IN THE COURT OF Sr.

CIVIL JUDGE KARACHI

(SOUTH)
Suit No……….

MUHAMMAD SAAD
R/o _________________________ ………………                      
Plaintiff

Versus

SM LAW COLLEGE
Ziauddin Road near I.I Chundrigur Road Karachi (South)

…………….                 Defendant

SUIT FOR RECOVERY OF RS 8,00,000/-(eight

lac rupees only)

Respectfully sheweth,

That the plaintiff was entered into a agreement with the

defendant to sell a painting. The plaintiff and defendant both
are agreed upon terms and conditions which are as follow:

1. That the plaintiff and defendant had made a sell agreement in

this agreement the plaintiff sold out his painting to the
defendant and defendant agreed to buy the same.
2. That on dated 08-10-2022 the agreement was executed.
(copy of Agreement is annexed as annexure
A)
3. That in this agreement the amount of payment was decided RS.
10,00,000/-(ten lac rupees only) which was to be paid by
defendant to the plaintiff against painting.
4. That the defendant was paid Rs. 2,00,000/-(two lac rupees only)
as an earnest money on the same day.
5. That the possession was handed over to the defendant on the
same day.
6. That the remaining balance was to be paid after 30 days of
agreement.
7. That after the lapse of time, when the plaintiff contacted to
defendant and requested him to pay remaining amount then
the defendant didn’t give positive response.
 8. That thereafter the plaintiff was continuously approaching the
defendant and demanding his remaining amount but
defendant was misleading the plaintiff.
9. That after two month ago the plaintiff demanded his money, in
rebuttal of, the defendant had threatened the plaintiff and said
“I am not fulfilling my part and also said that you can do
whatever you want and I don’t have any fear about any
consequences.
10. That in view of the aggressive behavior of defendant I
sent a legal notice on dated 10-12-2022 which was received by
defendant but the defendant did not reply thereon till now.
(copy of legal notice is annexed as annexure
B)
11. That the cause of action accrued firstly, on when the
defendant did not fulfill his part after completion of given time
period as per agreement and secondly, after completion of time the
plaintiff kept on approaching the defendant for the fulfillment of
consider amount but the defendant used delaying tactics and
threatening by various ways such as, he threatened me to imperil my
work place as well as my other private properties and thirdly, when
the defendant didn’t reply to my legal notice Dated 10-12-2022,
which is still continuing.
12. That the cause of action accrued within territorial jurisdiction
of this Honourable Court, suit property is also situated within the
territorial jurisdiction of this Honourable court, hence this
Honourable court has jurisdiction to adjudicate upon the matter.
13. That the prescribed court fee has been affixed on the plaint.

Prayer:
It is therefore respectfully prayed that a decree to the following
effects may kindly be passed in favor of plaintiff and against the
defendant with costs.

a. This hon’ble court may be pleased to pass a judgement and

decree for recover remaining amount sum of Rs. 8,00,000/-
(eight lac rupees only) in favor of plaintiff.
b. Any other relief if the court deem fit may award in favor of
plaintiff.

Plaintiff Through Counsel

VERIFICATION

Mr. Muhammad Saad S/o Shahzad Ahmed, Muslim, Adult R/o

____________________________________________________________________
____________________________________________________, The plaintiff
above matter do here by solemnly affirm and verify on oath
that the content of all of above paras are true and correct to the
best of my knowledge and belief.

Karachi Deponent
Dated;______________

Identified by me

Advocate

Sworn before me on oath at karachi by the deponent

abovenamed who is identified to me by
__________________________, advocate, who is known to me
personally.

Commission for taking affidavit