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Permanent Injunction Suit Reply

This document is a written reply on behalf of respondents in response to an application for permanent injunction filed by Ghulam Asghar Bhatti against Shafqat. It raises 3 preliminary objections arguing the applicant has no cause of action, the application is not maintainable, and is based on false averments. It then responds to each paragraph in the application, denying the allegations and arguing the applicant's intent is to wrongly occupy the respondent's plot. It requests the court dismiss the application.

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Kashif Abbas
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116 views2 pages

Permanent Injunction Suit Reply

This document is a written reply on behalf of respondents in response to an application for permanent injunction filed by Ghulam Asghar Bhatti against Shafqat. It raises 3 preliminary objections arguing the applicant has no cause of action, the application is not maintainable, and is based on false averments. It then responds to each paragraph in the application, denying the allegations and arguing the applicant's intent is to wrongly occupy the respondent's plot. It requests the court dismiss the application.

Uploaded by

Kashif Abbas
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as RTF, PDF, TXT or read online on Scribd
  • Written Reply on Behalf of Respondents

IN THE COURT OF Mr.

ASIF HAYAT GONDAL, LEARNED CIVIL


JUDGE, TAXILA

Ghulam Asghar Bhatti Vs. Shafqat etc.

SUIT FOR PERMANENT INJUNCTION

Application Under Order 39 Rule 2 (3) Read With Rule 4 &


Section 94, 151 CPC

WRITTEN REPLY ON BEHALF OF RESPONDENTS

Respectfully submitted:-

PRELIMINARY OBJECTION:

1- That the applicant has no cause of action against the

answering respondents, hence, the application is liable to be

dismissed.

2- That the application is not maintainable in its present

form and situation, hence liable to be dismissed.

3- That first the applicant/plaintiff filed a bogus suit against

the answering respondents and thereafter, filed the instant

application on the basis of false averments, hence the

application merits dismissal.

ON FACTS

1- Para-1 needs no reply.

2- Para-2 relates to record, hence need no reply.

3- Para-3 is correct.

4- Para-4 is not only incorrect but a tissue of falsehood and

no such incident ever took place. In fact, applicant/plaintiff


2

- -
intends to occupy a plot of answering respondents under the

garb of court order and for this purpose, first he filed a bogus

suit against the answering respondents and thereafter, filed

the instant application on the basis of false averments.

5- Para-5 is incorrect and denied. Detail reply has been

given earlier.

6- Para-6 is incorrect and denied. The answering

respondents are law abiding citizens and they have not

violated any court order.

7- Para-7 is incorrect and denied. The answering

respondents can’t think to commit contempt of court by

anyway.

8- Para-8 needs no reply because the answering

respondents have already appeared before this Learned Court.

9- Para-9 is incorrect and denied.

It is, therefore, respectfully prayed that

application may kindly be dismissed.

Respondents

Through

MALIK KHALID SHEHZAD


Advocate High Court

IN THE COURT OF Mr. ASIF HAYAT GONDAL, LEARNED CIVIL JUDGE, TAXILA Ghulam Asghar Bhatti Vs. Shafqat etc. SUIT FOR PERMANENT
- - intends to occupy a plot of answering respondents under the garb of court order and for this purpose, first he filed a b

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