Farhan Khaliq Anwer Advocate; The Lords International [Magazine of Law & Law Fields]

IN THE COURT OF VIth SENIOR  CIVIL JUDGE AT KARACHI SUIT NO.  1255 OF 2015 Shahida Perveen & Ors. …                      ………..    PLAINTIFFS. V E R S U S Asif  & Ors. …………………………              ……..DEFENDANTS PROPOSED ISSUES ON BEHALF OF THE PLAINTIFF 1.             Whether the suit of the plaintiff is maintainable under the law and the plaintiff has just & proper causes of action against the defendants to file the present suit? 2.             Whether the plaintiffs are lawful owners of the property in suit & are entitled to get leased out its rights. 3.             Whether t...

DECLARATION / WAKF FOR PUBLIC PURPOSE / GIFT DEED This Gift Deed / Declaration / Wakf for public purpose is made  at Karachi on this 08 th day of February 2017 BY AND BETWEEN (1) Mr. Umer Farooq S/O Muhammad Ishaq , Muslims, adults, resident of  Hose No: A680, Sector 11-G, Godhra Cooney, New Karachi, Karachi, holder of CNIC No. 42101-1654877-3, (hereinafter referred to as “the Donor / Grantor " which expression shall mean and include his/her legal heirs, legal representatives, executors, administrators and assigns) of the First Part . AND Madrassah Hudal Lil Aalmeen (Registered Under Societies Registration Act Vide registration: KAR NO: 2085 of 2014-2015) through its President / Administrator - Mr. Sajj ad Ahmed S/O Faqeerullah,  Muslims, adults, resident of  House / Plot No: 517, Sector 50-E, Lyari Express Way, Taiser Town, Karachi, holder of CNIC No. 31303-67267536, (hereinafter referred to as “the Donee / Trustee" which expression shall mean and in...

IN THE COURT OF CIVIL & FAMILY JUDGE – KARACHI . Suit No: 000/2000 Mst. S. Bol…………………… PLAINTIFF. VERSUS A. E. Khan. ……………………      DEFENDANT. COUNTER AFFIDAVIT TO APPLICATION U/S 17-A OF FAMILY COURT ORDINANCE. I, A. E. Khan S/O Late Khan, Muslim, adult, presently residing at House No. B, Housing Society, Karachi, do hereby state on oath as under: 1.     That I say that I, belong to a noble and civilized family and I used to earn my livelihoods by doing Private Job / works on daily wages in America /USA. Now just because of attitude of plaintiff, I am encircled in financial and other metromonial problems as and since last 10 months, I could not go to my workplace to earn, therefore I am jobless now. 2.     That I say that I had sufficient means to provide comfort and necessities of life to plaintiff and my son / baby. After the marriage, I / the answering defendant has paid handsome amounts to...

COMMON GROUNDS FOR BAIL APPLICATION 1.          That, applicant/accused is innocent and has falsely implicated in this case by police due to enmity. 2.          That, applicant / accused is ready to furnish surety for the satisfaction of the court.  3.          That, applicant / accused is neither previous convicted nor hardened criminal. 4.          That out of three culprits, none of them is specifically named, as assailant. 5.          That, the accused is no more required for investigation or recovery; the final challan has been submitted. 6.          That, the case of applicant/accused falls under proviso 3-A of S/497(1) Cr.P.C. 7.          That, the applicant / accused has g...