IN THE COURT OF SENIOR CIVIL JUDGE CHAMAN

Civil suit No.___________/2023

Bibi Raqima W/o Dad Muhammad

By caste Achakzai
Permanent resident of Mohalla Haji Rashid Killi Muhammad Hassan
Takedar Chaman.
Plaintiff

VERSUS

Director General NADRA Services, Balochistan

Quetta viz Incharge NADRA Officer (NRC) Chaman

Defendant

SUIT FOR DECLARATION CORRECTION OF DATE OF

BIRTH IN CNIC OF PLAINTIFF’S

The plaintiff respectfully sheweth:-

1. For services of summons/notices, the addresses of the parties are given
in the title of the suit.
2. Brief facts leading to resume instant suit against the NADRA
administration are that plaintiff’s has been assigned CNIC with number
54201-2375750-6 therein mentioning incorrect date of birth as 1973,
instead of correct and actual date of birth 01-07-1964. Likewise, the
eldest son of plaintiff namely Nazar Jan has been assigned a CNIC
with number 54201-3242811-1 mentioning date of birth as 21-03-1980
with slight difference of age day-21, month-03 and year-07 with
plaintiff/mother. It is explicit to expend here the facts that mentioning
similar date of birth of a mother with her son is actually comes in the
domain of unnatural age difference. This error has been made on part of
NADRA administration ab-initio, and the same has caused the renewal
of Nazar Jan into re-verification category since 31-07-2010 and
unnatural age difference between plaintiff and her eldest son Nazar Jan
has been blocked by NADRA of having 07 years difference in age
between Nazar Jan and plaintiff. Nazar Jan has time and again
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approached to NADRA Revocation Committee to restore his CNIC but

all in vain due to date of birth of plaintiff as 1973.
3. That it is most important to mention here that the actual date of birth of
plaintiff’s is somewhat 01-07-1964 instead of 1973 as mentioned in her
CNIC, Similarly spouse/husband of plaintiff’s namely Dad Muhammad
S/o Haji Kurang having CNIC No.54201-2466355-7 mentioning date
of birth 1961 (hereinafter referred to husband of plaintiff’s), Dad
Muhammad was 03 years older than her wife Bibi Raqima. If the date
of birth of plaintiff’s remained as 1973, there comes unnatural
difference in the age of mother’s with her sons and daughters
mentioned below accordingly.
 Dad Muhammad (54201-2466355-7) DoB (1961)
 Bibi Raqima (54201-2375750-6) DoB (1973)
 Nazar Jan (54201-3242811-1) DoB (21-03-1980)
 Fazal Muhammad (54201-9850621-7) DoB (01-01-1990)
 Khair Muhammad (54201-1909641-5) DoB (01-01-1998)
4. That as a matter of fact, plaintiff recently on renewal of her CNIC
applied to NADRA Office Chaman on 24-10-2022, after interviewing
and receiving Token Form, her application has been sent to re-
verification thereto unnatural age difference between plaintiff and
eldest son Nazar Jan having date of birth 1980.
5. That as question arise regarding unnatural age difference between
plaintiff and her son Nazar Jan, the plaintiff on the same occasion
requested NADRA staff to rectify her date of birth as 01-07-1964, and
she also disclosed that the date of birth which is mentioned in the CNIC
comes in the domain of unnatural age difference with son Nazar Jan
and daughters as mentioned in Para Supra, but NADRA administration
straight forward refused to do needful and directed plaintiff to approach
before the competent court of law to redress grievances. Hence this
suit.
6. That cause of action accrued to plaintiff against the NADRA authority
when NADRA assigned CNIC to plaintiff’s mentioning incorrect date
of birth as 1973 whereas all the son of plaintiff’s are having date of
births in their CNICs which comes in the domain of unnatural age
difference. It then accrued when plaintiff on renewal of her CNIC was
stopped by NADRA administration due to unnatural age difference
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between plaintiff, plaintiff’s descendants and plaintiff requested

NADRA staff on the same occasion to rectify her date of birth as 01-
07-1964 but was refused to do needful. It lastly accrued when plaintiff
again applied to NADRA office for same reasonable issues and praying
them to do needful which they straightforward refused to do needful
and directed to approach court of law. Hence cause of action still
subsists in favour of plaintiff.
7. That plaintiff and office of NADRA both are situated within the
territorial jurisdiction of this hon’ble court and the case in hand is
prima facie based on factual grounds and the same may kindly be
decreed in favour of plaintiff as well.
It is therefore respectfully prayed in view of the above facts and
circumstances, the suit in hand may kindly be decreed in favour of
plaintiff against the NADRA to the following effects:-
A. Declaring that date of birth of plaintiff has been mentioned wrongly
in her CNIC.
B. Declaring that actual date of birth of plaintiff is 01-07-1964 instead
of 1973.
C. Declaring that date of birth of plaintiff is actually causing unnatural
age difference between plaintiffs’ and her son Nazar Jan
accordingly.
D. Declaring that if date of birth of plaintiff remained as 1973, it comes
in the domain of unnatural age difference and NADRA authority is
quite competent to do needful which they are badly failed to do so.
E. Directing NADRA administration to rectify date of birth of plaintiff
to 01-07-1964.
F. Any other relief which deem fit and proper within the circumstances
may also be awarded to plaintiff in the interest of justice and equity.

Dated:____ August, 2023 Plaintiff

Through Attorney

VERIFICATION
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Verified on oath at Chaman on this day of August 2023 that

the contents of plaint are true and correct to the best of knowledge and belief.

DEPONENT

DOCUMENT RELIED UPON

1. Copy of CNIC of Plaintiff

2. Copy of MNIC Of Plaintiff
3. Copy of CNIC of Plaintiff’s husband.
4. Coy of MNIC of Plaintiff’s husband.
5. Coy of CNIC of Plaintiff’s son Nazar Jan.
6. Coy of CNIC of Plaintiff’s son Fazal Muhammad.
7. Coy of CNIC of Plaintiff’s son Khair Muhammad.
8. Any other documents which deem fit may also be produced during
pendency of the instant suit.

Dated:____August,2023. Plaintiff
Through Attorney