IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

Suit No. ____/24

________________________,
Resident of ______________________, Karachi.
…Plaintiff

VERSUS

1. ________________________, through its Director General, ___________________________, Lahore.

2. ________________________, through its General Manager, ___________________________, Lahore.

3. Director (Revenue), ___________________________, Lahore.

4. Divisional Engineer, ___________________________, Lahore.
   …Defendants

SUIT FOR DECLARATION AND PERMANENT INJUNCTION

Respectfully Sheweth:

1. That the plaintiff is a professional specialist and a respectable citizen. He is the lawful owner of Office No. ___, Floor ___, situated at ___________________________, Lahore (hereinafter “the premises”).

2. That the plaintiff has always retained possession of the premises either directly or through a tenant, Mr. ____________. On ___________, the plaintiff received two telephone bills for numbers ___________ and ___________, amounting to Rs. ______ and Rs. ______ respectively.

3. That the plaintiff contacted the defendants, stating that these numbers were never installed at his property. In good faith, he acted against his tenant; however, it was confirmed that no such telephone lines were ever physically installed at the premises.

4. That the plaintiff issued a legal notice through his counsel, requesting proper investigation. Defendant No. 4 responded via letter No. __________ dated ___________, claiming the numbers were issued in the name of Mr. __________ at the plaintiff’s address. The plaintiff denies any relationship or agreement with this person and reiterates that these phones were never present at the property.

5. That the plaintiff never applied for, authorized, nor installed any such telephone connections at the premises. Therefore, the related telephone bills are wrongful, baseless, and infringe upon the plaintiff’s legal rights.

6. That the impugned actions by the defendants are arbitrary and in violation of legal norms, causing undue harm to the plaintiff. The cause of action initially arose upon delivery of the disputed bills and continued with the defendants’ reply to the legal notice.

7. That since the property, cause of action, and parties are all situated in Lahore, this Honourable Court has jurisdiction.

8. That the suit is valued at Rs. ______ for jurisdiction purposes, which is exempt from court fee.

PRAYER

In light of the above, it is respectfully prayed that this Honourable Court may graciously be pleased to:

i. Declare that telephone connections bearing numbers ___________ and ___________ were never installed at the plaintiff’s premises;

ii. Declare that the plaintiff is not liable to pay any bills relating to these numbers;

iii. Restrain the defendants from recovering or enforcing the said dues from the plaintiff in any manner whatsoever during the pendency of this suit;

iv. Grant any other relief deemed appropriate in the interest of justice.

PLAINTIFF
Through Counsel

Advocate High Court
(Address & Credentials Hidden)

VERIFICATION

Verified on oath at Lahore this ___ day of __________ 20__ that the contents of paragraphs 1 to 6 are true and correct to the best of my knowledge and the remaining paragraphs are true to the best of my belief.

PLAINTIFF

IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

In re:

________________________
Versus
________________________ & Others

(Suit for Declaration)

**APPLICATION UNDER ORDER 39 RULE 1 & 2 READ WITH SECTION 151 CPC

FOR GRANT OF TEMPORARY INJUNCTION**

Respectfully Sheweth:

1. That the plaintiff has filed the accompanying suit before this Honourable Court; it is pending and not yet fixed for hearing.

2. That the contents of the plaint are adopted and made part of this application.

3. That the plaintiff has a strong prima facie case.

4. That the balance of convenience also lies in the plaintiff’s favour.

5. That if the defendants are not restrained, the plaintiff will suffer irreparable harm as he is being unjustly burdened with unlawful demands.

PRAYER

In view of the foregoing, it is respectfully prayed that:

• The defendants may kindly be restrained from enforcing or recovering the impugned amounts through the disputed bills until final decision of the suit;

• An interim injunction to this effect may also be granted.

APPLICANT
Through Counsel

Advocate High Court
(Address & Credentials Hidden)

IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

In re:
________________________
Versus
________________________ & Others

(Suit for Declaration)

AFFIDAVIT

I, _____________________, S/o _____________________, Resident of _____________________, Lahore Cantt., do hereby solemnly affirm and declare as under:

• That the contents of the accompanying application under Order 39 Rule 1 & 2 CPC are true and correct to the best of my knowledge and belief.

Deponent

VERIFICATION

Verified on oath at Lahore this ___ day of __________ 20__ that the contents of the above affidavit are true and correct to the best of my knowledge and belief.

Deponent