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Suit for Declaration Permanent Injunction against Sui Northern Gas

Suit for Declaration Permanent Injunction against Sui Northern Gas

Suit for Declaration Permanent Injunction against Sui Northern Gas
Civil Case No:/2020
In Re:
Rana Muhammad Afzal son of Muhammad Aslam resident of Mouza Tehsil Chand Rai Road Lahore
PLAINTIFF
VERSES
1.Sui Northern Gas Pipeline Limited through its Managing Director, Gas House 21-Kashmir Road, Lahore
2.General Manager, Sui Northern Gas Pipelines Limited, Guru Mangat Road Gulberg III, Lahore
3.Deputy Chief Billing, Sui Northern Gas Pipeline Limited, Guru Mangat Road, Gulbrg III, Lahore
DEFENDANTS
SUT FOR DECLARATION, PERMANENT WITH MANDATORY INJUNCTION ALONG WITH ALL CONSEQUENTIAL RELIEF
Respectfully Sheweth,
1.That the addresses of the parties are correct for summoning /notice for this Honorable Court.
2.That the plaintiff has a domestic Sui Gas connection which is consumer No. 369822450 at Mouza Tahseel Gulberg III, Lahore and the plaintiff was deposited all the bills regularly without any default.
3.That few months before on the instigation of some local political figures just in political revenge the defendants illegal and unlawfully and disconnects the gas supply of the plaintiff and blamed that you were supplying the gas to other homes.
4.That the plaintiff a number of times approached to the staff of the defendants and requested them that he has not committed any type of illegal and unlawful work and has not given gas supply to any one and also made request to reinstall the gas supply but they turned a deaf ear to the lawful and genuine request of the plaintiff and flatly refused and also sent a bill of Rs. 125,000/- illegally and unlawfully.
5.That the cause of action firstly arose when plaintiff received incorrect, illegal and unjustified bills and when requested to the defendants to correct the bill that refused the same without any lawful justification and made threat of disconnecting the Gas Supply of the plaintiff and secondly when they sent the said illegal and unjustified bill illegally and unlawfully.
6.That the plaintiff is residing at Lahore, officials of the defendants and functioning and working at Lahore, cause of action also accrued at Lahore, Gas Supply in question are also installed at the premises of the plaintiff at Lahore, therefore, this Honorable Court has got the jurisdiction to adjudicate upon this matter.
7.That the value of the suit for the purposes of Court Fee and jurisdiction is fixed Rs. 2,000/- which is exempted from the payment of Court Fee under law.
PRAYER
In the view of above submission, it is therefore respectfully prayed that the suit of the plaintiff may kindly be decreed in the favour of the plaintiff against the defendants and the bill amounting of Rs. 125,000/- may kindly be declared illegal, null avoid and the defendants may kindly be ordered to restore the gas supply of the plaintiff and also be directed do not received the said illegal and unjustified bill till the final decision of the instant suit.
Any other relief which this honorable court deems fit may kindly be awarded.
PETITIONER / PLAINTIFF
Through
CH. MUHAMMAD SHAHID BHALLI
Advocate High Court
Mob: 0301-6001125
Chamber No. 3 First Floor Adnan Center,
Model Town Link Road Lahore
Verification
Verified on oath at Lahore on the 31st day of October, 2016 that the contents of paras No. 1 to 5 are correct to the best of my knowledge and those of paras No. 6 to 8 are correct to the best of my information and belief.
PALINTIFF

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