalf of A.D.B.P. very diligently and
with the best of my efforts, it is therefore, most respectfully requested that
the name of undersigned may kindly be included on the Panel of
Advocates of A.D.B.P. Vehari & Multan by relaxing the rules and by also
treating the case of undersigned as a special case.
I shall be highly obliged.
Yours sincerely,
Dated: 24.02.2000
SAEED HASSAN HASHMI,
Advocate High Court,
40-Aziz Block, District Courts,
Multan.
Ph # 061-521253, 0300-639296
Vehari: 0693-696196
To,
The Chief Engineer,
PARCO (Mehmood Kot)
District Muzaffargarh.
Respected Sir,
I beg leave to state that I have come to know through some reliable
sources that some posts of Technologist/Boiler Foreman are lying vacant
under your kind control. I offer my services for one of them. My complete
Bio-data is as under: -
Yours Faithfully,
Dated: ________
Iqbal Hussain