IN THE COURT OF DISTRICT JUDGE, MULTAN.

Suit No. ____________/2002

Malik Allah Rakha S/o Malik Sardar Khan, caste Raan, R/o
Mohallah Nizam Abad, Khanewal Road, Multan.
Plaintiff
VERSUS
Muhammad Aslam S/o Muhammad Ashiq, caste Abaya, R/o House
No. 888/30, Mohallah Ghaffaria, near Chungi No. 6, Bosan Road,
Multan.
Defendant

Suit under order 37, rule 1 & section 151

C.P.C. for the recovery of Rs. 48,000/-.
The plaintiff respectfully sheweth as under: -

1. That the plaintiff and defendant belong to the same locality

therefore, the defendant is known to the plaintiff.

2. That the defendant is running a fruit shop near Khana-e-

Farhang Iran, Khanewal Road, Multan. He came to the

plaintiff and said that he was facing crises, therefore, he was

in need of money. He asked the plaintiff to lend him an

amount of Rs. 48,000/- for two months. He promised to return

the same within the promised period without fail.

3. That on 11.9.2001, in presence of witnesses, the plaintiff gave

the demanded amount of Rs. 48,000/- as loan to the

defendant. At the very moment, the defendant got executed

the receipt and pronote of the said borrowed amount and

handed over them to the plaintiff.

4. That after passing more than two months, the plaintiff asked

the defendant to return the borrowed amount to the plaintiff.

But he after making some lame excuses, totally refused to pay

back the borrowed amount.

5. That the plaintiff has asked the defendant time and again to

pay back the loan amount to the plaintiff but he has refused to

do so, therefore, the cause of action has accrued to the

plaintiff.

6. That for the first time, the cause of action has arisen on

11.9.2001, when the defendant got the loan from the plaintiff

and gave receipt and pronote in lieu thereof and last time a

week ago when the defendant has totally refused to pay back

the borrowed amount.

7. That the parties reside in Multan and cause of action has

arisen in Multan, therefore this court has the jurisdiction to try

this suit.

8. That value of the suit for the purposes of court fee and

jurisdiction is Rs. 48,000/-. Therefore the plaintiff has affixed

count fee of Rs. 3,600/-.

 Under these circumstances, it is humbly prayed

that the suit for the recovery of Rs. 48,000/- may very

graciously be decreed in favour of the plaintiff against

the defendant with costs throughout.

Humble Plaintiff,
Dated: _________

Through: -
Syed Muhammad Afaq Shah,
Advocate High Court,
93-District Courts, Multan.

Verification: -
Verified on oath this ______ day of January,
2002 that contents of the suit are true and to
the best of my knowledge and belief.
Deponent