Saeed
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MANAGER, NATIONAL BANK OF PAKISTAN, MUMTAZABAD, MULTAN. SUBJECT: -
LEGAL OPINION OF SUCCESSION CERTIFICATE UNDER SUCCESSION ACT IN CASE MST. SALMA BIBI VS. PUBLIC AT LARGE AND OTHERS.
Dear Sir, The succession certificate has been issued in favour of Mst. Salma Bibi, which empowers her to collect/receive the amount of Rs. 21391.59 along with interest (if any). According to my scrutiny, the succession certificate issued by Ch. Muhammad Siddique Senior Civil Judge, is genuine and the shares of the legal heirs are also correct. Hence presented for your kind perusal and further necessary action. Thanking you.
(SAEED HASSAN HASHMI) ADVOCATE HIGH COURT 40- AZIZ BLOCK, DISTRICT COURTS, MULTAN. BANK LEGAL ADVISOR.
MANAGER, NATIONAL BANK OF PAKISTAN, DERA ADDA BRANCH, MULTAN. SUBJECT: -
Request for the payment of 50% Professional Fee in Case: M/S Umar Straw Paper Vs. N.B.P.
Dear Sir, In the above-referred case, leave to defend as well as written reply to the application for the appointment of Commission has been submitted on behalf of National Bank of Pakistan. It is therefore, requested to pay my 50% (Rs. 25,000/-) professional fee in the above-mentioned case. Thanking you. Yours Sincerely,
(SAEED HASSAN HASHMI) ADVOCATE HIGH COURT, 40-AZIZ BLOCK, DISTRICT COURTS, MULTAN. BANK LEGAL ADVISOR.
1. In the Court of Mr. Muhammad Javed-ul-Hassnan Chishti Magistrate 1st Class, Multan.
Shabbir Ahmad @ Shiba s/o Ghulam Muhammad caste Mughal r/o Chak No.271/W.B Tehsil Duniapur, District Lodhran. (Accused/Petitioner) Versus The State.
(Respondent) In case FIR No.137/95 dated 23-3-95 Offence u/s 379/411 P.P.C. Police Station Cantt, Multan. Application under Section 249-A Cr.P.C. for the acquittal of accused/Petitioner.
Respectfully Sheweth:1. That the above captioned case is pending adjudication before this Hon’ble Court and is fixed for 10/6/99 for recording of prosecution evidence. 2. That brief facts giving rise to the instant application are that the above captioned case initially was got registered against unknown person and later on in local police planned a fake case and subsequently also shown a fake recovery from the accused/ Petitioner. 3. That the accused/Petitioner pray for his acquittal under section 249-A Cr.P.C. inter alia on following
GROUNDS a) That the charge against the accused/Petitioner is groundless. b) That there is nothing on the record to connect the accused/Petitioner with the commission of alleged offence. Moreover, the local police have shown a faked recovery from the Petitioner and actually nothing had been recovered from the Petitioner. c) That the complainant has failed to produce his evidence before this Hon’ble Court. This factum is also evident on the face of record that repeated summons of bailable and non-bailable were issued to the complainant as well as to the witnesses but non of them appeared before this court. This aspect of this case shows the insignificance and negligence on the part of the complainant and inference can very easily be drawn that he is not willing to prosecute the accused/Petitioner. d) That the accused/Petitioner is facing the agonies and worries of the case for about last 1-1/2 years without any fault on his part and the case is based on concoction and falsehood, as such the complainant has abused the process of the court. e) That strange enough to say that all the prosecution witnesses are not only related to each other rather they are inimical towards the accused/Petitioner and are very much interested to the complainant party for the prosecution of the accused/Petitioner in this false case. f) That the present case is outcome of malafide and ulterior motives and that the accused/Petitioner has been falsely implicated in this case on account of enmity. Moreover,
he is innocent as it has been proved from the evidence available on record. Under the above circumstances and submissions, it is most respectfully prayed that this application may kindly be accepted and that the accused/ Petitioner may very graciously be acquitted of the charge at this stage, in the supreme interest of justice. Humble Accused/Petitioner (Shabbir Ahmad) Dated: 08/06/99 Through: SAEED HASSAN HASHMI Advocate High Court 40-Aziz Block, District Courts, Multan.
In the Court of Mr. Muhammad Naeem Sheikh Civil Judge, Multan.
In re:Ghulam Mustafa
Vs.
Sui Northern Gas etc.
Suit for Declaration Written Statement on behalf of the defendants. Respectfully Sheweth:Preliminary objections. 1. That the suit is not maintainable in its present form. 2. That the plaintiff is estoped by his words and conduct. 3.
That the plaintiff has no cause of action to bring this suit, because a gas meter No. MG 24481963 was provided for domestic purposes but the plaintiff misused it and resultantly the gas supply was disconnected on 28.2.98 due to misuse of gas for commercial purposes. But later
on, secretly and illegally, the plaintiff connected his gas connection directly from the service line (unmetered gas) through rubber pipe and in this connection the respondents received a complaint from a member of Khidmat Committee Multan, on which on 5.4.99 a team comprising of the following members approached at the point where the gas was being misused (i) Mr. Naseemud-Din, Member Khidmat Committee (ii) Duty Magistrate 1st Class Multan. (iii) Sub-Engineer, Sui Northern Gas Multan and (iv) Representative from daily Khabrain Multan. So the above mentioned team removed the rubber pipe and stopped the direct use of gas. As such a cost of gas Rs.20,098/-, of gas pilfered by the plaintiff during the period from 1.3.98 to 5.4.99, was communicated vide letter No. MB:/470. It is worth mentioning here that on 9.4.99, the plaintiff himself submitted an affidavit through which he admitted that he is resident of Basti Bawa Safra, outside Daulat Gate, Multan and that he had been using gas in his shop for commercial purposes. He also promised that he would be careful in future. In the above mentioned affidavit, the plaintiff also requested that his gas meter may be reinstalled after receipt of dues. Copy of affidavit is attached herewith. As such the plaintiff, by misusing the domestic gas for commercial purposes and of stealing the gas directly through rubber pipe, has violated the terms and conditions of the contract signed by the plaintiff. 4. That the plaintiff has not come in court with clean hands because above mentioned consumer is a defaulter of
Rs.20,098.75 which includes the cost of gas pilfered and Government’s Central Excise Duty, as such has brought this suit only with the object to digest the above mentioned due amount. 5. That the suit of the plaintiff is not sustainable and is liable to be rejected under order 7 rule(11) of C.P.C. because of having no cause of action in the matter. 6. That the above captioned suit is liable to be dismissed with special costs u/s 35-A of C.P.C. Statement on Facts:1. That Para No.1 of the suit is absolutely incorrect, the house was never found locked and a family was continuously residing in the said premises/house. 2. That para No.2 of the suit is incorrect, the defendants had no litigation with the plaintiff in past. 3. That para No. 3 of the suit is incorrect, detail reply about arrears has been given in preliminary objections of Written Statement, moreover gas supply was disconnected due to misuse of domestic gas for commercial purposes. 4. That para No. 4 of the suit is absolutely incorrect, detail reply has been given in preliminary objections.
5. That para No. 5 of the suit is also absolutely incorrect and is not admitted as such. 6. That para No. 6 of the suit is incorrect, the plaintiff himself submitted affidavit, moreover regarding raid detailed reply has been given in preliminary objections. 7. That para No. 7 of the suit is incorrect and is not admitted. 8. That para No. 8 of the suit is incorrect, the plaintiff has no cause of action. 9. That para No. 9 of the suit is formal. 10.That para No. 10 of the suit is legal. Prayer of the suit is absolutely incorrect, based on malafide and ulterior motive therefore is liable to be dismissed with special costs and plaintiff may graciously be ordered to pay the cost of gas pilfered by the plaintiff as admitted by him in the attached affidavit. Humble Defendants. Through:-
Dated:- 22/06/99 Through:SAEED HASSAN HASHMI Advocate High Court, Seat No. 40-Aziz Block, District Courts, Multan. Verification:It is verified that the contents of the Written Statement are correct and true to the best of my knowledge and belief. Humble defendants. Through:
DEED OF RECONVEYANCE
L-15A HFSMTN-6873 ACCOUNT NO. 70601887-07
This INDENTURE made this _______day of March 2000 BETWEEN House Building Finance Corporation having its Head Office at F & T Centre, Karachi (hereinafter called the Corporation) of the one part and Mr. Syed Kazim Ali Shah s/o Syed Habib Shah residing at H. No. 1007 Rehman Colony Khanewal Road, Multan hereinafter called Partner of the other part. WHEREAS PARTNER availed of an investment of Rs. 100,000/- (Rupees One lac only) from the Corporation for the construction/purchase of the hose on Khasra No. 1487 and assigned the above said property in favour of the Corporation through a deed of Assignment and partnership registered in the office of District/Sub-Registrar on 3.3.90 at Multan in Book No. I Vol, No. 755 pages 269 to as No. 2692 hereinafter called the PRINICIPAL INDENTURE. NOW THIS INDENTURE WITNESSETH that in pursuance of the said agreement and in consideration of one premises the corporation doth heirs, executors, administrators and assigns ALL THAT piece of land bearing Khasra No. 1487 Khewat No. 953-880 Khatooni No. 1348 consisting of 5 marlas situated in Mauza Taraf Juma Khalsa in the jurisdiction of New Multan Police Station Taluka Sub District Multan more or less bounded on the North by House of Atta Ullah on the South by Street 12” wide on the East by Street 12” wide on the West by Plot of M. Bashir together with the dwelling house, or houses, stables, cook rooms and out building thereon AND ALL and singular other premises in the PRINCIPAL INDENTURE comprises or expressed to be hereby assured or which nowhere by any means vested in the Assignment and subject to redemption/Release/ Relinquish under or by virtue f the PRINCIPAL INDENTURE expressed. AND ALL THE estates, right, title interest, property claim and demand whatsoever of the corporation into out of an or upon the same premises heretofore expressed to use HEREBY reconveyed, granted, released, relinquished not in favour of and to the use of the PARTNER his/her heirs, executors, administrators and assign forever fraud and all discharged from all partnership money intended to be secured by the PRINCIPAL INDENTURE and from all action, suits, accounts, claims and demands for or in respect of the said money partnership or any part thereof or for, in respect the PRINCIPAL INDENTURE or of anything relating to the premises AND THE CORPORATION hereby covered with the partners to the premises AND THE CORPORATION hereby covered with the partners his/her heirs, executors, administrators and assigns that the Corporation has not done or knowingly suffered on any part thereof are, in or can be impeached encumbered or affected in titled estate or other howsoever. IN WITNESS WHEREOF the parties hereto have hereunto their hand seals the day and year first above written.
WITNESS.
FOR AND ON BEHALF OF THE MANAGER HOUSE BUILDING FINANCE CORPORATION MUTLAN. 1___________ 2____________ PARTNER Mst. Mussarat Parween w/o Kazim Ali Shah
LEGAL OPINION OF SUCCESSION CERTIFICATE UNDER SUCCESSION ACT IN CASE MST. SALMA BIBI VS. PUBLIC AT LARGE AND OTHERS.
Dear Sir, The succession certificate has been issued in favour of Mst. Salma Bibi, which empowers her to collect/receive the amount of Rs. 21391.59 along with interest (if any). According to my scrutiny, the succession certificate issued by Ch. Muhammad Siddique Senior Civil Judge, is genuine and the shares of the legal heirs are also correct. Hence presented for your kind perusal and further necessary action. Thanking you.
(SAEED HASSAN HASHMI) ADVOCATE HIGH COURT 40- AZIZ BLOCK, DISTRICT COURTS, MULTAN. BANK LEGAL ADVISOR.
MANAGER, NATIONAL BANK OF PAKISTAN, DERA ADDA BRANCH, MULTAN. SUBJECT: -
Request for the payment of 50% Professional Fee in Case: M/S Umar Straw Paper Vs. N.B.P.
Dear Sir, In the above-referred case, leave to defend as well as written reply to the application for the appointment of Commission has been submitted on behalf of National Bank of Pakistan. It is therefore, requested to pay my 50% (Rs. 25,000/-) professional fee in the above-mentioned case. Thanking you. Yours Sincerely,
(SAEED HASSAN HASHMI) ADVOCATE HIGH COURT, 40-AZIZ BLOCK, DISTRICT COURTS, MULTAN. BANK LEGAL ADVISOR.
1. In the Court of Mr. Muhammad Javed-ul-Hassnan Chishti Magistrate 1st Class, Multan.
Shabbir Ahmad @ Shiba s/o Ghulam Muhammad caste Mughal r/o Chak No.271/W.B Tehsil Duniapur, District Lodhran. (Accused/Petitioner) Versus The State.
(Respondent) In case FIR No.137/95 dated 23-3-95 Offence u/s 379/411 P.P.C. Police Station Cantt, Multan. Application under Section 249-A Cr.P.C. for the acquittal of accused/Petitioner.
Respectfully Sheweth:1. That the above captioned case is pending adjudication before this Hon’ble Court and is fixed for 10/6/99 for recording of prosecution evidence. 2. That brief facts giving rise to the instant application are that the above captioned case initially was got registered against unknown person and later on in local police planned a fake case and subsequently also shown a fake recovery from the accused/ Petitioner. 3. That the accused/Petitioner pray for his acquittal under section 249-A Cr.P.C. inter alia on following
GROUNDS a) That the charge against the accused/Petitioner is groundless. b) That there is nothing on the record to connect the accused/Petitioner with the commission of alleged offence. Moreover, the local police have shown a faked recovery from the Petitioner and actually nothing had been recovered from the Petitioner. c) That the complainant has failed to produce his evidence before this Hon’ble Court. This factum is also evident on the face of record that repeated summons of bailable and non-bailable were issued to the complainant as well as to the witnesses but non of them appeared before this court. This aspect of this case shows the insignificance and negligence on the part of the complainant and inference can very easily be drawn that he is not willing to prosecute the accused/Petitioner. d) That the accused/Petitioner is facing the agonies and worries of the case for about last 1-1/2 years without any fault on his part and the case is based on concoction and falsehood, as such the complainant has abused the process of the court. e) That strange enough to say that all the prosecution witnesses are not only related to each other rather they are inimical towards the accused/Petitioner and are very much interested to the complainant party for the prosecution of the accused/Petitioner in this false case. f) That the present case is outcome of malafide and ulterior motives and that the accused/Petitioner has been falsely implicated in this case on account of enmity. Moreover,
he is innocent as it has been proved from the evidence available on record. Under the above circumstances and submissions, it is most respectfully prayed that this application may kindly be accepted and that the accused/ Petitioner may very graciously be acquitted of the charge at this stage, in the supreme interest of justice. Humble Accused/Petitioner (Shabbir Ahmad) Dated: 08/06/99 Through: SAEED HASSAN HASHMI Advocate High Court 40-Aziz Block, District Courts, Multan.
In the Court of Mr. Muhammad Naeem Sheikh Civil Judge, Multan.
In re:Ghulam Mustafa
Vs.
Sui Northern Gas etc.
Suit for Declaration Written Statement on behalf of the defendants. Respectfully Sheweth:Preliminary objections. 1. That the suit is not maintainable in its present form. 2. That the plaintiff is estoped by his words and conduct. 3.
That the plaintiff has no cause of action to bring this suit, because a gas meter No. MG 24481963 was provided for domestic purposes but the plaintiff misused it and resultantly the gas supply was disconnected on 28.2.98 due to misuse of gas for commercial purposes. But later
on, secretly and illegally, the plaintiff connected his gas connection directly from the service line (unmetered gas) through rubber pipe and in this connection the respondents received a complaint from a member of Khidmat Committee Multan, on which on 5.4.99 a team comprising of the following members approached at the point where the gas was being misused (i) Mr. Naseemud-Din, Member Khidmat Committee (ii) Duty Magistrate 1st Class Multan. (iii) Sub-Engineer, Sui Northern Gas Multan and (iv) Representative from daily Khabrain Multan. So the above mentioned team removed the rubber pipe and stopped the direct use of gas. As such a cost of gas Rs.20,098/-, of gas pilfered by the plaintiff during the period from 1.3.98 to 5.4.99, was communicated vide letter No. MB:/470. It is worth mentioning here that on 9.4.99, the plaintiff himself submitted an affidavit through which he admitted that he is resident of Basti Bawa Safra, outside Daulat Gate, Multan and that he had been using gas in his shop for commercial purposes. He also promised that he would be careful in future. In the above mentioned affidavit, the plaintiff also requested that his gas meter may be reinstalled after receipt of dues. Copy of affidavit is attached herewith. As such the plaintiff, by misusing the domestic gas for commercial purposes and of stealing the gas directly through rubber pipe, has violated the terms and conditions of the contract signed by the plaintiff. 4. That the plaintiff has not come in court with clean hands because above mentioned consumer is a defaulter of
Rs.20,098.75 which includes the cost of gas pilfered and Government’s Central Excise Duty, as such has brought this suit only with the object to digest the above mentioned due amount. 5. That the suit of the plaintiff is not sustainable and is liable to be rejected under order 7 rule(11) of C.P.C. because of having no cause of action in the matter. 6. That the above captioned suit is liable to be dismissed with special costs u/s 35-A of C.P.C. Statement on Facts:1. That Para No.1 of the suit is absolutely incorrect, the house was never found locked and a family was continuously residing in the said premises/house. 2. That para No.2 of the suit is incorrect, the defendants had no litigation with the plaintiff in past. 3. That para No. 3 of the suit is incorrect, detail reply about arrears has been given in preliminary objections of Written Statement, moreover gas supply was disconnected due to misuse of domestic gas for commercial purposes. 4. That para No. 4 of the suit is absolutely incorrect, detail reply has been given in preliminary objections.
5. That para No. 5 of the suit is also absolutely incorrect and is not admitted as such. 6. That para No. 6 of the suit is incorrect, the plaintiff himself submitted affidavit, moreover regarding raid detailed reply has been given in preliminary objections. 7. That para No. 7 of the suit is incorrect and is not admitted. 8. That para No. 8 of the suit is incorrect, the plaintiff has no cause of action. 9. That para No. 9 of the suit is formal. 10.That para No. 10 of the suit is legal. Prayer of the suit is absolutely incorrect, based on malafide and ulterior motive therefore is liable to be dismissed with special costs and plaintiff may graciously be ordered to pay the cost of gas pilfered by the plaintiff as admitted by him in the attached affidavit. Humble Defendants. Through:-
Dated:- 22/06/99 Through:SAEED HASSAN HASHMI Advocate High Court, Seat No. 40-Aziz Block, District Courts, Multan. Verification:It is verified that the contents of the Written Statement are correct and true to the best of my knowledge and belief. Humble defendants. Through:
DEED OF RECONVEYANCE
L-15A HFSMTN-6873 ACCOUNT NO. 70601887-07
This INDENTURE made this _______day of March 2000 BETWEEN House Building Finance Corporation having its Head Office at F & T Centre, Karachi (hereinafter called the Corporation) of the one part and Mr. Syed Kazim Ali Shah s/o Syed Habib Shah residing at H. No. 1007 Rehman Colony Khanewal Road, Multan hereinafter called Partner of the other part. WHEREAS PARTNER availed of an investment of Rs. 100,000/- (Rupees One lac only) from the Corporation for the construction/purchase of the hose on Khasra No. 1487 and assigned the above said property in favour of the Corporation through a deed of Assignment and partnership registered in the office of District/Sub-Registrar on 3.3.90 at Multan in Book No. I Vol, No. 755 pages 269 to as No. 2692 hereinafter called the PRINICIPAL INDENTURE. NOW THIS INDENTURE WITNESSETH that in pursuance of the said agreement and in consideration of one premises the corporation doth heirs, executors, administrators and assigns ALL THAT piece of land bearing Khasra No. 1487 Khewat No. 953-880 Khatooni No. 1348 consisting of 5 marlas situated in Mauza Taraf Juma Khalsa in the jurisdiction of New Multan Police Station Taluka Sub District Multan more or less bounded on the North by House of Atta Ullah on the South by Street 12” wide on the East by Street 12” wide on the West by Plot of M. Bashir together with the dwelling house, or houses, stables, cook rooms and out building thereon AND ALL and singular other premises in the PRINCIPAL INDENTURE comprises or expressed to be hereby assured or which nowhere by any means vested in the Assignment and subject to redemption/Release/ Relinquish under or by virtue f the PRINCIPAL INDENTURE expressed. AND ALL THE estates, right, title interest, property claim and demand whatsoever of the corporation into out of an or upon the same premises heretofore expressed to use HEREBY reconveyed, granted, released, relinquished not in favour of and to the use of the PARTNER his/her heirs, executors, administrators and assign forever fraud and all discharged from all partnership money intended to be secured by the PRINCIPAL INDENTURE and from all action, suits, accounts, claims and demands for or in respect of the said money partnership or any part thereof or for, in respect the PRINCIPAL INDENTURE or of anything relating to the premises AND THE CORPORATION hereby covered with the partners to the premises AND THE CORPORATION hereby covered with the partners his/her heirs, executors, administrators and assigns that the Corporation has not done or knowingly suffered on any part thereof are, in or can be impeached encumbered or affected in titled estate or other howsoever. IN WITNESS WHEREOF the parties hereto have hereunto their hand seals the day and year first above written.
WITNESS.
FOR AND ON BEHALF OF THE MANAGER HOUSE BUILDING FINANCE CORPORATION MUTLAN. 1___________ 2____________ PARTNER Mst. Mussarat Parween w/o Kazim Ali Shah
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