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    In The Court of Honorable D

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    Iftikhar Ali
    The respondent, Muhammad Rafique, has submitted a written reply in response to an application filed by the petitioner, Shahid Hussain. The respondent argues that [1] the petitioner's application is false, frivolous and fabricated, [2] the petitioner has concealed material facts and failed to mention a previously dismissed transfer application, and [3] the petitioner intends to indirectly achieve illegal objectives that he could not achieve directly. The respondent also notes that [4] possession of the suit property is with the respondent, while the petitioner allegedly transferred ownership to evade the respondent, and [5] the three civil suits have different subject matters.

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    In The Court of Honorable D

    Uploaded by

    Iftikhar Ali
    13 views2 pages
    The respondent, Muhammad Rafique, has submitted a written reply in response to an application filed by the petitioner, Shahid Hussain. The respondent argues that [1] the petitioner's application is false, frivolous and fabricated, [2] the petitioner has concealed material facts and failed to mention a previously dismissed transfer application, and [3] the petitioner intends to indirectly achieve illegal objectives that he could not achieve directly. The respondent also notes that [4] possession of the suit property is with the respondent, while the petitioner allegedly transferred ownership to evade the respondent, and [5] the three civil suits have different subject matters.

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    IN THE COURT OF HONORABLE D

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    The respondent, Muhammad Rafique, has submitted a written reply in response to an application filed by the petitioner, Shahid Hussain. The respondent argues that [1] the petitioner's application is false, frivolous and fabricated, [2] the petitioner has concealed material facts and failed to mention a previously dismissed transfer application, and [3] the petitioner intends to indirectly achieve illegal objectives that he could not achieve directly. The respondent also notes that [4] possession of the suit property is with the respondent, while the petitioner allegedly transferred ownership to evade the respondent, and [5] the three civil suits have different subject matters.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
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    Download as docx, pdf, or txt
    13 views2 pages

    In The Court of Honorable D

    Uploaded by

    Iftikhar Ali
    The respondent, Muhammad Rafique, has submitted a written reply in response to an application filed by the petitioner, Shahid Hussain. The respondent argues that [1] the petitioner's application is false, frivolous and fabricated, [2] the petitioner has concealed material facts and failed to mention a previously dismissed transfer application, and [3] the petitioner intends to indirectly achieve illegal objectives that he could not achieve directly. The respondent also notes that [4] possession of the suit property is with the respondent, while the petitioner allegedly transferred ownership to evade the respondent, and [5] the three civil suits have different subject matters.

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    © All Rights Reserved
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    of 2

    IN THE COURT OF HONORABLE D&SJ PAKPATAN.

    Shahid Hussain Vs. Muhammad Rafique

    Subject: WRITTEN REPLY OF RESPONDENT / MUHAMMAD


    RAFIQUE REGARDING APPLICATION OF PETITIONER/ SHAHID
    HUSSAIN.

    Respectfully Sheweth:

    1- That the petitioner has filed the subject false, frivolous & fabricated
    based on distorted facts just to linger on the proceedings of the trial
    court(s).
    2- That the petitioner has concealed the material fact of the case & did
    not mention, intentionally & deliberately, his previously dismissed
    transfer application vide order dated 25-01-2023.
    3- That the petitioner intends to get his illegal objects indirectly, which,
    otherwise could not get directly by filing his previous transfer
    application.
    4- That, in 02 civil cases pending before worthy Mamoona Lashari Sb
    CJ Arifwala, possession over suit property is of respondent/
    Muhammad Rafique, while, petitioner had allegedly transferred the
    ownership to his wife i.e. Kousar Ilyas in order to deprive the
    respondent from legal /actual ownership etc. Application U/O 1 Rule
    10 of CPC, to implead her as necessary / proper party, is pending for
    arguments for 21-02-2023.
    5- That the parties & subject matter of the subject 03 civil suits are
    quite different.

    Sr. Name of Suit Mutation Defendants Cause of


    Action
    Court
    No No (Finally
    arose)
    1 Suit for Declaration 1527 1-Shahid 15-11-2021 Worthy Mamoona
    & Permanent Hussain Lashari Sb CJ
    injunction 2-Kousar Ilyas
    ( Proposed)
    2 Suit for Declaration 2405 & 2406 1-Shahid 15-11-2021 Worthy Mamoona
    & Permanent Hussain Lashari Sb CJ
    injunction 2-Kousar Ilyas
    ( Proposed)
    3 Suit for Declaration 1662, 1766, 1-Shahid 09-05-2022 Worthy Muhammad
    & Permanent 1785 Hussain Awais Sb CJ
    injunction 2- Asif Naz
    That the Worthy Muhammad Awais Sb CJ
    Arifwala, vide para-4 of his order dated 13-09-2022, has declared /
    held that the subject matter of the 02 suits pending before Worthy
    Mamoona Lashari CJ Arifwala is quite different from the suit pending
    before him. Petitioner assailed the said findings of the Court before
    Honorable Tariq Mahmood Rana Sb ADJ Arifwala through Civil
    Revision No.08/2022 which was dismissed by the Honorable
    Revisional Court Arifwala on merit vide order dated 12-11-2022 by
    holding that the findings of the trial court dated 13-09-2022 were apt
    to the facts & circumstances of the case. Therefore, now, the
    petitioner cannot get alter/ change the findings of the trial court as
    well as the Revisional Court regarding the 03 suits having different
    subject matter in the plea of subject consolidation/ transfer
    application.

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