IN THE COURT OF VI ADDITIONAL DISTRICT JUDGE
SOUTH AT KARACHI
Summary Suit No: 145/ 2018
Shakir Shaad
S/O Muhammad Younis Shaad,
through
attorney
Muammad
Kashif
S/O
Muhammad Habib ---------------------------Plaintiff
V/S
Muhammad
Khalid
S/o Gulfam.
--------------------------------------------Defendant
APPLICATION
UNDER ARTICLE 76 OF QSO,1984
R/W
SECTION 151 CPC
For
the reasons disclosed in the accompanying affidavit it is prayed on behalf of
the attorney of the plaintiff that this Hon’able court may be pleased to allow
the plaintiff to produce the secondary evidence of 2 cheques which are placed
on judicial record of XII Judicial Magistrate Karachi South in Case No.873/2018
and the same cheque bearing No.6113374, amounting Rs.150,000/-, dated
30-11-2015, Meezan Bank Ltd along with dishonored receipt dated 02-12-2015 was Exh-3/E
and Cheque No.6113371 , amounting Rs.200,000/-, dated 05-06-2014, Meezan
Bank Ltd., along with dishonored receipt dated 22-07-2014 was Exh-3/F
by the XII JM South at Karachi on 25-10-2018. It is submitted that due to the
serious accident of complainant namely Shakir Shaad, he could not get return
back from the trial court so that this Hon’able court may be pleased to allow
the attorney of the plaintiff to produce the certified copies of above 2 cheques before this Hon’able
court.
The prayer is
made in the interest of justice.
Karachi
Dated. -10-2019 Advocate
for Plaintiff
IN THE COURT OF VI ADDITIONAL DISTRICT JUDGE
SOUTH AT KARACHI
Summary Suit No: 145/ 2018
Shakir Shaad
S/O Muhammad Younis Shaad,
through
attorney
Muammad
Kashif
S/O
Muhammad Habib ------------------------------------------------------Plaintiff
V/S
Muhammad
Khalid
S/o
Gulfam. ------------------------------------------------------------------Defendant
AFFIDAVIT
I, Muammad
Kashif S/O Muhammad Habib, Muslim, adult
R/O House No.01, Shahjahan Building, Shoe Markeet, Nashter Road, Saddar,
Karachi through attorney of Shakir Shaad
S/o Muhammad Younis Shaad, do hereby state on oath as under :-
1. That I am the attorney of the plaintiff in
the above suit and deponent of this affidavit as such am fully conversant with
the facts of the case.
2.
That the accompanying APPLICATION U/A 76 of QSO, 1984 R/w U/S 151 CPC,
has been drafted and filed under my specific instructions, the contents whereof
I verily believe to be true and correct and may be treated as part and parcel
of this Affidavit for the sake of brevity.
3. That this honourable court has got
unfettered discretion to allow my application.
4. That unless the accompanied application
is allowed , I shall be seriously prejudiced and would suffer an irreparable
loss.
5. Whatever stated above is true and
correct to the best of my knowledge and belief.
Karachi.
Dated:
/10/2019 D
E P O N E N T
CNIC#___________________
Mob#____________________
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