IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN.

Sui Northern Gas Pipelines Limited, Gas House, 21-Kashmir Road,

Lahore through General Manager (Legal) Lahore, having its
Distribution Office at 7-A Piran Ghaib Road, Multan.
PLAINTIFF

VERSUS

Abdul Hameed S/o Haji Abdul Aziz, Nan Farosh, Shop No. 1485/8,
Chowk Lakkar Mandi, Multan.
DEFENDANT

SUIT FOR RECOVERY OF RS. 44,341/-

Respectfully Sheweth: -
1. That the Plaintiff is a Public Limited Company duly incorporated under the
Companies Act, 1913 (Now Companies Ordinance 1984) having its registered
office at Gas House, 21-Kashmir Road Lahore and Regional office situated at
Piran Ghaib Road, Multan.

2. That Mr. Shahid Hamid, who is General Manager (Legal) of the

Plaintiff Company and has signed and verified this plaint, is duly
competent and authorised to do so through General Power of
Attorney, executed in his favour by the Board of Directors of the
Plaintiff Company. He is fully conversant with the facts of this
 suit and is competent to institute this plaint. Copy of power of
attorney is annexed with the plaint.
3. That the defendant entered into an agreement with the Plaintiff Company for
the supply of Gas to its premises namely Abdul Hameed S/o Haji Abdul Aziz,
Nan Farosh, Shop No. 1485/8, Chowk Lakkar Mandi, Multan.
4. That the supply of the Gas was commissioned on 22.3.96 to the
defendant’s premises vide Consumer No. 11240029250.
5. That the defendant failed to make the payment of monthly gas
bills with effect from April 1998 issued to him and as such an
amount of Rs. 73,341/- was outstanding and payable by the
defendant to the Plaintiff Company on 28.4.98 when the gas
supply was disconnected due to non-payment of outstanding gas
bills. The defendant made the payment of Rs. 24,000/- on
different occasions and the same has been duly deducted from the
outstanding amount, detail of which has been given in the detail
of outstanding arrears, annexed with the plaint.
6. That the defendant had also deposited the amount of security of Rs. 5,000/-,
which has been adjusted against the outstanding amount of Rs. 73,341/- and
the balance of Rs. 44,341/- is still outstanding and payable by the defendant.

7. That a number of times, the defendant was reminded verbally, through letters
and through notices to pay the outstanding amount but he is adamant. Hence,
this suit.

8. That the cause of action in favour of the Plaintiff and against the defendant
accrued at the time of commencement of original agreement for the supply of
gas when the gas was commissioned and thereafter when the supply of gas
was disconnected on 28.4.98 and was advised to pay the outstanding gas bill
but the defendant failed to clear the same and finally a week ago when the
defendant refused to make payment of the total outstanding amount of Rs.
44,341/-.

9. That the cause of action arose within the limits of Tehsil & District Multan as
the defendant resides in Multan; therefore, this Court has jurisdiction to
adjudicate upon this suit.
10.That the value of the suit for the purpose of Court fee and jurisdiction is fixed
as Rs. 53,440/- for which, Court fee of Rs. 4010/- is fixed under this law.

Under the above circumstances, it is respectfully prayed that a

decree for Rs. 53,440/- along with interest/mark-up, as stipulated in
Clause 15 (i) of the Gas Supply Contract, from the date of default till
the realisation of decretal amount, may kindly be passed in favour of
the Plaintiff and against the defendant with costs.
Any other relief, of which, the Plaintiff is found entitled, may
also be granted, in the supreme interest of justice.

HUMBLE PLAINTIFF

Through: -
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.

Verification: -
Verified on oath at Multan this _____
day of ________ 2001 that para No. 1
to 6 are correct to the best of my
knowledge and remaining paras are
true to the best of my information.

PLAINTIFF
IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN.

Sui Northern Gas Pipelines Limited, Gas House, 21-Kashmir Road,

Lahore through General Manager (Legal) Lahore, having its
Distribution Office at 7-A Piran Ghaib Road, Multan.
PLAINTIFF

VERSUS

Abdul Jabbar S/o Noor Elahi, R/o Kulcha House near National Bank
of Pakistan, Kumhar Mandi, Vehari Road, Multan.
DEFENDANT

SUIT FOR RECOVERY OF RS. 116,727/-

Respectfully Sheweth: -
1. That the Plaintiff is a Public Limited Company duly incorporated
under the Companies Act, 1913 (Now Companies Ordinance
1984) having its registered office at Gas House, 21-Kashmir
Road Lahore and Regional office situated at Piran Ghaib Road,
Multan.

2. That Mr. Shahid Hamid, who is General Manager (Legal) of the

Plaintiff Company and has signed and verified this plaint, is duly
competent and authorised to do so through General Power of
Attorney, executed in his favour by the Board of Directors of the
 Plaintiff Company. He is fully conversant with the facts of this
suit and is competent to institute this plaint.

3. That the defendant entered into an agreement with the Plaintiff

Company for the supply of Commercial Gas to its premises
namely Abdul Jabbar (Kulcha House) near National Bank of
Pakistan, Kumhar Mandi, Vehari Road, Multan.

4. That the supply of the Gas was commissioned on 18.10.93 to the

defendant’s premises vide Consumer No. 11240029250.

5. That the defendant failed to make the payment of monthly gas

bills along-with charges of pilfered gas, with effect from October,
1998 details of pilfered gas from period 24.3.97 to 4.11.98,
estimated on three highest bills (as per policy) calculated from
the billing period 23.10.96 to 23.12.96, has been enclosed with
the plaint along-with affidavit of the consumer/defendant. As
such Rs. 120,927/- is outstanding and payable by the
consumer/defendant to the plaintiff company on 4.11.98 when the
gas supply was disconnected due to non-payment of outstanding
gas bills/charges.

6. That the defendant had also deposited the amount of security of

Rs. 4,200/-, which has been adjusted against the outstanding
amount of Rs. 120,927/- and the balance of
Rs. 116,727/- is still outstanding and payable by the defendant.

7. That a number of times, the defendant was reminded verbally,

through letters and through notices to pay the outstanding amount
but he is adamant. Hence, this suit.

8. That the cause of action in favour of the Plaintiff and against the
defendant accrued at the time of commencement of original
agreement for the supply of gas when the gas was commissioned
and thereafter when the supply of gas was disconnected on
4.11.98 and was advised to pay the outstanding gas bill but the
defendant failed to clear the same and finally a week ago when
 the defendant refused to make payment of the total outstanding
amount of Rs. 116,727/-.

9. That the cause of action arose within the limits of Tehsil &
District Multan as the defendant resides in Multan; therefore, this
Court has jurisdiction to adjudicate upon this suit.

10.That the value of the suit for the purpose of Court fee and
jurisdiction is fixed as Rs. 116,727/- for which, Court fee of Rs.
8,760/- is fixed under this law.

Under the above circumstances, it is respectfully prayed

that a decree for Rs. 116,727/- along with interest/mark-up, as
stipulated in Clause 15 (i) of the Gas Supply Contract, from
the date of default till the realisation of decretal amount, may
kindly be passed in favour of the Plaintiff and against the
defendant with costs.
Any other relief, of which, the Plaintiff is found
entitled, may also be granted, in the supreme interest of
justice.
HUMBLE PLAINTIFF

Through: -
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.

Verification: -
Verified on oath at Multan this _____
day of ________ 2001 that para No. 1
to 6 are correct to the best of my
knowledge and remaining paras are
true to the best of my information.
 PLAINTIFF

IN THE COURT OF SENIOR CIVIL JUDGE, MULTAN.

Sui Northern Gas Pipelines Limited, Gas House, 21-Kashmir Road,

Lahore through General Manager (Legal) Lahore, having its
Distribution Office at 7-A Piran Ghaib Road, Multan.
PLAINTIFF

VERSUS

Rana Amjad Iqbal S/o Rana Iqbal Azad R/o Café Madni near
Income Tax Office, opposite Gali Fiesta Garden, Nawan Shaher
Multan (ii) H. No. 165 Street No. 2, Chah Bohar Wala, Multan.
DEFENDANT

SUIT FOR RECOVERY OF RS. 46,861/-

Respectfully Sheweth: -
1. That the Plaintiff is a Public Limited Company duly incorporated
under the Companies Act, 1913 (Now Companies Ordinance
1984) having its registered office at Gas House, 21-Kashmir
Road Lahore and Regional office situated at Piran Ghaib Road,
Multan.

2. That Mr. Shahid Hamid, who is General Manager (Legal) of the

Plaintiff Company and has signed and verified this plaint, is duly
competent and authorised to do so through General Power of
 Attorney, executed in his favour by the Board of Directors of the
Plaintiff Company. He is fully conversant with the facts of this
suit and is competent to institute this plaint.

3. That the defendant entered into an agreement with the Plaintiff

Company for the supply of Commercial Gas to its premises
namely Rana Amjad Iqbal son of Iqbal Azad, Café Madni near
Income Tax Office, opposite Gali Fiesta Garden Nawan Shaher,
Multan.

4. That the supply of the Gas was commissioned on 24.9.97 to the

defendant’s premises vide Consumer No. 11230031580.

5. That the defendant failed to make the payment of monthly gas

bills along-with effect from February 1998 issued to him and as
such an amount of Rs. 51,861/- was outstanding and payable by
the defendant to the plaintiff company on 30.10.98 when the gas
supply was disconnected due to non-payment of outstanding gas
bills.

6. That the defendant had deposited the amount of security of Rs.

5,000/-, which has been adjusted against the outstanding amount
of Rs. 51,861/- and the balance of Rs. 46,861/- is still outstanding
and payable by the defendant.

7. That a number of times, the defendant was reminded verbally,

through letters and through notices to pay the outstanding amount
but he is adamant. Hence, this suit.

8. That the cause of action in favour of the Plaintiff and against the
defendant accrued at the time of commencement of original
agreement for the supply of gas when the gas was commissioned
and thereafter when the supply of gas was disconnected on
30.10.98 and was advised to pay the outstanding gas bill but the
defendant failed to clear the same and finally a week ago when
the defendant refused to make payment of the total outstanding
amount of Rs. 46,861/-.
9. That the cause of action arose within the limits of Tehsil &
District Multan as the defendant resides in Multan; therefore, this
Court has jurisdiction to adjudicate upon this suit.

10.That the value of the suit for the purpose of Court fee and
jurisdiction is fixed as Rs. 46,861/- for which, Court fee of
Rs. 3,515/- is fixed under this law.

Under the above circumstances, it is respectfully prayed

that a decree for Rs. 46,861/- along with interest/mark-up, as
stipulated in Clause 15 (i) of the Gas Supply Contract, from
the date of default till the realisation of decretal amount, may
kindly be passed in favour of the Plaintiff and against the
defendant with costs.
Any other relief, of which, the Plaintiff is found
entitled, may also be granted, in the supreme interest of
justice.
HUMBLE PLAINTIFF

Through: -
Saeed Hassan Hashmi
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.

Verification: -
Verified on oath at Multan this _____
day of ________ 2001 that para No. 1
to 6 are correct to the best of my
knowledge and remaining paras are
true to the best of my information.

PLAINTIFF