IN THE COURT OF SENIOR CIVIL JUDGE HALA

F.C SUIT NO. OF 2017

Mst.Seema

D/O Sajan

Adult, Muslim B/C Sheedi

R/O Muhallah Ghareeb abad Colony

Taluka Saeedabad District Matyari ……………… PLAINTIFF

VERSUS
1. FEDERATION OF PAKISTAN
Through Secretary Ministry of Interior Islamabad
2. CHAIRMAN NADRA ISLAMABAD
3. INCHARGE OFFICE NADRA
Taluka hala……………………………………………………………… DEFENDANT

SUIT FOR CORRECTION AND MANDATORY INJUCTION.

The plaintiff respectfully begs to submit as under:-

1. That, the Plaintiff is a law abiding citizen of Pakistan having been
endowed with certain fundamental rights as envisaged under the
constitution of Islamic republic Of Pakistan 1973 and serving as
CHOWKEDAR in Government Boys Primary School village Ghulam
Muhammad Manheja .
2. That, the Plaintiff’s actual Date Of Birth is 01-02-1977 and also
mentioned in education record as in primary school certificate as well as
 service book (Photo copy of Primary certificate and service book is
annexed herewith as annexure “ ” )
3. That, in the year 1984 district registrar team came a villege Ghulam
Muhammad manheja where Plaintiff applied for MNIC without knowing
the consequences and that time due to lack of knowledge and was
unaware regarding the Rules and regulations of registrar department as
well as Law of State. I furnished my information to authority and with
bona fide mistake I disclosed my date of birth as 03-05-1965 instead of
1964 authority without verification of my documents in respect of my
age issued my MNIC showing date of issue bearing MNIC
NO.45389025116 to Plaintiff.
4. That, the Plaintiff on basis of MNIC in the year 2003 applied for CNIC and
furnish information/biodata to nadra authority and nadra without
verification of his document in respect of my age and with bonafide
mistake issued my CNIC showing date of issuing 14-04-2003, and
expiration date 31-03-2015 bearing CNIC number 41301-7758818-9 to
plaintiff as showing date of birth 1965 instead of 3-5-1964.
5. That, the plaintiff unfortunately and mistakenly and did not notice at the
time of receiving CNIC and it is also mistake of plaintiff that he remained
fully unaware about such blunder.
6. That, the plaintiff CNIC expired on 31-3-2015 and he approached to the
office of defendant no: 3 in the month of 12-1-2013 for the renewal of
his CNIC………………………………………….
7. That, the plaintiff again approached to the nadra office for the necessary
correction in computerized national identity card regarding date of birth
where defendant no:3 firstly kept the plaintiff on hollow hopes and
finally in the month of…………………………. Advised him to seek remedy
through competent court of law for judgment and decree of declaration,
correction in date of birth.
8. ……………………………………………………
9. That, the plaintiff is residing within the jurisdiction of this honorable
court hence this honorable court has got the jurisdiction to try and
adjudicate upon the matter.
10.That, for the purpose of court fee, the suit is valued for declaration at
Rs, 1000/= there is no need to pay the court fees.
PRAYER
That, plaintiff submit following judgment and decree against the
defendants in favor of plaintiff,
A, that, this honorable court may be pleased to declare and
correct/rectify date of birth as 3-5-1964 of plaintiff instead of 1965, in
CNIC NO: 41301-7758818-9.
B, that, this honorable court may be pleased to direct the defendant
no:3 to issue fresh computerized national identity card to plaintiff which
necessary correction in date of birth as 3-5-1964 of plaintiff instead of
1965 in CNIC NO: 41301-7758818-9.
a. Any other relief which this honorable court deems fit and proper may
please to award to the plaintiff.

Hala
Dated: plaintiff
Advocate for plaintiff
Verification
I, misri unnar s/o Muhammad Ibrahim unar ,
adult, muslim,r/o village ghulam Muhammad
manahi taluka saeedabad, dist;matiari, do hereby
verify on oath that whatever stated above is true,
correct and best of my knowledge.
Hala
Dated: deponent
I know the deponent above named
Advocate.
 The deponent above named is identified by
mr,NAVEED AHMED ADVOCATE, who is personally
known to me.

Commissioner for taking affidavit

Document filled
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Documents relied upon

Any document filled relevant
ADDRESS OF THE PARTIES
Same as shown in cause of title
 IN THE COURT OF SENIOR CIVIL JUDGE HALA
F.C SUIT NO. OF 2017

MISRI UNNAR

S/O Muhammad Ibraheem

Adult, Muslim B/C Unnar

R/O villege Ghulam Muhammad Mnheja

Taluka Saeedabad District Matyari ……………… PLAINTIFF

VERSUS
1. FEDERATION OF PAKISTAN
Through Secretary Ministry of Interior Islamabad
2. CHAIRMAN NADRA ISLAMABAD
3. INCHARGE OFFICE NADRA
Taluka hala……………………………………………………………… DEFENDANT

LIST OF LEGAL HIERS UNDER ORDER 7 RULE 26 OF CPC

Hala
Dated: advocate for plaintiff