Sample Property Suit

IN THE COURT OF SR. CIVIL JUDGE AT KARACHI (EAST)

SUIT NO. OF 2024

[PLAINTIFF 1 NAME] son of [PLAINTIFF 1 FATHER NAME] (Since Deceased) legal Heirs;

[PLAINTIFF 2 NAME] son of Murad Ali

[PLAINTIFF 3 NAME] S/o Murad Ali

[PLAINTIFF 4 NAME] son of Murad Ali(Since Deceased) legal Heirs;

[PLAINTIFF 4 WIFE NAME] wife of [PLAINTIFF 4 NAME]

[MINOR NAME] daughter of [PLAINTIFF 4 NAME], Minor

[PLAINTIFF 5 NAME] wife of [PLAINTIFF 5 HUSBAND NAME] daughter of Murad Ali

ALL ARE MUSLIMS, ADULT, RESIDING AT R/o: H.No: 243-A, Block-6, [AREA REDACTED], KARACHI………………………………….. PLAINTIFF

VERSUS:

[DEFENDANT NAME]

D/O [DEFENDANT FATHER NAME], Muslim,

Adult, Resident of H.No: C-369,

Block-6, [AREA REDACTED],

Karachi …………………………………………….… DEFENDANT

SUIT FOR DECLARATION, PERMANENT INJUNCTION AND SPECIFIC PERFORMANCE

The legal heirs of the plaintiff abovenamed begs to submit as under:-

That plaintiff agreed to purchase and the defendant agreed to sell/transfer and convey his immovable property viz. Residential Flat No: 12, fourth floor situated in the project named as “[PROJECT NAME REDACTED]” on [PROPERTY ADDRESS REDACTED], measuring 111.30 sq. yds hereinafter referred to as the Said Property for a total sale consideration of Rs.510,000/- (Rupees five lac and ten thousand only)

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 the plaintiff on the date of Agreement of Sale i.e. 21st May 2002 paid a sum of Rs.5, 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.5, 10,000/- is annexed hereto and marked as annexure ‘C’.)

That as per