10/6/2019 2018

REJECTION OF PLAINT IN LIGHT OF PRECEDENTS OF SUPERIOR COURTS OF PAKISTAN

[1] [2]
MUHAMMAD AJMAL AND DR. DIL MUHAMMAD MALIK
Abstract
This article illustrates rejection of plaint under Order VII Rule 11 of Code of Civil Procedure 1908 as applied
and interpreted by the Superior Courts of Pakistan. The terms ‘cause of action’, ‘accrual of cause of action’ and
‘remedy’ have been elaborated and distinguished. The various general principles e.g. preference of correctness
of plaint, irrelevancy of consideration of defense, stage of rejection of plaint, material for rejection of plaint etc
along with their exceptions determined by the Superior Courts of Pakistan qua subject matter under
consideration have been classified and consolidated. Furthermore, the valuation of the suits for the purpose of
court fee and jurisdiction, the duty of the Court and ministerial staff qua valuation and discretion of the Court to
enlarge fixed time coupled with ancillary different aspects have also been discussed. The most important and
invoked ground for rejection of plaint- ‘barred by law’ has been elaborated with illustrations focusing on
connotation of law and distinguishing between rejection of plaint and dismissal of suit. Thereafter, the
consequences of rejection of plaint and remedies there against have also been brought under consideration. The
extremity of this article concludes the whole discussion.
1. Introduction.
[3] [4]
‘Justice delayed is justice denied’ and ‘justice hurried is justice buried’ are the principles of immense significance
in administration of justice in Pakistan. These canons are, primae facie, contradictory but harmonious interpretation of this pair of
canons ensures imparting justice on merits. The tool of Order VII Rule 11 of Code of Civil Procedure 1908 is applied to bury futile
and fruitless suits at the inception in Pakistan. Simultaneously, this device affords every opportunity to adjudicate upon
[5]
controversies on merits and to save the contesting parties from agony of frivolous and protracted litigation. However, this tool
is, sometimes, either applied unnecessarily or is not applied when necessary and results in multiplicity of litigation and wastage of
precious time of the court. In this context, the various aspects and questions relevant with captioned topic are elaborated in light of
statutory and precedent law of Pakistan in lines below.
Key Words: cause of action, valuation of suit, rejection of plaint, barred by law, precedent.
02. Relevant Law:
· Order VII, Rule 11 of Code of Civil Procedure, 1908
· Part B, Reception of Plaints and applications, Volume-I, High Court Rules and Orders, LHC.
· Part C, Examination of plaint, Volume-I, High Court Rules and Orders, LHC.
· Suit Valuation Act 1887, S.11
· Court Fee Act 1870
03. Grounds for Rejection of Plaint
The grounds for rejection of plaint has been specified in Order VII Rule 11 of Code of Civil Procedure 1908 e.g. (i) where
the suit does not disclose a cause of action, (ii) relief claimed is undervalued and the plaintiff on being required by the court to
correct the valuation within a time to be fixed by the court, fails to do so or the relief claimed is properly valued but the plaint is
written on insufficiently stamped paper and the plaintiff fails to supply requisite stamp paper within the time to be fixed by the
court or (iii) where the suit appears from the statement in the plaint to be barred by any law. These grounds have been elaborated
by the Superior Courts of Pakistan and the principles have been finally settled. The Order VII, Rule 11 of the Code of Civil
Procedure 1908 reads as under:
“The plaint shall be rejected in the following cases:-
a) Where it does not disclose a cause of action:
b) Where the relief claimed is under-valued, and the plaintiff, on being required by the Court to correct the
valuation within a time to be fixed by the Court, fails to do so:
c) Where the relief claimed is properly valued, but the plaint is written upon paper insufficiently stamped, and the
plaintiff, on being required by the Court to supply the requisite stamp-paper within a time to be fixed by the
Court, fails to do so:
d) Where the suit appears from the statement in the plaint to be barred by any law.”
The bare reading of the Rule 11 supra makes it certain that plaint can be rejected only in specified circumstances. However, this
Rule is not exhaustive and there are many circumstances wherein the plaint may be rejected or the suit may be dismissed. In
particular, the ground ‘barred by law’ is of wide connotation and covers express and implied bars. The word ‘shall’ clearly indicate
that rejection of plaint is mandatory and not discretionary when any of the grounds is present.

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04. General Principles

The most controversial and ambiguous aspect of the topic under consideration is acknowledgment of various general principles
and their exceptions by Superior Courts of Pakistan in various precedents. The most applied general rules and their exceptions are
as follows.
[6]
§ The first general principle is that every averment made in the plaint is to be accepted as correct’. The August Supreme Court
of Pakistan has recently clarified that ‘there can be little doubt that primacy, not necessarily exclusivity, is to be given to the
contents of plaint. The contents of written statement are not be examined and put in juxtaposition with the plaint in order to
determine whether contents of plaint are correct or incorrect. In carrying out analysis of the averments contained in plaint, the
[7]
court is not denuded to its normal judicial power of scrutiny. Thus, correctness of averments of plaint is general rule
subject to exception of judicial scrutiny.
§ The second general principle is that ‘the defense taken in the written statement cannot be looked into while considering
[8] [9]
rejection of the plaint’ except when legal plea e.g. res-judicata or time barred etc is advanced. However, in a case, the
respondent filed written statement, did not advance pleas of valuation and maintainability of the suit. The trial Court and
appellate court rejected plaint. The High Court ruled that the plea raised by the respondent was in nature of a defense in the
suit and cannot be looked into while considering the application under Order VII Rule 11 CPC 1908. These pleas are open to
[10]
be raised by the respondent at the time of trial of the suit. Thus, generally, the defense cannot be looked into but with
exception of legal plea.
§ The third general principle is that ‘the fact that the plaintiffs may ultimately fail in establishing the allegations in the plaint
[11]
cannot be a ground for rejecting a plaint under Order VII Rule 11 of CPC 1908. There is no controversy in this regard
and there is no exception to this rule.
[12]
§ The fourth one is that ‘the court should examine plaint for purpose of rejection of plaint at the time of presentation’’. The
August Supreme Court of Pakistan concluded that the rejection of plaint is contemplated at a stage when the Court has not
[13]
recorded any evidence in the suit. In another precedent, it was decided that where evidence had already been recorded and
the parties were seriously at issue, the Court should instead of rejecting the plaint, decide the dispute on merits by referring to
[14]
evidence of the parties. The plaint cannot be rejected without deciding the issues already framed. In such case, the proper
[15]
course for the Court would be to decide all issues together. However, the plaint can be rejected while dismissing
[16]
application for temporary injunction. In suit for specific performance, the Court concluded that the question- whether at
the time of entering into agreement the defendant had title to the property or not is a question of fact and the same cannot be
[17]
decided without allowing the parties to lead evidence. Thus, generally, rejection of plaint is preferred at the inception with
exception of before framing of issues.
[18]
§ The fifth general principle is that only contents of plaint should be looked into for rejection of plaint. However, exception
of this principle is- If there is some other material before the Court apart from the plaint at that stage which is admitted by the
[19]
plaintiff, the same can also be looked into and taken into consideration by the Court. The documents referred in plaint can
[20] [21]
be looked into. Even, documents of defendant qua res-judicata can also be looked into for rejection of plaint.
§ The sixth general principle is relevant with the suit which is not regulated in toto by Code of Civil Procedure 1908. However, the
provisions of Code of Civil Procedure 1908 are applied mutatis mutandis. The Peshawar High Court declared where
provisions of Code of Civil Procedure 1908 mutatis mutandis apply, the plaint can be rejected as in case of proceedings
[22]
under Defamation Ordinance 2002.
[23]
§ The seventh general principle is that plaint can be rejected suo moto without application of defendant. There is no exception
or dispute qua this principle.
[24]
§ The eighth general principle is- when plaint is vague, no rejection but amendment of plaint is just. Similarly, when factual
[25]
investigation is required, there should be no rejection of plaint. However, the exception of this general principle is- when
the rights of rival party are infringed, the plaint should be rejected. For example, when amendment of plaint changes character
[26]
and complexion of suit e.g. suit for declaration becomes suit for specific performance and vice-versa.
05. Cause of action

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The first ground for rejection of plaint is ‘non-disclosure of cause of action’. The word ‘action’ means proceedings in which a legal
[27]
demand of a right is made. The phrase ‘cause of action’ has been defined by Privy Council as- ‘every fact which if traversed, it
should be necessary for the plaintiff to prove in order to support his right to judgment, and which if not proved gives the defendant
[28]
a right to judgment. Supreme Court of Pakistan defined ‘cause of action’ as- ‘the ground on the basis of which the plaintiff
[29]
asks for favorable judgment and not related to defense or the relief prayed for’. The Lahore High Court defined ‘cause of
action’ as ‘the bundle or totality of essential facts which it is necessary for the plaintiff to prove before he can succeed. There may
[30]
be different causes of action from one transaction’.
There is an important question- how to answer whether the cause of action is same or not? The jurists and the precedents
answer this question. There are many tests which answer this aspect. First, if the evidence to support the two claims is different,
[31]
then the causes of action are also different. Similarly, the causes of actions in two suits may be considered the same if they are
[32]
identical in substance. For example, the petitioner issued cheques in favour of the respondent. The cheques were dishonored
and suit was filed. Subsequently, some agreements were executed in connection with cheques. The defendant raised objection of
cause of action. The High Court declared that from the contents of the suit, a cause of action was clearly disclosed in favour of the
respondent. The effect of subsequent events and disclosure of certain facts including execution of agreements, the circumstances
and the purpose for which said agreements were executed, will be the subject matter of examination by the learned trial court in
light of the evidence produced before it. The learned trial court after recording evidence of both parties would also be competent to
[33]
determine the effect of the said agreements on the suit filed by the respondents. If cause of action arises out of Pakistan, the
[34]
suit is not maintainable.
There is distinction between disclosure of cause of action and accrual of cause of action. There may be disclosure of cause
of action without accrual of the same. For example, when certain time is fixed for performance of agreement, the institution of suit
[35]
for specific performance is declared premature and suit is dismissed and not plaint is rejected. The reason is that there is a
disclosure of cause of action but not accrual of cause of cause of action. Similarly, contingent contracts also disclose but not accrue
[36]
cause of action before happening of contingency.
06. Under-Valuation of Relief Claimed
The second ground for rejection of plaint is under valuation of relief claimed. This ground has nexus with valuation of suit for
purpose of jurisdiction. This valuation is done under Suit valuation Act 1887. The initial duty of determination of proper valuation
[37]
of relief is upon the plaintiff. If valuation of relief determined by the plaintiff is incorrect, it the duty of the court to determine
[38]
proper valuation and also allow reasonable time to amend the plaint accordingly. Furthermore, the person presenting plaint
may be questioned by the Court in this regard and his answer may be recorded on plaint unless consent is given to amend the plaint
[39] [40]
then and there. The court should determine the proper valuation of the suit at the early stage. When, the plaintiff fails in
[41]
correcting the valuation of the relief, only then, rejection of plaint is permissible.
[42]
Only the plaint is to be looked into for determination of valuation of claim. If valuation determined by the court
[43]
exceeds the jurisdiction of the court, the plaint should be returned. The cardinal aspect is that valuation is to be determined of
not the whole relief but the claimed relief by the plaintiff. If some part of relief is relinquished, then omitted relief is exempted
from valuation. For example, A files suit for recovery of loan amount of Rs. 100000/- and interest Rs.25000/- but claims only
principal loan amount Rs. 100000/-. In this situation, valuation is to be based upon principal loan amount and not interest. The
[44]
provisions of Order VII Rule 11 are mandatory not discretionary.
07. Insufficient Court fee Stamps
The third ground for rejection of plaint is insufficiency of court fee stamps. The clause © of Rule 11 supra presupposes correct
[45]
valuation of relief claimed and is not attracted when court fee is not payable. The reader of concerned Court has the initial
duty to check court fee on the plaint and is responsible for loss. In case of ambiguity, the reader should refer the matter to the court.
[46]
However, the court has the ultimate duty to determine proper court fee payable by the plaintiff and grant reasonable time to
make good the deficiency of court fee. The court has discretionary power to extend time granted for making payment of court fee
[47]
unless there is contumacy; gross negligence and malafide under sections 148 and 149 Code of Civil Procedure 1908. The time
[48]
may also be extended under section 151 of Code of Civil Procedure 1908. When, the deficiency is removed, the plaint is

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[49]
deemed instituted from date of presentation. The issue may also be framed for determination of proper valuation of court fee.
[50]

08. Barred by Law

The fourth ground for rejection of plaint is ‘barred by law’ The ‘law’ means written law or statute law and is used in generic sense.
[51] [52]
Law means – a formal pronouncement of the will of a competent law giver. Law includes- constitution, statutes, judicial
[53]
principles, rules, by-laws etc. The illustrations when the suit is barred by law are- (i) Time barred suit is dismissed under
[54]
section 3 of Limitation Act 1908 and plaint is not rejected under Order VII Rule 11 of C.P.C. The law of limitation prevalent at
[55]
the time of institution of suit applies and not when cause of action arose. (ii) The relief relinquished in respect of one cause of
action is barred under Order II Rule 2 of C.P.C 1908. (iii) The suit hit by multifariousness is barred under Section 11, Explanation
IV of C.P.C 1908. (iv) The suit regarding execution, discharge and satisfaction of decree is barred under section 47 of CPC 1908.
(v) The suit hit by principle of res-judicata is barred under section 11 of C.P.C 1908. (vi) The suit regarding public nuisance
without consent of advocate general is barred under section 92 of C.P.C 1908. (vii) The suit for setting aside decree is barred under
section 12(2) of C.P.C 1908. (viii) The suit hit by doctrine of estopple is barred under article 114 of Qanun-e-Shadat Order 1984.
(ix) The suit for pre-emption by person who is not pre-emptor under section 6 of Punjab Pre-emption Act 1991. (x) When suit
withdrawn without permission, fresh suit barred on same cause of action under Order XXIII Rule 3. (xi) The suit for permanent
injunction restraining public functionaries from official functions is barred under section 56 (d) of Specific Relief Act 1877. (xii)
Suit for declaration on the basis of agreement to sell is barred under section 42 of Specific Relief Act 1877. (xiii) The suits for
specific performance of the nature which cannot be specifically enforced under section 21 of Specific Relief Act 1877. (xiv) Inter
pleader suit which does not fulfill conditions under section 88 and Order XXXV of C.P.C 1908.
09. Rejection of Plaint and Dismissal of Suit
The Lahore High Court discussed distinction between rejection of plaint and dismissal of suit in the words that "the rejection of
plaint" meant that if ingredients in Order VII, Rule.11 C.P.C. 1908 were available in plaint, the Court had jurisdiction and powers
to reject the plaint. Dismissal of suit connoted that it was a final determination of controversy between parties meaning thereby the
[56]
Trial Court could dismiss the suit only after holding inquiry and recording of evidence. Rejection of plaint provided or opened
door for plaintiff for filing fresh suit but in case of dismissal of suit, no fresh suit could be filed and only statutory remedy was
available against dismissal order. The defendants filed application under Section 151 of C.P.C. by placing on record all facts finally
settled between parties and plaintiffs admitted all such facts. Hence, no question for further determination of any issue had arisen
and the Court was within its rights to reject the plaint under O. VII, R.11, .C.P.C. Dismissal of suit for invoking doctrine of res
[57] [58]
judicata was not correct interpretation of law. Rejection of plaint is proper order not dismissal of suit.
10. Rejection of Plaint and Return of Plaint
There is delicate simple difference between rejection of plaint and return of plaint. Return of plaint is concerned with competency
of the Court whereas rejection of plaint is concerned with competency of the suit. When, the court comes to conclusion at any
stage that it has no jurisdiction, the plaint is to be returned under Order VII Rule 10 and not rejected under Order VII Rule 11 of
[59]
Code of Civil Procedure 1908. The orders ‘corum non judice’ are nullity in eyes of law. The Court having jurisdiction can pass
an order under Order VII Rule 11 of C.P.C 1908.
11. Consequences
The consequences of rejection of plaint are both ultimate and temporary. The ‘rejection of plaint is not res-judicata against a
[60] [61]
plaintiff and defendant’ except when rejection of plaint amounts to final adjudication e.g. res-judicata or time barred suit.
The rejection of plaint is decree as defined in section 2(2) and is appealable under Order 41 Rule 23 of Code of Civil Procedure
1908. However, when plaint is not rejected, the order of rejection can be questioned in revision. The fresh suit may be instituted if
[62]
not barred by law.
12. Conclusions and Recommendations
The Order VII Rule 11 of Code of Civil Procedure 1908 is not exhaustive in nature as there are many other grounds which may
justify rejection of plaint. The Order VII Rule 11 C.P.C, 1908 is mandatory not directory in nature having penal consequences. The
general rule that- only averments of plaint are relevant for rejection of plaint’ has two exceptions- (i) the documents admitted by
plaintiff annexed with plaint can be looked into and (ii) in exceptional circumstances e.g. res-judicata or time barred suit ,
documents of defendant too. Similarly, the averments of plaint are presumed correct but subject to judicial scrutiny by the court.
Generally, the plaint can be rejected at any stage but preferably at initial stage before issuance of summons and seldom at later
stage. When issues have been framed, the suit should be decided on merits. The disclosure of cause of action and accrual of cause
of action are distinct aspects. The rejection of plaint is relevant with former not later aspect. The plaint is not to be rejected when
amendment of plaint is permissible under the law. The reason able time must be granted to determine proper valuation of relief or
make good deficiency of court fee and grant of time by the court is mandatory. The further enlargement of time fixed by court is
permitted except when there is contumacy, malafide and gross negligence of plaintiff. The rejection of plaint and dismissal of suit

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or two distinct aspects. Rejection of plaint not dismissal of suit is proper order on grounds detailed in Order VII Rule 11 C.P.C
1908. The law of limitation prevalent at the time of institution of suit applies and not when cause of action arose. The plaint can be
rejected suo moto without application by defendants. The order of rejection of plaint is appealable whereas order of refusal to
reject plaint is revisable.
----------------------

[1]
. The writer is an HEC Scholar for PhD in Law enrolled in University of South Asia, Lahore. This article is meant for enrichment of legal
acumen. Hence, I shall be highly obliged to those learned fellows who pinpoint and resolve deficiencies and errors relevant with this topic and
communicate me at this email address: ajmal7361@yahoo.com.
[2]
. The worthy Dr. Dil Muhammad Malik is co-author of this article and Supervisor and Dean Faculty of Law, University of South Asia Lahore and
ex-principal Punjab University Law College Lahore.
[3]
. Nanik Ram V. Ghullam Akbar, 2016 MLD 52 (Kar).
[4]
. Ibid.
[5]
. Sher Khan v. Gulzar Khan, 2016 CLC 663 (Pesh)
[6]
. Mst. Shabeona Perveen v. M/s. Defence Officers Housing Society Authority, Karachi, 1993 CLC 2523; Hakim Bashir Ahmad Vs. The
Government of Sind through Deputy Commissioner, Hyderabad and 2 others, 1984 CLC 3061; Haji Allah Bakhsh v. Abdul Rehman and
others,1995 SCMR 459
[7]
. Haji Abdul Karim v. Messrs Florida Builders Ltd., PLD 2012 SC 247; AL-Mezan Investment Management Company v. WAPDA First Sukkok
Company Ltd., PLD 2017 SC 1
[8]
. Mst. Shabeona Perveen v. M/s. Defence Officers Housing Society Authority, Karachi, 1993 CLC 2523; Hakim Bashir Ahmad v. The
Government of Sind through Deputy Commissioner, Hyderabad and 2 others,1984 CLC 3061
[9]
. Muhammad Akhtar v. Abdul Hadi, 1981 SCMR 58
[10]
. Mst. Shabeona Perveen v. M/s. Defence Officers Housing Society Authority, Karachi, 1993 CLC 2523
[11]
. Mst. Shabeona Perveen v. M/s. Defence Officers Housing Society Authority, Karachi, 1993 CLC 2523; Hakim Bashir Ahmad v. The
Government of Sind through Deputy Commissioner, Hyderabad and 2 others,1984 CLC 3061
[12]
. Rule 1, Chapter-1-C, Volume 1, Rules and Orders, Lahore High Court
[13]
. Jewan and 7 others Vs. Federation of Pakistan through Secretary Revenue, Islamabad and 2 others,1994 SCMR 826
[14]
. Kamal-ud-Din v. Province of Punjab and others, 1977 MLD 21; Mst. Karim Bibi and others v. Zubair and others,1993 SCMR 2039; Principal,
Government Higher Secondary School, Oghi v. Mir Afzal and 2 others,1995 CLC 525
[15]
. Faiz Ahmad Vs. Ghulam Ali, 2000 AC 739
[16]
. Salah-ud-Din v. Zaheer-ud-din, PLD 1988 SC 221; Asghar Ali V. P.K Shahani, 1992 CLC 2282
[17]
. Sharjeel Younus v. Salahuddin Mirza, 2008 YLR 1523
[18]
. Egypt Air v. Sarfraz Ahmad Tarar, 2003 CLC 1425
[19]
. Jewan and 7 others v. Federation of Pakistan through Secretary Revenue, Islamabad and 2 others,1994 SCMR 826
[20]
. Shireen Nawaz v. University of Peshawar, 1998 CLC 308
[21]
. Muhammad Akhtar v. Abdul Hadi, 1981 SCMR 58
[22]
. Abdur Rashid v. S. Fida-ur-Rehman Shah, PLD 2017 Pesh 19. Defamation Ordinance, 2002, S. 10.
[23]
. Abdur Rashid v. S. Fida-ur-Rehman Shah, PLD 2017 Pesh 19
[24]
. NED University of Engineering & Tech v. Tariq Ali, PLD 1993 Kar 626
[25]
. Manzoor Ahmed v. Abdul Khaliq, 1990 SCMR 1677; See also: Fatima Moeen v. Additional District Judge Sheikhupura, 1992 SCMR 1199
[26]
. Mushtaq Ahmed v. Muhammad Aslam, 2016 CLCN 100 (Pesh)
[27]
. Messrs Rah-e-Manzil Transport and others v. Muhammad Ameen, PLD 1963 Kar 182
[28]
. Read v. Brown, (1889) 22 Q B D 128; Read also: Muhammad Khalid Khan v. Mahbub Ali Mian etc, PLD 1948 PC 131;Abdul Hakim etc v.
Saadullah Khan etc., PLD 1970 SC 63; Mitha Khan v. Muhammad Younis, 1991 SCMR 2030
[29]
. PLD 1970 SC 363
[30]
. Muhammad Yateem v. Ghullam Nabi, PLD 1975 Lah 563
[31]
. Brunsden v. Humphery, (1884) 14 QBD 141; See also: Muhammad Yateem v. Ghullam Nabi etc., PLD 1975 Lah 563
[32]
. Ibid.

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[33]
. Hamid Ghani v. Basit Siddiqui, 2011 LHC 2383
[34]
. Global Containers Lines Ltd. V. American President Lines Ltd., 1998 CLC 360
[35]
. Limitation Act 1908, Section 3; Schedule 1, Article 113.
[36]
. Contract Act 1872, Sections 31 to 35.
[37]
. Rules and Orders of Lahore High Court Lahore, Volume I, Chapter 3-A, Rule 7
[38]
. Zafar Alam v. Member revenue Board, 1991 SCMR 1153
[39]
. Rules and Orders of Lahore High Court Lahore, Volume I, Chapter 3-A, Rule 7
[40]
. Muhammad Nasrullah v. Muhammad Ayaz, PLD 1975 Lah 886
[41]
. Parveen v. Jamsheda Begum, PLD 1983 SC 227
[42]
. Allah Bakhsh v. Abdul Rehman, 1995 SCMR 459
[43]
. PLD 1971 Kar 682
[44]
. PLD 1994 SC AJK 32
[45]
. Sher Bahadur Khan v. Anwar Khan, 1996 CLC 1624
[46]
. Rule 5, Chapter-1-B, Volume 1, Rules and Orders, Lahore High Court.
[47]
. Code of Civil Procedure, 1908, s.149; Siddiqui Khan v. Abdul Shakoor, PLD 1984 SC 289; 1994 SCMR 262
[48]
. Faqir Muhammad v. Noor Muhammad, 1970 SCMR 188
[49]
. PLD 1970 SC 42
[50]
. Muhammad Yaqoob v. Additional District Judge Kasur, 1985 CLC 774
[51]
. Shahzad Hussain v. Hajiran Bibi, PLD 1990 Lah 222
[52]
. Federation v. United Sugar Mills, PLD 1977 SC 397
[53]
. Al-Jihad case, PLD 1997 SC 84
[54]
. Limitation Act, 1908, s.3; PLD 1977 Lah 1243
[55]
. PLJ 1983 SC 143
[56]
. Al-Mezan Investment Management Company Ltd. V. Wapda First Sukkok Company Ltd., PLD 2017 SC 1
[57]
. Muhammad Anwar Etc v. Province of Punjab through District Officer (Revenue), Pakpattan etc., 2017 CLC 1660
[58]
. Rule 6, Chapter-1-C, Volume 1, Rules and Orders, Lahore High Court.
[59]
. Administrator Thal Development v. Ali Muhammad, 2012 SCMR 730.
[60]
. Province of the Punjab through Collector, Sheikhupura v. Syed Ghazanfar Ali Shah, 2017 SCMR 172
[61]
. Shahzad Hussain v. Hajiran Bibi, PLD 1990 Lah 222
[62]
. Mian Khan v. Aurangzeb, 1989 SCMR 58

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