For Immediate Use

On behalf of the Plaintiff

IN THE COURT OF ___________ SENIOR CIVIL JUDGE (_________)

AT KARACHI

Suit No. __________ of 2005

M.A. Muqtadir
Son of Mr. Muhammad Abdul Rasheed
Resident of Flat No. B-205, Farhan Dreamland
Block 16, Gulistan-e-Jouhar
Karachi …….………………………Plaintiff

Versus

Abdul Qayoom Yousuf Akbani

Son of (late) Yousuf M. Akbani
Resident of B-5, Galaxy Skyline Apartments
Street No. 33, Phase V, Extension, DHA
Karachi …………………Defendant

APPLICATION UNDER ORDER 39 RULE 1 & 2 READ WITH

SECTION 151 C.P.C

It is respectfully prayed on behalf of the Plaintiff above named that for the
reasons, amongst others, mentioned in the accompanying affidavit, this
Hon’ble Court may be pleased to make following orders:

1. Injunction, restraining the Defendant to leave the country while the

matter is pending before this Hon’ble Court.

Prayed accordingly in the interest of justice.

Karachi.
Dated: _____________, 2005

________________________________
Advocate for the Applicant/Plaintiff

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 For Immediate Use
On behalf of the Plaintiff

IN THE COURT OF ___________ SENIOR CIVIL JUDGE (_________)

AT KARACHI

Suit No. __________ of 2005

M.A. Muqtadir
Son of Mr. Muhammad Abdul Rasheed
Resident of Flat No. B-205, Farhan Dreamland
Block 16, Gulistan-e-Jouhar
Karachi …….………………………Plaintiff

Versus

Abdul Qayoom Yousuf Akbani

Son of (late) Yousuf M. Akbani
Resident of B-5, Galaxy Skyline Apartments
Street No. 33, Phase V, Extension, DHA
Karachi …………………Defendant

AFFIDAVIT

I, M.A. Muqtadir S/o. Muhammad Abdul Rasheed, muslim, adult, resident of

Karachi, do hereby solemnly affirm and state on oath as follows:-

1. That we are well conversant with the fact of the case.

2. That the accompanying Application under Order 39 Rule 1 & 2 read

with Section 151 CPC has been drafted under our instructions.

3. That the Plaintiff shall be seriously prejudiced and will suffer

irreparable loss in case Application under Order 39 Rule 1 & 2 not
granted.

4. That the contents of the accompanying Application are true and correct
to the best of our knowledge and belief.

5. That the Applicant has a very good prima facie case in its favour.

6. That the balance of convenience and inconvenience also lies in favour

of the Applicant.

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7. That the Applicant will suffer irreparable loss if the accompanying
application is not granted.

8. That whatever stated above is true and correct to the best of our
knowledge and belief.

_______________
DEPONENT

The Deponents are identified by me to the Commissioner for taking Affidavit.

_______________
ADVOCATE

Solemnly affirmed before me at Karachi on this _____ day of

______________ 2005 by the Deponents who is identified by Mr. Agha Shah
Waliullah Advocate, who is known to me personally.

______________________________
Commissioner for taking Affidavits

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