IN THE COURT OF SENIOR CIVIL JUDGE DADU
Mst. ABC
W/O Cast R/O
Tehsil & District Dadu ……….......................................….PLAINTIFF
VS.
FDA S/O
M.D. Cast R/o
Tehsil&
District Dadu ……….................................……..DEFENDANT
SUIT FOR ACCOUNT.
Respectfully Sheweth:
1) That the late husband of the plaintiff Al-Hajj Almas Khan was owner
of Flour Mill Known in the name and style of Fazal Karim Flour Mills Shahdara
Dadu.
2) That Almas Khan husband of the plaintiff met an accident
inDecemberlast and died at the spot having received headinjuries which proved
fatal.
3) That the defendant is in possession of the said Mill Manager.
Having been appointed by late husband of the plaintiff three years back.
4) That as a manager of the mill the defendant has been keeping the
account. It may be stated that since the death of late Almas Khan the mill in
question is running day and night under the supervision of the defendant and
has earned lacs of rupees as profit.
5) That as per term of the appointment defendant was assigned the
duties of keeping the true account and rendering the same to the owners of the
mills six monthly.
6) That the plaintiff is wife of Almas Khan the owner of the mill and
is entitled one half share of his estate as well as the income. Profits earned
from the property in question.
7) That the account of the mill are in possession of the defendant
but inspite of laps of more than one year the defendant has not tendered the
same or paid any amount of the earned profits so far to the plaintiff.
8) That legal notice was served on the defendant to do the needful but
of no avail, hence this suit.
9) That cause of action accrued in favour of the plaintiff and
against the defendant in December last year when the husband of the plaintiff,
Almas Khan dead of accident. It further accrued on expiry of sixmonth when the
defendant was in terms of his contract to render the bones and again in
December this year when the defendant has fail to render the accounts for this year
and for the proceedings years. It has finally reason at ten days back when the
defendant flatly refused to tender the accounts to the plaint.
10) That the plaintiff does not no the exact amounts of profits accrued. Hence the present suit is
tendively valued at Rs. for
which proper court fees of Rs. has
been affixed. The balance if any shall be made good after the actual amount is determined
by this Honourable court the payable to the plaint.
11) That the parties reside at Dadu where the suit property situates
and cause of action accrued therefore this honourable Court has jurisdiction to
adjudicate upon the matter.
Prayer
It is prayed that defendant
may be directed to produce true accounts for the last two years so as to be
appropriated in accordance with Shahria among us the legal hires of the
deceased Almas Khan under the Muhammadan law. Plaintiff being the sole wife of
late Almas Khan is entitled to one half of the total estate/profits, said Almas
Khan being died issue less. Is parents have already expired five years ago.
Any relief which
this honourable Court may deem fit is further prayed.
S.D.Plaintiff
Through
Councel
Verification:
Verified on oath at
Dadu of 20 that the contents of paraNo.1-8 are true to the best of
my knowledge and that the paras 9-11 correct to the best of my belief.
wao
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