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In re:
Muhammad Alam etc. Vs. Small Business
Finance Corporation
Vehari etc.
Respectfully Sheweth:-
Humble Respondent.
Through: -
Through:-
SAEED HASSAN HASHMI MANAGER
Advocate High Court,
Seat No. 40, Aziz Block
District Courts, Multan.
IN THE COURT OF MUHAMMAD KHALIL CHAUDHARY,
JUDGE BANKING COURT NO-II, MULTAN.
In re:
Muhammad Alam etc. Vs. Small Business
Finance Corporation
Vehari etc.
AFFIDAVIT of:-
Mushtaq Sarwar Manager Small Business
Finance Corporation, Vehari.
Deponent.
Verification: -
Verified on oath at Multan,
this_____ day of August, 1999 that the contents
of this affidavit are true to the best of my
knowledge and belief.
Deponent
IN THE COURT OF MALIK AHMAD BAKHSH BHAPA,
JUDGE BANKING COURT NO-I, MULTAN.
In re:
Wazeer Ahmad Vs. Small Business
Finance Corporation
Vehari etc.
Memo of Appearance
Respectfully Sheweth:-
1. That the above titled suit is pending adjudication before this
Hon’ble Court and is fixed for today.
2. That the above titled suit of the undersigned has been engaged
as a counsel to defend the suit. The power of Attorney still has
not been received; the same will be produced as soon as
received.
Through:-
In the ____________________________________________________________________________
in the matter of ____________________________________________________________________
______________________________________________Plaintiff/Appellant/Petitioner/Complainant
FIR. No._________________
Dated:___________________
U/s _____________________
P.S. ____________________
Versus
Defendant/Respondent/Accused
KNOW we all to whom these presents shall come that I/we, the undersigned, appoint
Saeed Hassan Hashmi
Advocate High Court
to be the Advocate for the _____________in the above mentioned case to do all following acts, deeds
and things or any of them, that is to say: -
1. To act, appear and plead in this court or any other court in which the same may be tried or heard in
the first instance or in appeal or review or revision or execution or in any other stage of its progress
until its final decision.
2. To present pleading, appeals, cross objections or Petitions for execution, review, revision, withdrawal,
compromise or other Petitions or affidavits or other documents as shall deemed necessary or
advisable for the prosecution of the said cause at all its stages.
3. To withdraw or compromise the said cause or submit to arbitration any differences or disputes that
shall arise touching or in any manner relating to the said cause.
4. To receive money and grant receipts thereof and to do all other acts and things which may be
necessary to be done for the progress in course of the prosecution of the said case.
5. To employee any other Legal Practitioner authorising him to exercise the power and authorities
hereby conferred on the Advocate whenever he may think fit to do so. AND I hereby agree to ratify
whatever the Advocate or his substitute shall do in the premises,
AND I hereby agree not to hold the Advocate or his substitute responsible for the result of the said
cause in consequence of his absence from the court when the said cause is called up for hearing
AND I hereby agree in the event of the whole or any part of the fee agreed by me to be paid to
Advocate remaining unpaid, he will be entitled to withdraw from the prosecution of the said cause
until the same is paid.
IN WITNESS WHEREOF I/WE hereunto set my/our hands to these presents the contents of which
have been explained to be understood by me this the
________day of ________1999.
Accepted subject to payment of full fee.
Sr. Consumer Name & Address of Title of the Date of Stay Amount involved Amount Status Remarks
No. No. the Suit/Appeal/Petition filing of granted/ not recovered
Consumer/plaintiff Suit/ Nature of suit/ Name of court granted Default Pilferage if any
Appeal/ cause of action.
Petition.
1131084572 Muhammad Ali R/o Muhammad Ali Suit for Muhammad. Stay granted 5056 __ Fixed for There
1 Street No. 4, T.B. Vs 30.3.98 Declaration. Naeem Sheikh but vacated. evidence of are bright
Hospital, Multan. S.N.G.P.L. S.N.G.P.L. chances
Gul Sher Muhammad Gul Sher Muhammad Suit for Sadiq Masood Stay granted 148106 Evidence
2 11210028373 R/o Mohallah Sadiq Vs 17.10.98 Declaration. but vacated.
Abad, old Shujabad S.N.G.P.L.
Road, Multan.
Rana Shahid Iqbal S.N.G.P.L. 13.11.99 Recovery Ch. Muhammad Recovery 125824.18 Evidence
City Top Restaurant Vs Siddique suit of
3 11200026826 B.C.G. Chowk Bwp. Rana Shahid Iqbal S.N.G.P.L
Road, Multan. .
4 11240018803 Sh. Asif Data Bakery Sh. Asif Ali 24.9.99 Suit for Rana Stay granted X 10137/- Full Evidence
13-A Nusrat Road, Vs Declaration Muhammad but vacated. alongwith
Multan. S.N.G.P.L. Akram charges
5 11320427524 Sh. Asif Data Bakery Sh. Asif Ali 27.7.99 Suit for Rana Stay granted X Evidence
13-A Nusrat Road, Vs injunction Muhammad but vacated.
Multan. S.N.G.P.L. Akram
6 11210028373 Gul Sher Muhammad S.N.G.P.L. 2.12.99 Recovery Ch. Rasheed Recovery 139105.92 Evidence
R/o Mohallah Sadiq Vs Ahmad suit of
Abad, old Shujabad Gul Sher S.N.G.P.L
Road, Multan.
7 11200028435 Pop Corn Factory, S.N.G.P.L. 15.12.99 Recovery Ch. Rasheed Recovery 25216/- Summons
Yaqoob Town Vs Ahmad suit for
Multan. Muhammad Ashfaq attendance
8 Peer Khursheed Muhammad Iqbal Dec’1999 Suit for Mian M. Riaz Stay granted Report of
Colony, Multan. Vs S.N.G.P.L. declaration Khurram but vacated. Commission
9 11200020099 Chowk Shah Abbas, Irshad Ahmad 25.11.99 Suit for Muhammad Stay granted 62862/- Evidence
Suraj Kund Raod, Vs declaration Naeem Sheikh but vacated. of plaintiff
Multan. S.N.G.P.L.
10 11210028276 Gali No. 2, Mohallah S.N.G.P.L. 24.1.2000 Recovery Sadiq Masood Recovery 11925/- Evidence
Aslam Abad, Masoom Vs suit
Shah Road, Multan. Hafiz Maqsood
11 11200029869 Gali No. 1 Ghaus S.N.G.P.L. 14.3.2000 Recovery Sardar Recovery 630047/- Evidence
Abad, near Central Vs Muhammad suit
Jail, Multan. Ali Sher Babar
12 11200030120 Plot No. 46, Mauza S.N.G.P.L. 14.3.2000 Recovery Sardar Recovery 73208/- Ex-parte
Taraf Daira Vehari, Vs Muhammad suit Evidence
road Multan. Muhammad Tahir Babar
13 11200029126 Muhammad Hashim, S.N.G.P.L. 16.5.2000 Recovery Mian Recovery 23457.53 Correct
R/o Muhammadi Vs Muhammad suit address
Mohallah Multan. Hashim Ali Riaz Khurram
14 14304008088 Muhammad Yousaf, Muhammad Yousaf 4.4.2000 Suit for Taj Muhammad Stay not 4873/- Argument
R/o H.No. 2004, I/s Vs injunction Mirza granted
Daulat Gate, Multan. S.N.G.P.L.
15 11210026407 H. No. 1263, Bagh S.N.G.P.L. 23.5.2000 Recovery Sadiq Masood Recovery 104232/- Summon
Vehra O/s Dehli Vs suit
Gate, Multan. Muhammad Rafiq
16 11240029539 Shop No. 1500/8, S.N.G.P.L. 23.5.2000 Recovery Mahmood Recovery 28146/- Recovery
Lakar Mandi Multan. Vs Haroon Khan suit
Abdul Khaliq
17 11210023011 Fish Corner H. No. 3, Muhammad Nasir 5.4.2000 Suit for Taj Muhammad Stay not 84296/- Arguments
Main Street Masoom Vs declaration Mirza granted
Shah Road, Multan. S.N.G.P.L.
18 11350999948 Muhammad Nawaz Capt. Muhammad May’2000 Suit for Syed Pervaiz Ali 19040/- Arguments
77 A.C. Saddar C-12, Nawaz declaration Shah
Circuit House, Multan. Vs S.N.G.P.L.
19 11210030358 Mohallah Iqbal Sh. Muhammad Jan’2000 Suit for Mian Stay not 116845/- Evidence
Nagar, T.B. Hospital Saleem injunction Muhammad granted
Multan. Vs Riaz Khurram
S.N.G.P.L.
20 11213220026 Arshad Sweet Mart, Arshad Ali 2.6.2000 Suit for Rana .Stay 57994/- Arguments
Opp. Hassnain Oil Vs declaration Muhammad granted
Mills, Central Jail, S.N.G.P.L. Akram
Multan.
21 11320220155 Muahammad Hanif Muhammad Hanif Aug’2000 Appeal Basheer Ahmad Stay not 29110/ Summon-
R/o Gulgasht Colony Vs Bhatti granted. ing of
Multan. S.N.G.P.L. record.
22 11220027263 Farzand Ali R/o Farzand Ali Suit for Muhammad Stay granted 18000/- Arguments
Rewari Sweet Vs permanent Akram Rana (Security)
Chowk S.N.G.P.L. injunction.
Kumharanwala, Mtn.
23 11200030432 R/o Shop behind Dilawar Hussain Suit for Hafiz Stay granted 190854/- Arguments
Yaqboob Town New Vs. declaration Muhammad
central Jail Multan. S.N.G.P.L. Iqbal Kaliyar
Dear Sir/Madam,
Rashid Hassan
It is to confirm that the above named was assaulted by Police
in 1983 and he was struck by hand gun on his head. He was
subsequently detained for about 4 weeks. All this happened because
he was campaigning against the Military Regime for restoration of
Civil Liberties and Democracies.
Thanking you,
Dear Sir,
Mr. Haji Noor Muhammad Khan S/o Haji Muhammad Bakhsh Khan
resident of Al Ata Colony, Street No. 3, Shah Badar Road, Multan, wants a
loan amounting to Rs. 180,000/- from H.B.L. Branch Gulgasht. He has
submitted the following documents for legal opinion: -
Sir,
The plaintiff respectfully submits as under: -
7. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on 2.7.2000 when the
period of the notice dated 17.6.2000 expired and the
defendant failed to repay the above said investment and share
of the Corporation of the plaintiff.
8. That the value for the purpose of court fee and jurisdiction is
Rs. 379,686/- and a court fee of Rs. 15,000/- has been affixed
and paid.
Plaintiff,
Dated: ________
H.B.F.C.
Through: - its District Manager,
Multan.
Through: -
(Muhammad Qasim Khan),
Advocate High Court,
District Courts, Multan.
VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff
IN THE COURT OF JUDGE BANKING COURT, MULTAN.
Respectfully Sheweth: -
1. That plaintiff corporation is a statutory body constituted under
House Building Finance Corporation Act, XVIII, 1952 and is a
Financial Institution as defined in the Financial Institutions
(Recovery of Finances) Ordinance, 2001, presently having its
Head Office at Karachi and District Offices at other places of
Pakistan including one of its office at Multan. The District
Manager, Multan being its District Manager is authorised to
institute the present suit signed, verify pleadings, to do such acts
which are necessary and incidental thereto being conversant with
the facts of the case and is able to depose about the fate.
2. That the plaintiff provides financial facilities on partnership basis
for the construction and purchase of house/building in Pakistan in
terms of Act XVIII, 1952 and Rules & Regulations made
thereunder.
3. That the defendants availed investment of Rs.347,000/- on
24.6.97 from the plaintiff to construct the house on plot No. 260,
Block I, Shah Rukne Alam Colony, Multan, through case file No.
HFS-MTN-9623, Account No. 70604383-75 on the terms and
conditions as set out in Registered Deed of assigned and
Partnership (hereinafter called “Assignment Deed”) executed by
the defendant No. 1 on 24.6.1997 in the office of Sub-Registrar
(Urban), Multan under the provision of H.B.F.C. Act XVIII, 1952
and the Rules and Regulations made thereunder. An attested copy
of Registered Assignment Deed is filed herewith and marked as
Annex “A”. The assigned property is bounded as under: -
North: Plot No. 259
South: Plot No. 261
East: Plots No. 249, 250, 251
West: Road 25’ wide
4. That the defendant No. 2 stood guarantor for defendant No. 1 and
he executed a Guarantor Form duly signed by him, which is also
annexed with the suit. In this way, he is equally liable to pay
outstanding the amount of H.B.F.C./plaintiff.
5. That the defendants had to pay the said investment to the plaintiff
in monthly installments of Rs. 5,342/- per month initially,
regularly and terms of the said Registered Deed of Assignment
and Partnership, but they paid nothing to discharge their liability
inspite of issuance of legal notices by the plaintiff.
8. That the cause of action for this suit finally arises within the
jurisdiction of this Hon’ble Court on when the
period of the notice dated expired and the
defendant failed to repay the above said investment and share of
the Corporation of the plaintiff.
9. That the value for the purpose of court fee and jurisdiction is Rs.
568,157/- and a court fee of Rs. 15,000/- has been affixed and
paid.
Plaintiff,
Dated: ________
H.B.F.C.
Through: - its District Manager,
Multan.
Through: -
(Saeed Hassan Hashmi),
Advocate High Court,
40-Aziz Block,
District Courts, Multan.
VERIFICATION: -
Verified on oath at Multan this _____ day of
__________ 2001 that the contents of the
above plaint are true and correct to the best
of my knowledge and belief and nothing has
been kept concealed.
Plaintiff