ex Parte Proof Naima Redacted

IN THE COURT OF [COURT REDACTED] AT KARACHI (EAST)

Civil Suit No. [REDACTED]/2024

Mr. [REDACTED] son of [REDACTED]-------------------- PLAINITFF

(Since Deceased through legal Heirs)

VS:

Mst. [REDACTED] D/O

Mr. [REDACTED] ------------------------------ DEFENDANT

EX PARTE PROOF ON BEHALF OF PLAINTIFF

I, [REDACTED] W/o [REDACTED], residing at H.No [REDACTED] 243-A, Block [REDACTED], P.E.C.H.S. [REDACTED]. [REDACTED], do hereby state on oath as under:-

That I say that the plaintiff agreed to purchase and the defendant agreed to sell/transfer and convey his immovable property viz. Residential Flat No [REDACTED] 12, fourth floor situated in the project named as “Al-Ahmed Lodge [REDACTED], of plot No:SB-51, in Block [REDACTED], situated at KDA Scheme No. [REDACTED], Gulshan-e-Iqbal [REDACTED], Karachi, measuring [AREA REDACTED] sq. yds. hereinafter referred to as the Said Property for a total sale consideration of Rs. [AMOUNT REDACTED] (Rupees [AMOUNT REDACTED])

That I say that the plaintiff took over the possession of the property along with the token money paid to the defendant along with the power of attorney duly registered in the name of Plaintiff and subsequently even plaintiff paid the whole amount also to the defendant for which Receipt/sale agreement full payment acknowledgement.

(Photocopy of Duly Registered General Power of Attorney and sale agreement is attached herewith marked as ‘A’ & ‘B’ respectively)

That I say that the plaintiff on the date of Agreement of Sale i.e. [DATE REDACTED] paid a sum of Rs. [AMOUNT REDACTED] 10,000/- (Rupees Five Lac and Ten Thousand Only) to the defendant as and by way of complete payment towards the sale consideration.

(Photocopy of the receipt executed by the defendant acknowledging Rs. [AMOUNT REDACTED] 10,000/- is annexed hereto and marked as annexure ‘C’.)

That I say that as per the said Agreement of Sale and general power of attorney, defendant handed over vacant and peaceful possession of the Said Property to the plaintiff at the time of General Power of Attorney of dated: [DATE REDACTED].

That I say that the plaintiff in his life time again and again requested to the Defendant to ex