MANAGER,

NATIONAL BANK OF PAKISTAN,

MUMTAZABAD,
MULTAN.

SUBJECT: - LEGAL OPINION OF SUCCESSION

CERTIFICATE UNDER SUCCESSION
ACT IN CASE MST. SALMA BIBI VS.
PUBLIC AT LARGE AND OTHERS.

Dear Sir,
The succession certificate has been issued in favour of
Mst. Salma Bibi, which empowers her to collect/receive the amount of
Rs. 21391.59 along with interest (if any).
According to my scrutiny, the succession certificate issued by
Ch. Muhammad Siddique Senior Civil Judge, is genuine and the
shares of the legal heirs are also correct.

Hence presented for your kind perusal and

further necessary action.
Thanking you.

(SAEED HASSAN HASHMI)

ADVOCATE HIGH COURT
40- AZIZ BLOCK, DISTRICT
COURTS, MULTAN.
BANK LEGAL ADVISOR.
MANAGER,
NATIONAL BANK OF PAKISTAN,
DERA ADDA BRANCH,
MULTAN.

SUBJECT: - Request for the payment of 50% Professional

Fee in Case: M/S Umar Straw Paper Vs. N.B.P.

Dear Sir,
In the above-referred case, leave to defend as well as
written reply to the application for the appointment of Commission
has been submitted on behalf of National Bank of Pakistan. It is
therefore, requested to pay my 50% (Rs. 25,000/-) professional fee in
the above-mentioned case.
Thanking you.

Yours Sincerely,

(SAEED HASSAN HASHMI)

ADVOCATE HIGH COURT,
40-AZIZ BLOCK, DISTRICT
COURTS, MULTAN.
BANK LEGAL ADVISOR.
1.
In the Court of Mr. Muhammad Javed-ul-Hassnan Chishti
Magistrate 1st Class, Multan.
Shabbir Ahmad @ Shiba s/o Ghulam Muhammad caste Mughal
r/o Chak No.271/W.B Tehsil Duniapur, District Lodhran.

(Accused/Petitioner)
Versus

The State. (Respondent)

In case FIR No.137/95 dated 23-3-95

Offence u/s 379/411 P.P.C. Police Station
Cantt, Multan.

Application under Section 249-A Cr.P.C.

for the acquittal of accused/Petitioner.

Respectfully Sheweth:-
1. That the above captioned case is pending adjudication before
this Hon’ble Court and is fixed for 10/6/99 for recording of
prosecution evidence.

2. That brief facts giving rise to the instant application are that the
above captioned case initially was got registered against
unknown person and later on in local police planned a fake case
and subsequently also shown a fake recovery from the accused/
Petitioner.

3. That the accused/Petitioner pray for his acquittal under section

249-A Cr.P.C. inter alia on following
 GROUNDS

a) That the charge against the accused/Petitioner is

groundless.
b) That there is nothing on the record to connect the
accused/Petitioner with the commission of alleged
offence. Moreover, the local police have shown a faked
recovery from the Petitioner and actually nothing had
been recovered from the Petitioner.
c) That the complainant has failed to produce his evidence
before this Hon’ble Court. This factum is also evident on
the face of record that repeated summons of bailable and
non-bailable were issued to the complainant as well as to
the witnesses but non of them appeared before this court.
This aspect of this case shows the insignificance and
negligence on the part of the complainant and inference
can very easily be drawn that he is not willing to
prosecute the accused/Petitioner.
d) That the accused/Petitioner is facing the agonies and
worries of the case for about last 1-1/2 years without any
fault on his part and the case is based on concoction and
falsehood, as such the complainant has abused the process
of the court.
e) That strange enough to say that all the prosecution
witnesses are not only related to each other rather they are
inimical towards the accused/Petitioner and are very
much interested to the complainant party for the
prosecution of the accused/Petitioner in this false case.
f) That the present case is outcome of malafide and ulterior
motives and that the accused/Petitioner has been falsely
implicated in this case on account of enmity. Moreover,
 he is innocent as it has been proved from the evidence
available on record.

Under the above circumstances and

submissions, it is most respectfully prayed that this
application may kindly be accepted and that the accused/
Petitioner may very graciously be acquitted of the charge at
this stage, in the supreme interest of justice.

Humble Accused/Petitioner

(Shabbir Ahmad)

Dated: 08/06/99

Through:
SAEED HASSAN HASHMI
Advocate High Court
40-Aziz Block, District
Courts, Multan.
 In the Court of Mr. Muhammad Naeem Sheikh Civil Judge,
Multan.

In re:-
Ghulam Mustafa Vs. Sui Northern Gas etc.

Suit for Declaration

Written Statement on behalf of the defendants.

Respectfully Sheweth:-
Preliminary objections.
1. That the suit is not maintainable in its present form.

2. That the plaintiff is estoped by his words and conduct.

3. That the plaintiff has no cause of action to bring this suit,

because a gas meter No. MG 24481963 was provided for
domestic purposes but the plaintiff misused it and
resultantly the gas supply was disconnected on 28.2.98
due to misuse of gas for commercial purposes. But later
 on, secretly and illegally, the plaintiff connected his gas
connection directly from the service line (unmetered gas)
through rubber pipe and in this connection the
respondents received a complaint from a member of
Khidmat Committee Multan, on which on 5.4.99 a team
comprising of the following members approached at the
point where the gas was being misused (i) Mr. Naseem-
ud-Din, Member Khidmat Committee (ii) Duty
Magistrate 1st Class Multan. (iii) Sub-Engineer, Sui
Northern Gas Multan and (iv) Representative from daily
Khabrain Multan. So the above mentioned team removed
the rubber pipe and stopped the direct use of gas. As such
a cost of gas Rs.20,098/-, of gas pilfered by the plaintiff
during the period from 1.3.98 to 5.4.99, was
communicated vide letter No. MB:/470.
It is worth mentioning here that on 9.4.99,
the plaintiff himself submitted an affidavit through which
he admitted that he is resident of Basti Bawa Safra,
outside Daulat Gate, Multan and that he had been using
gas in his shop for commercial purposes. He also
promised that he would be careful in future. In the above
mentioned affidavit, the plaintiff also requested that his
gas meter may be reinstalled after receipt of dues. Copy
of affidavit is attached herewith. As such the plaintiff, by
misusing the domestic gas for commercial purposes and
of stealing the gas directly through rubber pipe, has
violated the terms and conditions of the contract signed
by the plaintiff.
4. That the plaintiff has not come in court with clean hands
because above mentioned consumer is a defaulter of
 Rs.20,098.75 which includes the cost of gas pilfered and
Government’s Central Excise Duty, as such has brought
this suit only with the object to digest the above
mentioned due amount.

5. That the suit of the plaintiff is not sustainable and is liable

to be rejected under order 7 rule(11) of C.P.C. because of
having no cause of action in the matter.

6. That the above captioned suit is liable to be dismissed

with special costs u/s 35-A of C.P.C.

Statement on Facts:-
1. That Para No.1 of the suit is absolutely incorrect, the
house was never found locked and a family was
continuously residing in the said premises/house.

2. That para No.2 of the suit is incorrect, the defendants had

no litigation with the plaintiff in past.

3. That para No. 3 of the suit is incorrect, detail reply about

arrears has been given in preliminary objections of
Written Statement, moreover gas supply was disconnected
due to misuse of domestic gas for commercial purposes.

4. That para No. 4 of the suit is absolutely incorrect, detail

reply has been given in preliminary objections.
5. That para No. 5 of the suit is also absolutely incorrect and
is not admitted as such.

6. That para No. 6 of the suit is incorrect, the plaintiff

himself submitted affidavit, moreover regarding raid
detailed reply has been given in preliminary objections.

7. That para No. 7 of the suit is incorrect and is not admitted.

8. That para No. 8 of the suit is incorrect, the plaintiff has no

cause of action.

9. That para No. 9 of the suit is formal.

10.That para No. 10 of the suit is legal.

Prayer of the suit is absolutely incorrect, based on

malafide and ulterior motive therefore is liable to be
dismissed with special costs and plaintiff may graciously
be ordered to pay the cost of gas pilfered by the plaintiff
as admitted by him in the attached affidavit.

Humble Defendants.

Through:-
Dated:- 22/06/99

Through:-
SAEED HASSAN HASHMI
Advocate High Court,
Seat No. 40-Aziz Block,
District Courts, Multan.

Verification:-
It is verified that the contents of
the Written Statement are correct and true to
the best of my knowledge and belief.

Humble defendants.

Through:
 DEED OF RECONVEYANCE L-15A

HFSMTN-6873
ACCOUNT NO. 70601887-07

This INDENTURE made this _______day of March 2000 BETWEEN House Building
Finance Corporation having its Head Office at F & T Centre, Karachi (hereinafter called
the Corporation) of the one part and Mr. Syed Kazim Ali Shah s/o Syed Habib Shah
residing at H. No. 1007 Rehman Colony Khanewal Road, Multan hereinafter called
Partner of the other part.

WHEREAS PARTNER availed of an investment of Rs. 100,000/- (Rupees One lac only)
from the Corporation for the construction/purchase of the hose on Khasra No. 1487 and
assigned the above said property in favour of the Corporation through a deed of
Assignment and partnership registered in the office of District/Sub-Registrar on 3.3.90 at
Multan in Book No. I Vol, No. 755 pages 269 to as No. 2692 hereinafter called the
PRINICIPAL INDENTURE.

NOW THIS INDENTURE WITNESSETH that in pursuance of the said agreement and in
consideration of one premises the corporation doth heirs, executors, administrators and
assigns ALL THAT piece of land bearing Khasra No. 1487 Khewat No. 953-880
Khatooni No. 1348 consisting of 5 marlas situated in Mauza Taraf Juma Khalsa in the
jurisdiction of New Multan Police Station Taluka Sub District Multan more or less
bounded on the North by House of Atta Ullah on the South by Street 12” wide on the
East by Street 12” wide on the West by Plot of M. Bashir together with the dwelling
house, or houses, stables, cook rooms and out building thereon AND ALL and singular
other premises in the PRINCIPAL INDENTURE comprises or expressed to be hereby
assured or which nowhere by any means vested in the Assignment and subject to
redemption/Release/ Relinquish under or by virtue f the PRINCIPAL INDENTURE
expressed.
AND ALL THE estates, right, title interest, property claim and demand whatsoever of the
corporation into out of an or upon the same premises heretofore expressed to use
HEREBY reconveyed, granted, released, relinquished not in favour of and to the use of
the PARTNER his/her heirs, executors, administrators and assign forever fraud and all
discharged from all partnership money intended to be secured by the PRINCIPAL
INDENTURE and from all action, suits, accounts, claims and demands for or in respect
of the said money partnership or any part thereof or for, in respect the PRINCIPAL
INDENTURE or of anything relating to the premises AND THE CORPORATION
hereby covered with the partners to the premises AND THE CORPORATION hereby
covered with the partners his/her heirs, executors, administrators and assigns that the
Corporation has not done or knowingly suffered on any part thereof are, in or can be
impeached encumbered or affected in titled estate or other howsoever.
IN WITNESS WHEREOF the parties hereto have hereunto their hand seals the
day and year first above written.

FOR AND ON BEHALF OF THE MANAGER

HOUSE BUILDING FINANCE CORPORATION MUTLAN.
WITNESS. 1___________
2____________ PARTNER

Mst. Mussarat Parween w/o Kazim Ali Shah