Suit For Declaration with Permanent Injunction Against LESCO
Civil Case No:/2020
In Re:
Muhammad Ramzan son of Muhammad Yousaf resident of Mouza Niaz Baig near Chungi Amersidhu Lahore
PLAINTIFF
VERSES
1.Chief Executive, LESCO, Queens Road, Lahore
2.Xen, LESCO, Model Town Extension, Lahore
3.SDO, LESCO, Sub Division Model Town Lahore
4.Revenue Officer, LESCO, Model Town Lahore
DEFENDANTS
SUT FOR DECLARATION WITH PERMANENT INJUNCTION ALONG WITH ALL CONSEQUENTIAL RELIEF
Respectfully Sheweth,
1.That the addresses of the parties are correct for summoning /notices for this Honorable Court.
2.That the facts giving rise to the institution of the present civil suit is that an Electricity meter is installed vide reference No. 213564852 situated at 25-commercial area new garden town Lahore in the name of plaintiff.
3.That the plaintiff is regularly paying the electricity bills throughout and nothing is outstanding against the above said Reference Number/Electricity Metter.
4.That on 24.02.2016, the officials of defendants visited the suit property of the plaintiff and demanded the copies of paid electricity bills, which the plaintiff provided the same, which shows the plaintiff is not defaulter of any dues regarding the above said electricity meter.
5.That in the month of July, 2016 the plaintiff paid the bill of amounting Rs. 13,590/- and there was nothing as arrears against the plaintiff and in the month of August and September, 2016 the plaintiff paid his bill and not even a single penny was pending against the plaintiff are arrears but in the month of October, 2016 the defendant sent the bill of amounting of Rs. 6,890/- along with illegal and unjustified arrears of amounting Rs. 16,787/- and also declare the status of the meter was defaulter when the plaintiff made a strong protest and said that if the meter was defective then why you mistake and they made promise to correct the same and the defendants lingering on the matter from one pretext or the other and finally refused to correct this illegal and unjustified bill and made threat of disconnection of the meter of the plaintiff in case of nonpayment of this illegal and unjustified bill, hence this suit.
6.That the cause of action 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 Electric Supply of the plaintiff which is still continuing.
7.That the plaintiff is residing at Lahore, officials of the defendants and functioning and working at Lahore, cause of action also accrued at Lahore, Electricity Meter 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.
8.That the value of the suit for the purposes of Court Fee and jurisdiction is fixed Rs. 15,920/- 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 bill for the month of October, 2016 along with the arrears of Rs. 24,360/- may kindly be declared illegal and unlawful and the defendants may kindly be ordered do not disconnect the meter / connection installed at the premises of the plaintiff vide reference number mentioned at para No. 2 of the suit till the final decision of the suit and cost the suit may kindly be awarded to the plaintiff.
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