Ammended Plaint

( AMENDED PLAINT )
IN THE COURT OF SENIOR CIVIL JUDGE, SANGHAR.
F.C.SUIT NO.45 OF 2007.
Muhammad Haneef S/o Lal Khan Brohi by caste,

muslim, adult, r/o Chak No.46 Deh Sadrat, Taluka
and District Sanghar.
………………………….Plaintiff.
Versus.
1. Niaz S/O Haneef Jatt by caste, muslim, adult, R/o

Chak No.50, Taluka and District Sanghar.
2. Mukhtiarkar Land Revenue, Sanghar.
3. Tapedar Deh Sadrat, Taluka Sanghar.
4. S.H.O, Police Station Mangli.
5. Province of Sindh, Through Secretary Land Revenue

Department, Govt. of Sindh, Karachi.
6. Mst. Marvi D/o Qutub Din, muslim, adult, aged

about 14 years, through her guardian -ad-litem
Kamaluddin S/O Jiando Khan, muslim, adult, by
caste Shar, Zamindar, R/o Village Jiando Khan
Shar, Taluka Sanghar.
7. Ghullam Sarwar S/o Rais Haji Kamaluddin, muslim,

adult, by caste Shar, P.O Chak NO.41, Taluka and
District Sanghar.
8. Sub Registrar, Sanghar.
9. Micro Film, Registrar, Hyderabad.
…………………..Defendants.
SUIT FOR CANCELLATION OF SALE DEED,

DECLARATION &PERMANENT INJUCTION.
P/2…
P/2…
The above named plaintiff respectfully submits as under:-
1. That the provisions of S.A.R Act are not applicable to this suit.
2. That an agricultural land bearing temporary Block Nos.59, 60 area 32

acres and 61,62, area 32 acres, total area 64-00 acres of Deh Sadrat taluka and
District Sanghar situated within the territorial jurisdiction of this honourable court,
is the “SUBJECT MATTER” of this suit.
3. That, the suit land is un-assessed land and originally owned by one
Muhammad Shabbir, which was purchased by the plaintiff in the year 1988, in
the sum of Rs.1,30,000/-, thereafter such entry in Record of Rights i.e. in VII-B
was also effected in the name of plaintiff vide Jariyan No.193.
4. That, since purchase of suit land, the plaintiff is in physical and cultivating
possession of the suit land and is residing there, by constructing his house over
the some portion of suit land and is paying land revenue etc. to the Govt.
regularly without any hindrance.
5. That, defendant No.1 is very clever and greedy eyed person and always
kept his greedy eyes upon the land of plaintiff and always tried to dispossess the
plaintiff from suit land without any cogent reason and without due course of law
by using illegal methods.
6. That, about 20 days ago, the defendant No.1, along with defendant No.3
and 4 and sub ordinates of defendant No.4, appeared on suit land and
threatened to plaintiff to handover the possession of land, saying that he
(defendant No.1) is owner of the land and denying the character and title of
plaintiff over the suit land, whereupon plaintiff disclosed that he (plaintiff) is legal
owner of suit land which was purchased by him from one Muhammad Shabbir
and such entry in Record of Rights is also effected in the name of plaintiff, but
defendant No.1 did not hear the plaintiff and went away by issuing threats that he
with the help of defendant No.3 will keep his name in the record of rights and
thereafter will come again and will dispossess the plaintiff from the suit land.
7. That, as soon as, the plaintiff approached to defendant No.2 and after
verification of Khata which was not changed by defendant No.1, requested to
defendant No.2 that, defendant No.1, malafidely denying the legal character and
title over the suit land, showing himself owner of the suit land and with the help of
Tapedar and police (the defendant No.2 and 3) illegally, malafidely wants to
occupy the suit land from the plaintiff. The plaintiff further requested to defendant
No.2 to direct/ restrain the Tapedar of Deh Sadrat not to interfere in peaceful
possession of the plaintiff over suit land, but the defendant No.2, at the influence
of defendant No.1 did not hear the plaintiff and shown his disability.
P/3…
P/3…
8. That, again about 2/3 days back when plaintiff was present on his land,
where defendant No.1 alongwith 8/10 unknown persons armed with deadly
weapons appeared on suit land and malafidely by making fire in the air tried to
dispossess the plaintiff from the suit land by denying the title and legal character
of plaintiff over the suit land, but due to intervention of plaintiff and other local
persons the defendant No.1 could not succeed and went away by issuing threats
that any time they will come again and with the help of defendant No.4 will
dispossess the plaintiff from suit land.
9. That the action of defendant No.1, for dispossessing the plaintiff from suit
land i.e., temporary block Nos.59,60 area 32-00 acres and 61,62 area 32-00
acres total area 64-00 acres of Deh Sadrat, Taluka and District Sanghar, with the
help of defendant No.3 and 4, by denying the character and title of plaintiff over
the suit land showing himself, owner is illegal malafide void, abinitio and is not
binding upon the plaintiff, there is also great apprehension that defendant No.1
with the help of defendant No.3 and 4, any time will take over the possession of
the suit land and in case of dispossessing of plaintiff from suit land, there will be
blood shade, hence this suit.
10. That after filing the suit defendants No.6 and 7 appeared before the
Honourable court and moved application U/O 1 rule 10 CPC, posing them to be
the purchaser of the suit land on the basis of General Power of attorney of
Muhammad Hanief S/O Ranjha Khan. It is submitted that Muhammad Shabbir
the previous owner of the suit land filed Suit bearing F.C.Suit No.83 of 1985
reference Muhammad Shabbir Vs.Nasir Hayat and others, in that suit so called
General Power of attorney namely Mohammad Hanief S/O Ranjha Khan was
also defendant No.7. Ultimately a private settlement (Faisla) in between
Muhammad Hanief S/O Ranjha Khan and others (who are shown to be the seller
of the suit land to defendant No.6 and 7), was taken place in which the suit land
was proved and written in the Faisla to be the property of Muhammad Shabbir.
such Punchaiti Faisla was submitted in that suit before the honourable court and
the suit was disposed off in the year 1987. Thereafter the plaintiff purchased the
suit land from Muhammad Shabbir but defendant No.6 and 7 malafidely, in
collusion with Sub-Registrar, Sanghar, on the basis of forged Photostat copy of
power of attorney managed and fabricated the sale deed produced by defendant
No.6 and 7, which is based on false footing, void, illegal, and is liable to be
cancelled by the Honourable Court.
11. That defendants No.6 and 7 even tried to get their entries effected in the
record of rights in their names secretly and by hiding from the plaintiff in collusion
with defendant No.2 but ultimately the same were cancelled by District Officer
Revenue and thereafter by Defendant NO.2 and 3 being false and were taken
place due to mistake. P/4…
P/4…
12. That action of defendant NO.1 is illegal and so called registered sale deed
at S.No.425, dated: 12.04.2007 in the names of defendants Nos. 6 and 7 is false,
fabricated and is liable to be cancelled.
13. That defendants No. 8 & 9 are necessary parties for the proper
adjudication in the matter.
14. That the cause of action accrued the plaintiff to file the present suit when
about 20 days ago, the defendant No.1, with defendant No.3 and 4 and sub-
ordinates of defendant No.4 appeared on suit land and tried to dispossess the
plaintiff from the suit land by denying the character and title of plaintiff over the
suit land showing himself owner of the suit land again 2/3 days back when
defendant No.1 along with 8/10 unknown persons armed with deadly weapons
appeared on suit land and malafidely by making fire in the air tried to dispossess
the plaintiff from suit but due to intervention of plaintiff and other local persons
the defendant NO.1 could not succeed and when the plaintiff came to know
about the so called registered sale deed dated:12.4.2007 in favour of defendants
No.6 and 7 and when the plaintiff came to know about the entries kept and
cancelled, which continues till today.
15. That, the suit land is situated within the territorial jurisdiction of this
Honourable court, therefore this Honourable court has jurisdiction to entertain the
present suit.
16. That, notice U/S 80 CPC could not be given to official defendants due to
urgency.
17. That the value of the suit for the purpose of court fee and jurisdiction is
fixed at Rs.40,00,400/-, as for relief of cancellation the value is fixed
Rs.40,00,000/- the value of Declaration if fixed at Rs.200/- and for Injunction
Rs.200/- on which maximum court fee of Rs.15,000/- is paid.
18. That the plaintiff prays for judgment and decree as under:-
(a) That defendants Nos.6 and 7 be directed to produce before the

Honourable Court the original sale deed mentioned at S.No.425,
dated: 12.04.2007, in respect of the suit land comprising of block No.
59, 60, 61, 62 total area 64-00 acres of Deh Sadrat, Taluka and District
Sanghar, presented in the office of defendant No.8 and may be
ordered to be cancelled with the direction to defendant No.8, to do so.
(b) That ,this Honourable court may be pleased to declare that the plaintiff
is law full and legal owner of the suit land i.e. temporary block Nos: 59,
60, area 32-00 acres and 61, 62 area 32 -00 acres, total area 64-00
acres of the Deh Sadrat Taluka and District Sanghar, which was
P/5…
P/5…
purchased by the plaintiff in the sum of Rs.1,30,000/- from one

Muhammad Shabbir, this Honourable Court further may be pleased to
declare that act of defendant No.1, denying the title and legal character
of plaintiff over the suit land and claiming himself as owner of suit land
is illegal, malafide, void, abinitio and is not binding upon plaintiff.
(c) That this Honourable Court may be pleased to issue permanent

injunction restraining the defendants for interfering in peaceful
cultivating and physical possession of the suit land i.e. temporary
Block Nos: 59, 60 area 32-00 acres and 61, 62 area, 32 -00 acres total
area 64-00 acres of the Deh Sadrat Taluka and District Sanghar or
creating any through themselves, their agents, associates, servants,
helpers, friends, attorneys in any manner whatsoever.
(d) That, costs of the suit be born by the defendants .
(e) Any other relief, which this Honourable Court deems fit and proper
may be awarded to plaintiff.
Advocate for plaintiff Plaintiff
Sanghar
Dated: 04.05.2007
VERIFICATION.
I, Muhammad Hanief S/O Lal Khan Brohi by caste, muslim, adult, R/o
Chak No 46 Deh Sadrat Taluka and District Sanghar, do hereby verify on oath,
on this 12th day of December 2008 at Sanghar that whatever stated above is true
and correct to the best of knowledge and belief.
DEPONENT.
I know the deponent
Advocate.
P/6…
P/6…
Documents filed
1. Photostat copy Village Form VII- B

2. Photostat copy of Pass Book
3. Photostat copy of Land Revenue Receipts.
4. Photostat copy of plaint of F.C. Suit No 83 of 1985.
5. Photostat copy of Panchaiti Faisla dated 05-05-1987.
6. Photostat copy of Form VII-B, Entry No 3568 dated 12-04-2007.
Documents Relied upon

1. Record of F.C. Suit No. 83 of 1985 .
2. Original of the above.
3. Any other relevant record.
Addresses of parties are same as shown in title clause of suit.
Drafted by me and typed under the instructions of plaintiff at my office.
List of L.Rs of plaintiff
1. Mrs Muhammad Hanif wife adult

2. Liaquat Ali son adult
3. Barkat Ali son adult
In case of death of plaintiff during the pendency of the suit the LRs No. 2
will inform this honorable court.
Advocate for plaintiff.

Muhammad Haneef Brohi

Versus.
Niaz & Others
APPLICATION U/O 39 RULE 1 & 2 CPC
It is humbly prayed on behalf of plaintiff that this
Honourable Court may be pleased to issue ad-interim injunction in
favour of plaintiff and against defendants restraining them for
interfering with in peaceful cultivating and physical possession of the
suit land i.e. temporary Block Nos: 59, 60 area 32-00 acres and 61, 62
area, 32 -00 acres total area 64-00 acres of the Deh Sadrat, Taluka and
District Sanghar, by themselves, through their agents, associates,
servants, helpers, friends, attorneys directly or indirectly in any manner
whatsoever & defendants Nos. 2, 6 & 7 may further be directed not to
create any third party interest in the suit land on the basis of false
registered sale deed mentioned at S.No.425, dated: 12.04.2007 and Sub-
Registrar Sanghar may also be restrained from accepting any document
for registration in respect of the suit land till the disposal of the suit on
the consideration of the grounds mentioned in the accompanying
affidavit.
ADVOATE FOR PLAINTIFF.

Sanghar
Dated:28-01-2009

Versus.
Niaz & Others

……………………..Defendants.
AFFIDAVIT.
I, Muhammad Hanif son of Lal Khan Brohi, adult, muslim,

r/o: Chak No.46 Deh Sadrat, Taluka and District Sanghar, do hereby
state on oath as under:-
1. That I am plaintiff and hence fully conversant with the facts of the
present suit.
2. That I have given the details of my case in memorandum of plaint,

the contents whereof are true and correct and same be read and treated
as part of this affidavit to avoid repetition.
3. That I have good prima facie case and the balance of convenience
is also in my favour and in case the injunction as prayed is not granted I
shall suffer serious loss and injury.
Whatever stated above is true and correct to the best of my

knowledge and belief.
I know the deponent.
Deponent.
Advocate.

Versus.
Niaz & Others

AFFDIAVIT.
I,

Versus.
Niaz & Others

STATEMENT
I, hereby adopt application under order 39 Rule 1 & 2 CPC
already filed before the Honourable Court along with plaint against all the
defendants.
ADVOCATE FOR PLAINTIFF.
Sanghar.
Dated: 15.12.2008

Versus.
Niaz & Others

STATEMENT / UNDER TAKEING.
I, on behalf of the plaintiff do hereby under take to submit court
fees stamps of Rs.10,900/- on or before date of hearing, as the same has been
applied for and Rs.4,100/- were already paid.
ADVOCATE FOR PLAINTIFF.
Sanghar.
Dated: 12.12.2008
AMMENDED PLAINT.

muslim, adult, r/o Chak No.46 Deh Sadrat, Taluka
and District Sanghar.
Versus.
1. Niaz S/O Haneef Jatt by caste, muslim, adult, R/o

Chak No.50, Taluka and District Sanghar.
2. Mukhtiarkar Land Revenue, Sanghar.
5. Province of Sindh, Through Secretary Land Revenue

Department, Govt. of Sindh, Karachi.
6. Mst. Marvi D/o Qutub Din, muslim, adult, aged

about 14 years, through her guardian -ad-litem
Kamaluddin S/O Jiando Khan, muslim, adult, by
caste Shar, Zamindar, R/o Village Jiando Khan
Shar, Taluka Sanghar.
7. Ghullam Sarwar S/o Rais Haji Kamaluddin, muslim,

adult, by caste Shar, P.O Chak NO.41, Taluka and
District Sanghar.
SUIT FOR CANCELLATION OF SALE DEED,

DECLARATION &PERMANENT INJUCTION.
P/2…
P/2…
1. That the provisions of S.A.R Act are not applicable to this suit.
2. That an agricultural land bearing temporary Block Nos.59, 60 area 32

acres and 61,62, area 32 acres, total area 64-00 acres of Deh Sadrat taluka and
District Sanghar situated within the territorial jurisdiction of this honourable court,
is the “SUBJECT MATTER” of this suit.
3. That, the suit land is un-assessed land and originally owned by one
Muhammad Shabbir, which was purchased by the plaintiff in the year 1988, in
the sum of Rs.1,30,000/-, thereafter such entry in Record of Rights i.e. in VII-B
was also effected in the name of plaintiff vide Jariyan No.193.
4. That, since purchase of suit land, the plaintiff is in physical and cultivating
possession of the suit land and is residing there, by constructing his house over
the some portion of suit land and is paying land revenue etc. to the Govt.
5. That, defendant No.1 is very clever and greedy eyed person and always
kept his greedy eyes upon the land of plaintiff and always tried to dispossess the
plaintiff from suit land without any cogent reason and without due course of law
by using illegal methods.
6. That, about 20 days ago, the defendant No.1, alongwith defendant No.3
and 4 and sub ordinates of defendant No.4, appeared on suit land and
threatened to plaintiff to handover the possession of land, saying that he
(defendant No.1) is owner of the land and denying the character and title of
plaintiff over the suit land, whereupon plaintiff disclosed that he (plaintiff) is legal
owner of suit land which was purchased by him from one Muhammad Shabbir
and such entry in Record of Rights is also effected in the name of plaintiff, but
defendant No.1 did not hear the plaintiff and went away by issuing threats that he
with the help of defendant No.3 will keep his name in the record of rights and
thereafter will come again and will dispossess the plaintiff from the suit land.
7. That, as soon as, the plaintiff approached to defendant No.2 and after
verification of Khata which was not changed by defendant No.1, requested to
defendant No.2 that, defendant No.1, malafidely denying the legal character and
title over the suit land, showing himself owner of the suit land and with the help of
Tapedar and police (the defendant No.2 and 3) illegally, malafidely wants to
occupy the suit land from the plaintiff. The plaintiff further requested to defendant
No.2 to direct/ restrain the Tapedar of Deh Sadrat not to interfere in peaceful
possession of the plaintiff over suit land, but the defendant No.2, at the influence
of defendant No.1 did not hear the plaintiff and shown his disability.
P/3…
P/3…
8. That, again about 2/3 days back when plaintiff was present on his land,
weapons appear on suit land and malafidely by making fire in the air tried to
persons the defendant No.1 could not succeed and went away by issuing threats
that any time they will come again and with the help of defendant No.4 will
9. That the action of defendant No.1, for dispossessing the plaintiff from suit
acres total area 64-00 acres of Deh Sadrat, Taluka and District Sanghar, with the
help of defendant No.3 and 4, by denying the character and title of plaintiff over
the suit land showing himself owner of is, illegal malafide void, abinitio and is not
with the help of defendant No.3 and 4, any time will take over the possession of
the suit land and in case of dispossessing of plaintiff from suit land, there will be
10. That after filing the suit defendant No.6 and 7 appeared before the
Honourable court and moved application U/O 1 rule 10 CPC, posing them to be
the purchaser of the suit land on the basis of General Power of attorney of
Muhammad Hanief S/O Ranjha Khan. It is submitted that Muhammad Shabbir
the previous owner of the suit land filed Suit bearing F.C.Suit No.83 of 1985
reference Muhammad Shabbir Vs.Nasir Hayat and others, in that suit so called
General Power of attorney namely Mohammad Hanief S/O Ranjha Khan was
also defendant No.7. Ultimately a private settlement (Faisla) in between
Muhammad Hanief S/O Ranjha Khan and others (who are shown to be the seller
of the suit land to defendant No.6 and 7), was taken place in which the suit land
was proved and written in the Faisla to be the property of Muhammad Shabbir.
such Punchaiti Faisla was submitted in that suit before the honourable court and
the suit was disposed off in the year 1987. Thereafter the plaintiff purchased the
suit land from Muhammad Shabbir but defendant No.6 and 7 malafidely, in
collusion with Sub-Registrar, Sanghar, on the basis of forged Photostat copy of
power of attorney managed and fabricated the sale deed produced by defendant
No.6 and 7, which is based on false footing, void, illegal, and is liable to be
cancelled by the Honourable Court.
place due to mistake.
P/4…
P/4…
12. That action of defendant NO.1 is illegal and so called registered sale deed
at S.No.425, dated: 12.04.2007 in the names of defendants Nos. 6 and 7 is false,
fabricated and is liable to be cancelled.
13. That the cause of action accrued the plaintiff to file the present suit when
about 20 days ago, the defendant No.1, with defendant No.3 and 4 and sub-
ordinates of defendant No.4 appeared on suit land and tried to dispossess the
plaintiff from the suit land by denying the character and title of plaintiff over the
suit land showing himself owner of the suit and again 2/3 days back when
defendant No.1 along with 8/10 unknown persons armed with deadly weapons
appeared on suit land and malafidely by making fire in the air tried to dispossess
the plaintiff from suit but due to intervention of plaintiff and other local persons
the defendant NO.1 could not succeed and when the plaintiff came to know
about the so called registered sale deed dated:12.4.2007 in favour of defendants
No.6 and 7 and when the plaintiff came to know about the entries kept and
cancelled, which continues till today.
14. That, the suit land is situated within the territorial jurisdiction of this
Honourable court, therefore this Honourable court has jurisdiction to entertain the
present suit.
15. That, notice U/S 80 CPC could not be given to official defendants due to
urgency.
fixed at Rs.40,00,400/-, as for relief of cancellation the value is fixed
Rs.40,00,000/- the value of Declaration if fixed at Rs.200/- and for Injunction
Rs.200/- on which maximum court fee of Rs.15,000/- is paid.
(f) That defendants Nos.6 and 7 be directed to produce before the

Honourable Court the original sale deed mentioned at S.No.425,
dated: 12.04.2007, in respect of the suit land comprising of block No.
59, 60, 61, 62 total area 64-00 acres of Sadrat, Taluka and District
Sanghar, presented in the office of Sub-Registrar Sanghar and may be
ordered to be cancelled with direction to sub-registrar Sanghar to do
so.
(g) That ,this Honourable court may be pleased to declare that the plaintiff
is law full and legal owner of the suit land i.e. temporary block Nos: 59,
60, area 32-00 acres and 61, 62 area 32 -00 acres, total area 64-00
acres of the Deh Sadrat Taluka and District Sanghar, which was
P/5…
P/5…
purchased by the plaintiff in the sum of Rs.1,30,000/- from one
Muhammad Shabbir, this Honourable Court further may be pleased to
declare that act of defendant No.1, denying the title and legal character
of plaintiff over the suit land and claiming himself as owner of suit land
is illegal, malafide, void, abinitio and is not binding upon plaintiff.
(h) That this Honourable Court may be pleased to issue permanent

injunction restraining the defendants Nos. 1 to 7 for interfering in
peaceful cultivating and physical possession of the suit land i.e.
temporary Block Nos: 59, 60 area 32-00 acres and 61, 62 area, 32
-00 acres total area 64-00 acres of the Deh Sadrat Taluka and District
Sanghar, through themselves, their agents, associates, servants,
helpers, friends, attorneys in any manner whatsoever.
(i) That, costs of the suit be born by the defendants .
(j) Any other relief, which this Honourable Court deems fit and proper
may be awarded to plaintiff.
Sanghar
Dated: 04.05.2007
VERIFICATION.
I, Muhammad Hanief S/O Lal Khan Brohi by caste, muslim, adult, R/o
Chak No 46 Deh Sadrat Taluka and District Sanghar, do hereby verify on oath,
on this 12th day of December 2008 at Sanghar that whatever stated above is true
and correct to the best of knowledge and belief.
DEPONENT.
I know the deponent
Advocate.
P/6…
P/6…
Documents filed
1. Photostat copy Village Form VII- B

2. Photostat copy of Pass Book
3. Photostat copy of Land Revenue Receipts.
6. Photostat copy of Form VII-B, Entry No 3568 dated 12-04-2007.

1. Record of F.C. Suit No. 83 of 1985 .
3. Any other relevant record.
Addresses of parties are same as shown in title clause of suit.

In case of death of plaintiff during the pendency of the suit the LRs No. 2

Muhammad Haneef ……………….. Plaintiff.
Versus.
Niaz & Others ………………………..Defendants.
OBJECTIONS TO APPLICATION
U/O7 RULE 11CPC
1. That the suit is maintainable at law and discloses cause of action.
2. That the application is pre matured as application U/o 6 rule 17 CPC filed
on behalf of the plaintiff is pending adjudication before the honourable court
therefore the question of cause of action against defendant No.6 and 7 does not
arise and is not amenable at this stage.
3. That the suit is not barred by any law and defendant No.6 and 7 have
unnecessarily filed this application only to create complications with malafide
intention so that matter is lingered on.
4. That defendants No.6 and 7 shall not suffer any loss of injury if the
application is not allowed.
5. That application U/O 7 rule 11 CPC is not maintainable at this stage,

hence the same is liable to be dismissed.

Versus.
REPLICATION / REJOINDER TO
OBJECTION TO APPLICATION U/O 39
RULE 1 & 2 CPC.
I, Muhammad Hanief S/o Lal Khan Brohi by caste, Muslim, Adult, R/o
Chak No. 46, Deh Sadrat Taluka and District Sanghar, do here state on oath as
under:-
1. That I am plaintiff and hence fully conversant with the facts of the present
case.
2. That neither defendant Nos. 6 & 7 are owners of the suit land nor they are
in physical possession of the same, on the contrary I am legal owner as well as
in cultivating possession of the suit land for which I have submitted Dhall receipts
as well as record of rights.
3. That I have good prima-facie case for grant of injunction in my favour as

well as balance of convenience lies in my favour. I shall suffer serious loss and
injury if the application is not granted in my favour.
4. That it shall be in the interest of justice that in my application U/O 39 rule 1

and 2 CPC is granted.
Whatever stated above is true and correct to the best of my knowledge

and belief.
I know the deponent
Deponent
Advocate
Muhammad Haneef …..……………….. Plaintiff.
Versus.
APPLICATION U/O 6 RULE 17 CPC
It is prayed on behalf of the plaintiff that this Honourable court may be
pleased to allow the plaintiff to amend the plaint on the consideration of grounds
mentioned in accompanying affidavit.
PROPOSED AMENDMENTS.
1. In title of the suit the word “cancellation of sale deed” be inserted before
declaration and injunction.
2. In Para No. 3 of the plaint the word ”Muhammad Bashir“ the word
“Muhammad Shabbir” be substituted.
3. In Para No 6 of the plaint in line No 7 the word ”Muhammad Bashir“ the

word “Muhammad Shabbir” be substituted.
4. After Para No. 9 following new paras be inserted:-

10. “ That after filing the suit defendants No 6 and 7 appeared before the
honorable court and moved the application U/O 1 Rule 10 CPC, posing them to
be the purchaser of the suit land on the basis of general power of attorney of
Muhammad Haneef s/o Ranjha Khan. It is submitted that Muhammad Shabbir
the previous owner of the suit land filed suit bearing F.C. Suit No 83 of 1985, Ref:
Muhammad Shabbir versus Nasir Hayat and others, in that suit so called general
power of attorney namely Muhammad Haneef s/o Ranjha Khan was also
-:(Page-2):-
defendant No 7. Ultimately a private settlement (faisla) in between Muhammad

Haneef s/o Ranjha Khan and others (who are shown to be the seller of the suit
land to defendant No 6 and 7) was taken place, in which the suit land was proved
and written in the faisla to be the property of Muhammad Shabbir. Such
Punchayati faisla was submitted in that suit before the honuorable court and the
suit was disposed off in the year 1987. Thereafter the plaintiff purchased the suit
land form Muhammad Shabbir but defendants No 6 and 7 malafidely, in collusion
with Sub- Registrar Sanghar, on the basis of forged Photostat copy of power of
attorney managed and fabricated the sale deed produced by defendants No 6
and 7, which is based on false footing, void, illegal and liable to be cancelled by
the honourable court.”
11. “That defendants No 6 and 7 even tried to get their entries effected in the
with defendant No. 2 but ultimately the same were cancelled by District Officer
Revenue and thereafter by defendants No. 2 and 3 being false and were taken
place due to mistake.”
12. “That action of defendant No 1 is illegal and so called registered sale deed
at Serial No 425 dated 12-04-2007 in the names of defendants No. 6 and 7 is
false, fabricated and is liable to be cancelled.
5. In Para No 10 which shall now be numbered as Para No 13 the following

words in its last line before “which continue till today” may be instituted;
“and when the plaintiff came to know about the so called registered sale deed
dated 12-04-2007 in favour of defendants No. 6 and 7 and when the plaintiff
came to know about the entries kept and cancelled.”
6. That No. of Paras 11 and 12 may be substituted as 14 and 15.
7. Para No 13 now be numbered as16 may be substituted as under:-

16. “ That the value of the suit for the purpose of court fee and jurisdiction is
fixed at Rs 40,00,400/- as for relief of cancellation the value is fixed at Rs
40,00,000/-, the value for declaration is fixed at Rs 200/- and for injunction Rs
200/-, on which maximum court fee of Rs 15,000/- is paid.”
8. That Para No 14 may be substituted as Para No. 17 and following may be

substituted
(a) “that defendants No 6 and 7 be directed to produce before the honourabe
court the original sale deed mentioned at serial No. 425 dated 12-04-2007 in
respect of the suit land comprising of block No 59, 60, 61, 62 total area 64-00
acres of Deh Sadrat Taluka and District Sanghar, presented in the office of Sub-
-:(Page-3):-
Registrar Sanghar and may be ordered to be cancelled with direction to Sub-

Registrar Sghar to do so.” AND
(a) may be substituted as (b) and in line No 7 word “Muhammad Bashir may be
substituted as “Muahmmad Shabbir” AND
(b) may be substituted as (c) and in line No. 3 after defendants No “ 1 to 7” may
be replaced for 1,3 and 4. AND
(c) and (d) may be replaced as (d) and (e) respectively.
9. In the portion of documents filed, after No.3 following documents may be

inserted to be filed;
4. Photostat copy of plaint of F.C Suit No.83 of 1985
5. Photostat copy of Panchayati Faisila dated 05-05-1987
6. Photostat copy of Form VII-B entry No.3568 dated 12-04-2007.
10. In the portion of documents relied uon, at serial No.1

1. Record of F.C.Suit No.83 of 1985 AND No.1 and 2 be replaced as No.2
and 3 respectively.
Advocate for plaintiff

Versus.
AFFIDAVIT
under:-
suit.
2. That accompanying application U/O 6 Rule 17 has been drafted under my

instruction and I say that the same is true and correct.
3. That the amendments sought for are necessary for the purpose of
determining the real question in controversy between the parties.
4. That the amendments will not change the status or nature of the suit.
5. That I could not clarify to my advocate at the time of filing the suit about
some facts sought for to be amended and now I have come to know about the
same and due to such reason the amendments sought could not be incorporated
in the plaint.
6. That if the application as sought for is not allowed/granted I shall suffer

serious loss and injury.
-:(2):-
7. That justice requires that amendments sought for may kindly be allowed/
granted.

and belief.
I know the deponent
Deponent
Advocate
Muhammad Haneef …..……………….. Plaintiff.
Versus.
APPLICATION U/O 18 RULE 18, R/W ORDER

26 RULE 9 AND SECTION 151 CPC
It is requested that on consideration of grounds submitted in the affidavit

hereto, the honourable court may be pleased to inspect suit land viz. bearing
block No 59, 60, 61 and 62 area 64-00 acres, Deh Sadrat, Taluka and District
Sanghar, or issue a commission to such person as honourable court deems fit, to
make local investigation for the purpose of elucidating the actual position of
possession and control over it and report there about to the honourable court.
This prayer is made in the interest of justice.
Advocate for Plaintiff

Versus.
AFFIDAVIT
under:-
application.
2. That accompanying application U/O 18 Rule 18 R/W Order 26 Rule 9 and

Section 151 CPC is filed under my instructions.
3. That the above matter involves question of occupation/possession and

control over the suit land and both parties claim control / possession, therefore, it
has become necessary to resolve the said controversy through inspection by the
honorable court or issue of commission as prayed in the accompanying
application.
4. That by grant of prayer made in the accompanying application, no

prejudice will be cause to any of the party but real position will come to light and
matter will be decided with all fairness.
5. That I will suffer irreparably and deprived of my rights if the prayer made in
the accompanying application is not granted.
and belief.
I know the deponent
Deponent
Advocate

Versus.
AFFIDAVIT
under:-
application.
2. That accompanying application U/O 18 Rule 18 R/W Order 26 Rule 9 and

Section 151 CPC is filed under my instructions.
3. That the above matter involves question of occupation/possession and

control over the suit land and both parties claim control / possession, therefore, it
has become necessary to resolve the said controversy through inspection by the
honorable court or issue of commission as prayed in the accompanying
application.
4. That by grant of prayer made in the accompanying application, no

prejudice will be cause to any of the party but real position will come to light and
matter will be decided with all fairness.
5. That I will suffer irreparably and deprived of my rights if the prayer made in
the accompanying application is not granted.
and belief.
I know the deponent
Deponent
Advocate

Versus.
OBJECTIONS TO APPLICATION U/O

39 RULE 1 & 2, R/W S. 151 CPC FILED
BY DEFENDANTS NO 6 AND 7 IN
SHAPE OF COUNTER AFFIDAVIT.
under:-
case.
2. That neither defendant Nos. 6 & 7 are owners of the suit land nor they are
in physical possession of the same, on the contrary I am owner as well as in
cultivating possession of the suit land for which I have submitted Dhall receipts
as well as record of rights. Defendants No 6 and 7 in collusion with Sub Registrar
Sanghar manipulated false and bogus registered sale deed on the basis of
forged photostat copy of power of attorney which is liable to be cancelled, as
defendants No 6 and 7 tried to get their entries effected in the record of rights but
the same were cancelled by Revenue authorities that the same were taken place
due to mistake.
3. That the application filed by defendants No 6 and 7 is not maintainable as
the suit has been filed by me and my application in this regard is pending
adjudication before the honourable court.
4. That Muhammad Shabbir purchased the suit land from Muhammad Hayat
Block No.23, 24,45 and 46 measuring 80-00 acres in deh 50 Samatri and block
NO.59,60,61 and 62 measuring 64-00 acres in chak NO.46 deh sadrat taluka
Page-2
and District Sanghar. Thereafter a dispute arose in between said Muhammad

Shabbir and legal heirs of Muhammad Hayat so also father of defendant No.1
namely Niaz Hussain and and Muhammad Shabbir filed F.C.Suit No.83 of 1985
before this honourable court and it was clearly mentioned in the plaint that the
subject matter of this suit was not in dispute, as the same was the property of
Muhammad Shabbir sold by owner Muhammad Hayat. Ultimately the
compromise in between the parties was also taken place and there is no
mentioned of the subject matter of this suit to be in dispute. This compromise
was taken place on the basis of Panchaiti Faisla. Thereafter the suit land was
sold by said Muhammad Shabbir to the plaintiff in the year 1988.
5. That the suit land was entered into the name of the plaintiff in the record of
rights since then he is enjoying its peaceful cultivating possession.
6. That defendants No.6 and 7 in connivance with other defendants

manipulated the registered sale deed and tried to effect the entries in thieve
names and got Fouti Khata Badal of the land by fraud and misrepresentation for
the land which was already sold out to Muhammad Shabbir and then to the
plaintiff but the said Khatas were cancelled by D.D.O, Mukhtiarkar, Sanghar.
Phot copies of plaint of F.C.Suit No.83 of 1985, application U/O 23 rule 1 CPC,
Punchaiti Faisla, record of rights infavour of plaintiff, Fouti Khata Badal and
cancellation order are submitted herewith.
7. That neither the balance of convenience lies in favour of defendants No 6

and 7 nor they have good prima-facie case but on the contrary I have good
prima-facie case for grant of injunction in my favour as well as balance of
convenience lies in my favour. I shall suffer serious loss and injury if the
application is granted in favour of defendants No 6 and 7.

and belief.
I know the deponent

Deponent
Advocate
1. That the provisions of D.A.R Act are not applicable to this suit.
2. That ,an agricultural land bearing temporary Block Nos.59, 60 area 32

acres and 61,62, area 32 acres, total area 64-00 acres situated in Deh Sadrat
taluka and District Sanghar within the territorial jurisdiction of this honourable
court shall herein after be referred to as suit land.
3. That the suit land is un-assessed land and originally owned by one
Muhammad Shabbir, which was purchased by the plaintiff in the year 1988 in the
sum of Rs.1,30,000/-, thereafter such entry in record of rights i.e in deh From VII-
B was also effected in the name of the plaintiff vide Jariyan No. 193.
4. That since purchase of suit land, the plaintiff is in physical and cultivating
possession of the suit land and is residing there by constructing of his house over
the some portion of the suit land and is paying land revenue etc. to the Govt.
5. That defendant No.1 is very clever and greedy eyed person and always
kept his greedy eyes upon the land of the plaintiff and always tried to dispossess
the plaintiff from the suit land without any cogent reason and without due course
of law by using illegal methods.
6. That about 20 days ago the defendant No.1 alongwith defendant No.3 and
4 and sub ordinates of defendant No.4, appeared on suit land and threatened to
plaintiff to handover the possession of suit land, saying that he ( defendant No.1)
is owner of the land and denying the character and title of the plaintiff over the
suit land, whereupon plaintiff disclosed that he (plaintiff) is legal owner of suit
land which was purchased by him from Muhammad Shabbir and such entry in
record of rights is also effected in the name of plaintiff, but defendant No.1 did
not hear the plaintiff and went away by issuing threats that he with the help of
defendant No.3 will keep his name in the record of rights and thereafter will come
again and will dispossess the plaintiff from the suit land.
7. That as soon as, the plaintiff approached to defendant No.2 and after
verification of Khata which was not changed by defendant No.1 requested to
defendant No.2, that defendant No.1 malafidely denying the legal character and
title over the suit land showing himself owner of the suit land and with the help of
tapedar and police (defendant No.2 and 3) illegally, malafidely want to occupy
the suit land from the plaintiff. The plaintiff further requested to defendant No.2
direct/ restrain the tapedar of deh sadrat not to interfere in peaceful possession
of the plaintiff over the suit land, but the defendant No.2, at the influence of
defendant No.1 did not hear the plaintiff and shown his disability.
Page 3
8. That again about 2/3 days back when plaintiff was present on his land,
persons defendant No.1 could not succeed and went away by issuing threats that
any time they will come again and with the help of defendant No.4 will
9. The action of defendant No.1, for dispossessing the plaintiff from the suit
acres total area 64-00acres of deh Sadrat, taluka and District Sanghar with the
help of defendant No.3 and 4 by denying the character and title of plaintiff over
the suit land showing himself owner is illegal, malafide, void, abinitio, and is not
with the help of defendant No.3 and 4 at any time will take over the possession of
suit land and in case of dispossessing the plaintiff from suit land, there will be
honourable court and moved application U/O 1 rule 10 CPC, posing them to be
the purchaser of suit land on the basis of General Power of attorney of
Muhammad Hanief S/o Ranjha Khan. It is submitted that Muhammad Shabbir the
original owner of the suit land filed Suit bearing F.C.Suit No.83 of 1985 reference
Muhammad Shabbir Vs.Nasir Hayat and others, in that suit so called General
Power of attorney namely Mohammad Hanief S/o Ranjha Khan was also
defendant No.7. Ultimately a private faisla in between Muhammad Hanief S/o
Ranjha Khan and others who are shown to be the seller of the suit land to
defendant No.6 and 7 was taken place in which the suit land was proved and
written in the Faisla to be the property of Muhammad Shabbir. Such Punchaiti
Faisla was submitted in that suit before the honourable court and the suit was
disposed off in the year 1987. Thereafter the plaintiff purchased the suit land
from Muhammad Shabbir but defendant No.6 and 7 malafidely, in collusion with
Sub-Registrar, Sanghar, on the basis of forged photo copy of power of attorney
managed and fabricated the sale deed produced by defendant No.6 and 7 which
is based on false footing, void, illegal, and is liable to be cancelled by the
honourable Court.
Page-4
12. That action of defendant NO.1 is illegal and the so called registered sale
deed submitted by defendants No.6 and 7 is false and fabricated that is liable to
be cancelled.
13. That the cause of action accrued to the plaintiff to file the present suit
when the defendant No.1 along with defendant No.3 and 4 and sub-ordinates of
defendant No.4 appeared on suit land and tired to dispossess the plaintiff from
the suit land by denying the character and title of the plaintiff over the suit land
showing himself owner of the suit land and when defendant No.1 along with 8/10
unknown persons armed with deadly weapons appeared on suit land and
malafidely by making fire in the air tried to dispossess the plaintiff from the suit
land but due to intervention of plaintiff and other local persons the defendant
NO.1 could not succeed and when the plaintiff came to know about the so called
registered sale deed dated:-12.4.2007 in favour of defendant NO.6 and 7 and
when the plaintiff came to know about the entries kept and cancelled in the name
of defendants NO.6 & 7 which continues till today within the jurisdiction of this
honourable Court.
14. That the suit land is situated within the territorial jurisdiction of this
honourable court, therefore this honourable court has jurisdiction to entertain the
present suit.
15. That notice U/S 80 CPC could not be given to official defendants due to
urgency.
fixed at Rs. 1,30,000/-, for declaration and injunction, where on court fee
amounting to Rs. 4,100/- has been paid, valuation for the relief of cancellation is
fixed at Rs 200/- being consequential relief where on no court fee stamp is
payable.
(a) That this honourable court may be pleased to declare that the plaintiff
is law full and legal owner of the suit land i.e temporary block Nos 59, 60
area 32-00 acres and 61, 62 area 32 -00 acres total area 64-00 acres of
the Deh Sadrat Taluka and District Sanghar which was purchased by the
plaintiff in the sum of Rs. 1,30,000/- from its previous owner Muhammad
Shabbir in the year 1988.
Page-5
(k) That defendants Nos 6 and 7 be directed to produce before the
honourable the original sale deed in respect of the suit land comprising
of block Nos 59, 60 area 32-00 acres and 61, 62 area 32 -00 acres
total area 64-00 acres of the Deh Sadrat Taluka and District Sanghar,
presented in the office of Sub Registrar Sanghar dated 12-04-2007,
jariyan No 425 and be ordered to be cancelled with direction to Sub
Registrar Sanghar to do so.
(l) That injunction be issued, where by the defendants be restrained for

interfering in peace full cultivating and physical possession of suit land
or alienating or try to alienate the suit land or any part thereof by any
means of alienation to any other person directly or indirectly i.e.
temporary block Nos 59,60, area 32-00 acres and 61,62 area 32-00
acres total area 64-00 acres of Deh Sadrat Taluka and District
helpers, friends, attorneys in any manner what so ever.
(m) Any other relief as the honourable court deems fit.
(n) Costs of the suit be borne by defendants No 1, 6 and 7.
VERIFICATION.
Chak No 46 Deh Sadrat Taluka and District Sanghar, do here by verify on this 5 th
day of December 2007 at Sanghar that what ever stated above is true and
correct to the best of knowledge and belief.
Sanghar
Dated:5.12.2007. DEPONENT.
I know the deponent
Advocate.
Documents filed
1. Photostat copy village form VII- B
2. Photostat copy of pass book
3. Photostat copy of land revenue receipts in 3 Nos.
Page-6

6. Photostat copy of form VII-B entry No 3568 dated 12-04-2007.
2. Record of F,C Suit No 83 of 1985.
3. Any other relevant record or evidence.
Addresses of parties are same as shown in title clause of the suit.

In case of death of plaintiff during the pendency of the suit the LRs No 2

AMMENDED PLAINT.
As per direction of the Hon’ble Court.

Muslim, adult, r/o Chak No.46 Deh Sadrat,
Taluka and District Sanghar. ………………………….Plaintiff.
Versus.
1. Niaz S/o Haneef Jatt by caste, Muslim,

adult, R/o Chak No.50, Taluka and District
Sanghar.
2. Mukhtiarkar Land Revenu, Sanghar.
5. Province of Sindh, Through Secretary

Land Revenue Department, Govt. of Sindh,
Karachi.
6. Mst. Marvi D/o Qutub Din, muslim,adult,

aged about 14 years, through her guardian
-ad-litem Kamaluddin S/o Jiando Khan,muslim,
adult, by caste Shar, Zamindar, R/o Village
Jiando Khan Shar, Taluka Sanghar.
7. Ghullam Sarwar S/o Rais Haji Kamaluddin,

muslim,adult, by caste Shar, P.O Chak NO.41,
Taluka and District Sanghar. …………………..Defendants.
SUIT FOR CANCELLATION OF SALE

DEED, DECLARATION & PERMANENT
INJUCTION.
1. That the provisions of D.A.R Act are not applicable to this suit.
Page-2
2. That ,an agricultural land bearing temporary Block Nos.59, 60 area 32

acres and 61,62, area 32 acres, total area 64-00 acres situated in Deh Sadrat
taluka and District Sanghar within the territorial jurisdiction of this honourable
court shall herein after be referred to as suit land.
3. That the suit land is un-assessed land and originally owned by one
Muhammad Shabbir, which was purchased by the plaintiff in the year 1988 in the
sum of Rs.1,30,000/-, thereafter such entry in record of rights i.e in deh From VII-
B was also effected in the name of the plaintiff vide Jariyan No. 193.
4. That since purchase of suit land, the plaintiff is in physical and cultivating
possession of the suit land and is residing there by constructing of his house over
the some portion of the suit land and is paying land revenue etc. to the Govt.
5. That defendant No.1 is very clever and greedy eyed person and always
kept his greedy eyes upon the land of the plaintiff and always tried to dispossess
the plaintiff from the suit land without any cogent reason and without due course
of law by using illegal methods.
6. That about 20 days ago the defendant No.1 alongwith defendant No.3 and
4 and sub ordinates of defendant No.4, appeared on suit land and threatened to
plaintiff to handover the possession of suit land, saying that he ( defendant No.1)
is owner of the land and denying the character and title of the plaintiff over the
suit land, whereupon plaintiff disclosed that he (plaintiff) is legal owner of suit
land which was purchased by him from Muhammad Shabbir and such entry in
record of rights is also effected in the name of plaintiff, but defendant No.1 did
not hear the plaintiff and went away by issuing threats that he with the help of
defendant No.3 will keep his name in the record of rights and thereafter will come
again and will dispossess the plaintiff from the suit land.
7. That as soon as, the plaintiff approached to defendant No.2 and after
verification of Khata which was not changed by defendant No.1 requested to
defendant No.2, that defendant No.1 malafidely denying the legal character and
title over the suit land showing himself owner of the suit land and with the help of
tapedar and police (defendant No.2 and 3) illegally, malafidely want to occupy
the suit land from the plaintiff. The plaintiff further requested to defendant No.2
direct/ restrain the tapedar of deh sadrat not to interfere in peaceful possession
of the plaintiff over the suit land, but the defendant No.2, at the influence of
defendant No.1 did not hear the plaintiff and shown his disability.
Page 3
8. That again about 2/3 days back when plaintiff was present on his land,
persons defendant No.1 could not succeed and went away by issuing threats that
any time they will come again and with the help of defendant No.4 will
9. The action of defendant No.1, for dispossessing the plaintiff from the suit
acres total area 64-00acres of deh Sadrat, taluka and District Sanghar with the
help of defendant No.3 and 4 by denying the character and title of plaintiff over
the suit land showing himself owner is illegal, malafide, void, abinitio, and is not
with the help of defendant No.3 and 4 at any time will take over the possession of
suit land and in case of dispossessing the plaintiff from suit land, there will be
honourable court and moved application U/O 1 rule 10 CPC, posing them to be
the purchaser of suit land on the basis of General Power of attorney of
Muhammad Hanief S/o Ranjha Khan. It is submitted that Muhammad Shabbir the
original owner of the suit land filed Suit bearing F.C.Suit No.83 of 1985 reference
Muhammad Shabbir Vs.Nasir Hayat and others, in that suit so called General
Power of attorney namely Mohammad Hanief S/o Ranjha Khan was also
defendant No.7. Ultimately a private faisla in between Muhammad Hanief S/o
Ranjha Khan and others who are shown to be the seller of the suit land to
defendant No.6 and 7 was taken place in which the suit land was proved and
written in the Faisla to be the property of Muhammad Shabbir. Such Punchaiti
Faisla was submitted in that suit before the honourable court and the suit was
disposed off in the year 1987. Thereafter the plaintiff purchased the suit land
from Muhammad Shabbir but defendant No.6 and 7 malafidely, in collusion with
Sub-Registrar, Sanghar, on the basis of forged photo copy of power of attorney
managed and fabricated the sale deed produced by defendant No.6 and 7 which
is based on false footing, void, illegal, and is liable to be cancelled by the
honourable Court.
Page-4
12. That action of defendant NO.1 is illegal and the so called registered sale
deed submitted by defendants No.6 and 7 is false and fabricated that is liable to
be cancelled.
13. That the cause of action accrued to the plaintiff to file the present suit
when the defendant No.1 along with defendant No.3 and 4 and sub-ordinates of
defendant No.4 appeared on suit land and tired to dispossess the plaintiff from
the suit land by denying the character and title of the plaintiff over the suit land
showing himself owner of the suit land and when defendant No.1 along with 8/10
unknown persons armed with deadly weapons appeared on suit land and
malafidely by making fire in the air tried to dispossess the plaintiff from the suit
land but due to intervention of plaintiff and other local persons the defendant
NO.1 could not succeed and when the plaintiff came to know about the so called
registered sale deed dated:-12.4.2007 in favour of defendant NO.6 and 7 and
when the plaintiff came to know about the entries kept and cancelled in the name
of defendants NO.6 & 7 which continues till today within the jurisdiction of this
honourable Court.
14. That the suit land is situated within the territorial jurisdiction of this
honourable court, therefore this honourable court has jurisdiction to entertain the
present suit.
15. That notice U/S 80 CPC could not be given to official defendants due to
urgency.
fixed at Rs. 1,30,000/-, for declaration and injunction, where on court fee
amounting to Rs. 4,100/- has been paid, valuation for the relief of cancellation is
fixed at Rs 200/- being consequential relief where on no court fee stamp is
payable.
(a) That this honourable court may be pleased to declare that the plaintiff
is law full and legal owner of the suit land i.e temporary block Nos 59, 60
area 32-00 acres and 61, 62 area 32 -00 acres total area 64-00 acres of
the Deh Sadrat Taluka and District Sanghar which was purchased by the
plaintiff in the sum of Rs. 1,30,000/- from its previous owner Muhammad
Shabbir in the year 1988.
Page-5
(o) That defendants Nos 6 and 7 be directed to produce before the
honourable the original sale deed in respect of the suit land comprising
of block Nos 59, 60 area 32-00 acres and 61, 62 area 32 -00 acres
total area 64-00 acres of the Deh Sadrat Taluka and District Sanghar,
presented in the office of Sub Registrar Sanghar dated 12-04-2007,
jariyan No 425 and be ordered to be cancelled with direction to Sub
Registrar Sanghar to do so.
(p) That injunction be issued, where by the defendants be restrained for

interfering in peace full cultivating and physical possession of suit land
or alienating or try to alienate the suit land or any part thereof by any
means of alienation to any other person directly or indirectly i.e.
temporary block Nos 59,60, area 32-00 acres and 61,62 area 32-00
acres total area 64-00 acres of Deh Sadrat Taluka and District
helpers, friends, attorneys in any manner what so ever.
(q) Any other relief as the honourable court deems fit.
(r) Costs of the suit be borne by defendants No 1, 6 and 7.
VERIFICATION.
Chak No 46 Deh Sadrat Taluka and District Sanghar, do here by verify on this 5 th
day of December 2007 at Sanghar that what ever stated above is true and
correct to the best of knowledge and belief.
Sanghar
Dated:5.12.2007. DEPONENT.
I know the deponent
Advocate.
Documents filed
1. Photostat copy village form VII- B
2. Photostat copy of pass book
3. Photostat copy of land revenue receipts in 3 Nos.
Page-6

6. Photostat copy of form VII-B entry No 3568 dated 12-04-2007.
2. Record of F,C Suit No 83 of 1985.
3. Any other relevant record or evidence.
Addresses of parties are same as shown in title clause of the suit.

In case of death of plaintiff during the pendency of the suit the LRs No 2

Muhammad Haneef ………………………….Plaintiff.
Versus.
Niaz and others, …………………………. Defendants
APPLICATION U/O 39 RULE 1 & 2 CPC.
It is prayed that this honourable court may be pleased to issue ad-interim

injunction restraining the defendants for interfering in peace full cultivating and
physical possession of the suit land or alienating or try to alienate the suit land or
any part thereof by any means of alienation to any other person directly or
indirectly i.e. temporary block Nos 59,60, area 32-00 acres and 61,62 area 32-
00 acres total area 64-00 acres of Deh Sadrat Taluka and District Sanghar,
through themselves, their agents, associates, servants, helpers, friends,
attorneys in any manner what so ever, on the consideration on grounds
mentioned in accompanying affidavit.
Sanghar
Dated;5. 12.2007. Advocate for plaintiff
Muhammad Haneef ………………………….Plaintiff.
Versus.
Niaz and others, …………………………. Defendants
A F F I D A V I T.
I, Muhammad Hanif S/o Lal Khan Brohi by caste, Muslim, Adult, R/o Chak
No 46 Deh Sadrat Taluka and District Sanghar, do here by stat on oath as
under:-
1. That I am plaintiff in the above suit and am well aware with the facts of the
case.
2. That application U/O 39 Rule 1 & 2 CPC is filed by my advocate under my

instructions, its contents are true and correct.
3. That I have brought prima- facie and arguable case.
4. That balance of convenience is in my favour.
5. That if the injunction application not allowed as prayed, the very purpose
for filing this suit will be frustrated.
What stated above is true and correct to the best of my knowledge and
belief.
Sanghar
Dated;-5.12.2007 Deponent
I know the deponent.
Advocate.

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( AMENDED PLAINT )

IN THE COURT OF SENIOR CIVIL JUDGE, SANGHAR.

F.C.SUIT NO.45 OF 2007.

Muhammad Haneef S/o Lal Khan Brohi by caste,

1. Niaz S/O Haneef Jatt by caste, muslim, adult, R/o

2. Mukhtiarkar Land Revenue, Sanghar.

3. Tapedar Deh Sadrat, Taluka Sanghar.

4. S.H.O, Police Station Mangli.

5. Province of Sindh, Through Secretary Land Revenue

6. Mst. Marvi D/o Qutub Din, muslim, adult, aged

7. Ghullam Sarwar S/o Rais Haji Kamaluddin, muslim,

SUIT FOR CANCELLATION OF SALE DEED,

2. That an agricultural land bearing temporary Block Nos.59, 60 area 32

(a) That defendants Nos.6 and 7 be directed to produce before the

purchased by the plaintiff in the sum of Rs.1,30,000/- from one

(c) That this Honourable Court may be pleased to issue permanent

(d) That, costs of the suit be born by the defendants .

Advocate for plaintiff Plaintiff

1. Photostat copy Village Form VII- B

Documents Relied upon

Addresses of parties are same as shown in title clause of suit.

Drafted by me and typed under the instructions of plaintiff at my office.

List of L.Rs of plaintiff

1. Mrs Muhammad Hanif wife adult

Advocate for plaintiff.

IN THE COURT OF SENIOR CIVIL JUDGE, SANGHAR.

Muhammad Haneef Brohi

APPLICATION U/O 39 RULE 1 & 2 CPC

It is humbly prayed on behalf of plaintiff that this

Honourable Court may be pleased to issue ad-interim injunction in

favour of plaintiff and against defendants restraining them for

interfering with in peaceful cultivating and physical possession of the

District Sanghar, by themselves, through their agents, associates,

servants, helpers, friends, attorneys directly or indirectly in any manner

whatsoever & defendants Nos. 2, 6 & 7 may further be directed not to

registered sale deed mentioned at S.No.425, dated: 12.04.2007 and Sub-

Registrar Sanghar may also be restrained from accepting any document

the consideration of the grounds mentioned in the accompanying

ADVOATE FOR PLAINTIFF.

F.C.SUIT NO.45 OF 2007.

Muhammad Haneef Brohi

Niaz & Others

I, Muhammad Hanif son of Lal Khan Brohi, adult, muslim,

2. That I have given the details of my case in memorandum of plaint,

Whatever stated above is true and correct to the best of my

I know the deponent.

F.C.SUIT NO.45 OF 2007.

Muhammad Haneef Brohi

Niaz & Others

F.C.SUIT NO.45 OF 2007.

Muhammad Haneef Brohi

Niaz & Others

I, hereby adopt application under order 39 Rule 1 & 2 CPC

ADVOCATE FOR PLAINTIFF.

F.C.SUIT NO.45 OF 2007.

Muhammad Haneef Brohi

Niaz & Others

STATEMENT / UNDER TAKEING.

I, on behalf of the plaintiff do hereby under take to submit court