Awais Zia and one another - Versus - Public at Large and others

Last Updated: Tuesday May 01, 2012

IN THE COURT OF MR. FARRUKH HUSSAIN, CIVIL JUDGE, LAHORE

Suit No. _________/2003

In re:

Awais Zia and one another – Versus – Public at Large and others

Suit: For declaration with permanent injunction

WRITTEN STATEMENT ON THE BEHALF OF DEFENDANT NO. 4

Respectfully Sheweth:

1. The contents of paragraph number 1 are denied due to lack of knowledge.

2. The contents of paragraph number 2 are denied due to lack of knowledge.

3. The contents of paragraph number 3 are admitted to the extent of purchase of plot in Quaid-e-Azam Town Housing Society, Janjatay, Rai Wind, Lahore, and remaining part of the said paragraph is denied due to lack of knowledge.

4. The answering defendant number 4 does not deny to make entries in relevant record of the society subject to the Decree of this Honourable Court and remaining part of the paragraph number 4 is denied due to lack of knowledge.

5. Legal therefore needs no reply.

6. The contents of paragraph number 6 are denied due to lack of knowledge.

7. The contents of paragraph number 7 are admitted to be corrected to the extent of cause of action which is legal but remaining part of the said paragraph is denied due to lack of knowledge.

8. Legal therefore does not call for reply.

9. Legal.

It is, therefore, respectively prayed that if the plaintiffs and defendant number 2 are able to prove the facts of the plaint alleged and their respective rights, then the answering defendant number 4 will have no objection to decree the suit subject to payment of necessary fee and dues to give effect the respective rights in relevant record of the society. Answering defendant number 4 also seeks for the payment of cost on account of defence and subsequent proceedings, if any.

		Answering Defendant No. 4
	through	(Muhammad Tariq Munir) Advocate

		(Nasir Nazir Butt) Advocate
		C/o. Tariq Munir Law Associates Chamber No. 5-6, 3^rd Floor, Al-Majeed Centre, Link Fareed Kot Road, 1 – Mozang Road, LAHORE.

Verification: Verified on Oath today this 9^th day of January 2004 at LAHORE. The contents of paragraphs of above written statement from 1 to 6 are correct to the best of my knowledge, information, and belief and remaining paragraphs from 7 to 9 are believed by me to be true and correct on the information received.

Answering Defendant No. 4