BEFORE THE COURT OF DISTRICT AND SESSION JUDGE,

RAWALPINDI

1. CHOUDARY SHAHID HUSSAIN s/o Choudhary Haq Nawaz

2. MST HAMEEDA BEGUM w/o Choudary Shahid Hussain
3. CHOUDARY KHURRAM SHAHID s/o Choudary Shahid Hussain,
All resident of House No. NYA, Street No. 11-B, Mohallah Shah Jeewan Colony,
Girja Road, Rawalpindi 0300-7557559
PLAINTIFFS

VERSUS
1. MST. RUBIA NAZ d/o Muhammad Younis
2. MUHAMMAD YOUNIS s/o Musharaf Din
3. MST TALAAWAT JABEEN w/o Muhammad Younis
4. MUHAMMAD MOHSIN s/o Muhammad Younis
5. MUHAMMAD AHSAN s/o Muhammad Younis
6. MUHAMMAD NAWAZ s/o Sufi Zaman (c/o Muhammad Younis)
All resident of House no. B-III 782, Hajweri street, Khurram Colony, Muslim
Town Rawalpindi 03057557559, 03339206461, 031550540683
DEFENDANTS
SUIT FOR THE RECOVERY OF DAMAGES OF RS. 100,000,000/-
RUPEES ONE HUNDRED MILLION

Respectfully Sheweth:

The ephemeral facts leading to the instant Suit are:

1. That the Plaintiffs are law-abiding citizen having good moral character and
aware to their rights and duties as defined by Allah Almighty. Plaintiff no 1
is well educated person and served about 40 years in General Headquarter
and earned good reputation throughout service and retired in 2016 and now
manage a General Store. Plaintiff no 2 is a housewife, whereas Plaintiff no 3
is ex-CSP PAS Probationary (CTP 41), well-known personality among state
administrator and served in Military College Murree on prestige position.
Due to healthiness of old age parents and being elder among siblings opted
to serve at home station and joined Inter Services Organisation in Rwp since
2019, thru career accomplished kudos from higher authority.

2. That the Plaintiff no 3 got married with defendant no 1, who later on found
disobedient lady and belongs to Cheater, Blackmailer, dishonest and
fraudulent family.

3. That, Defendant no 1 is serving as teacher in F. G. School for girls, Chongi

no 22, Choudhry Iqbal Road (2nd Shift) Rawalpindi and on 08 Nov 2023,
Wednesday pursue consent that she will visit her parents’ home after
attending school and spend Iqbal Day holiday (i.e. 09 Nov 2023) and
consecutive weekend and pledge to return after duty hours at 1800 hrs on 13
Nov 2023 later snubbed to coming back.

4. That Plaintiff no 3, filed suit for conjugal rights in the court of Family Judge
Rawalpindi on 16 Nov 2023 after processing of court summon to defendant
no 1 for appearance before the court, in opposing she concocted assertions
against plaintiffs and addressed a complaint to PS Dhamial on 17th Nov 2023
for registration of FIR against plaintiffs.

5. That far ahead an application vides eTag No 10298 dated 20 Nov 2023 to
CPO Rawalpindi to lodge FIR against plaintiffs in which defendant no 1
alleged that my husband (Plaintiff no 3) with the assistance of Plaintiff no 1
 and 2, called on Afghan nationals for assassins on hire on 02 Nov 2023
midnight which were entirely founded on surmises.

6. That it was important to mention here that defendants refused to register any
FIR also for enquiry against said Afghan nationals just sought criminal
proceedings against plaintiffs which creates doubts, henceforth Investigating
Officer Sub Inspector Shakeel Aftab PS Dhamial extend the parameter of
investigation and found that defendant no 6 solemnized marriage of Mst
Saba (divorced niece) with a wealthy Old-man in Sep 2023. Defendant no 3
was aggravated with him, of the reason he did not match such a wealthy
person for her daughter (Defendant no 1). Defendant no 6 wonted to arrange
wealthy spouses habitually his seniors’ colleagues of old-ages for divorced
ladies to gain service benefits such turns are usually identified as “Brokers”
in our social order. Therefore, defendant no 6 pledged that he may arrange a
wealthy partner for defendant no 1 but she is married, hence defendant no 3
to fulfil her craving twitch forcing plaintiff no 3 to divorce defendant no 1
beside the fact having a child Ch. Muhammad Zohaib and also pregnant with
twins with maternity in March 2024 and on disappointment said Afghan
nationals were hired by defendant no 3 and 4 for assassination of plaintiff
no 3.

7. That plaintiffs got astonished that defendant no 1 annexed a self-created

enquiry report with application to CPO and claimed that enquiry report by
SSP was shared via WhatsApp to Defendants and others on 17th Nov 2023
but providentially on 16th Nov 2023 plaintiff already filed a suit for
conjugal rights against defendant in which stated all facts and also grievance
marked to Director Cyber Crime Wing, CCW (FIA) through Prime Minister
vide code 91141404 about misusing of Plaintiffs’ no 3, WhatsApp
https://wa.me/03007557559.

8. That, Defendant no 1 and her compeer Defendant 2 to 6, once more

approached to CPO Rwp vide complaint eTag no. 10967 date 12 Dec 2023
for investigation from higher authorities and complaint was assigned to ASP
Zainab Ayub then SDPO Saddar Rawalpindi, and complaint was dismissed
with comments that after witnessing CCTV recording about attending school
on 6th, 7th and 8th Nov 2023 from Plaintiff no 3 home to School as per
 normal routine beside it attendance record of said dates from FGEI Regional
Office Rwp which confirmed that whole drama is staged to deprive Plaintiff
no 1 from his son Choudary Muhammad Zohaib and to Blackmail and
alternate motives.

9. That on struggles of Choudary Tariq (Honest and Noble Man) alongside the
plaintiffs’ energies for compromise on 7th Jan 2024, birthday of Minor was
celebrated and both parties along were in a comfortable environment. Body
gesture of defendant no 1, clearly identify that she was much comfortable
with plaintiff no 3 there is no fear of any kind. and all ingredients of
defendant’s complaint comes doubtful and whole drama was just to enforce
him to divorce defendant no 1.

10. That, entirely assertion leveled were concocted and impelled by defendants
just to blackmail and usurp money from plaintiff no 3 and to pressurize him
to divorce defendant no 1 to achieve their wishes mentioned in supra paras.
An Persian phrase “‫ ”من ترا حاجی بگویم تو مرا مال بگو‬may deem fit on
collaboration of defendants to blackmail, harass, slander, libel and to defame
plaintiffs as defendants are professional Blackmailers, Cheaters, Fraudulent,
greedy and criminal mindset. Plaintiff no 1 got dumbfounded when
Defendants to blackmail and harass necessitated to increase deferred dower
to Rupees Fifty Lacs and demanding money, defendant no 4 & 5 also
threaten to plaintiff no 3 that if said demands will not putative. they will
abort the pregnancy of defendant no 1 as she was pregnant with Twins and if
reported to Police also deprive from minor Muhammad Zohaib.

11. That defendant no 5 called Plaintiff no 3 as “Kafir” in the presence of

Usman and Asif Shah. Such word regarding a Muslim be proclaimed are
strictly prohibited in Islam as a Hadith of Muhammad P.B.U.H, narrated as.
‫)جو شخص کسی دوسرے کو فسق کا طعنہ دے یا کافر کہے اور وہ کافر نہ ہو تو اس کا‬
(‫فسق اور کفر کہنے والے پر لوٹتا ہے۔‬

This act clearly reflects that defendants fearlessness cross any limit to fulfil
their desire and to chagrin plaintiff no 3 to divorce defendant no 1.
12. That on 09th Jan 2024, it came into facts that on 3th Jan 2024, defendant
just to coerce plaintiffs to achieve her illicit demands and wishes filed a
petition u/s 22 - A, Cr.P.C for register of Criminal Case against Plaintiffs.

13. That plaintiff no 3 asked to Defendant no 1 “Why you filed said petition u/s
22-A? she replied that said petition was signed prior to negotiation and now
filed by defendant no 4 (Muhammad Mohsin) and will be withdrawn, if
plaintiff no 3 agreed to increase deferred dower Rs. 50,00,000/- as which
was not suitable.

14. That on 27th Jan 2024, Defendants one again threatened to plaintiff no 3 to
accept for increase of dower deferred up to Rs. 50,00,000/- otherwise
criminal proceeding will be initiated against plaintiffs which was rejected by
plaintiff no 3 and opted to defend said petition with grace and dignity.

15. That on 12 Feb 2024, Petition u/s 22A was DISMISSED by Hon’ble
Muhammad Safdar, ASJ/ Ex- officio Justice of Peace, Rwp with observation
that
“…….. keeping in view the factum of pendency of family
litigation between the parties coupled with the fact that the police in
its report negated the alleged occurrence and the Plaintiff has not
sought registration of criminal case against said Afghan national,
the possibility of converting family dispute into criminal one cannot
be ruled out.” (Attested True Copy Attached)

16. That after dismissal of Petition u/s 22-A, defendants started to defame
Plaintiffs in sphere of Society specially among family, relatives and at work
place. Defendant no 1 narrated the concoct allegation to Maj Tahemina
Kausar and also to in-laws of Mr. Choudary Bilal Shahid (Real son of
Plaintiff 1 and 2) via telephonic calls, alongside its defendant no. 6 on
instigation of defendants hired personal to harass Plaintiff no 3 who
shadowed him.

17. That defendant no. 6 on instigation of defendants visited office of Plaintiff

no 3 in last week of Feb 2024, and narrated concoct allegation to Staff
Muhammad Dewan, Khadim Hussain and Sharjeel, which were already
 found baseless by Police and Courts of Law, instant act was just to defame,
damage reputation and to vexation Plaintiff no 3 to divorce defendant no 1.

18. That Defendant no 5 created a Facebook page by using picture of an Indian

Radio Journalist Sameya (www.facebook.com/MirchiSayema) and
propagated that Plaintiff no 3 has extra matrimonial affairs with a lady.
These concocted slanders against Plaintiff no 3 about “hiring of Afghan
nations and having extra matrimonial affairs with Indian RJ Sameya” are
totally false and baseless. Defendants leveled these allegations just to
deprive plaintiff no 3 from service which is only source of his bread and
butter as he is serving in Inter Service Organisation and all employees are
strictly monitored by security agencies (Intelligence) and cyber wings. Such
type of acts as alleged by defendants (contacts and affairs with anti-state
nationalist) may lead to Field Court Martial of the individual.

19. That plaintiff no 3 kept as trust 5 gold bars weighing 10 tola with defendant
no 1 which she handed to defendant no 3, being a greedy and corrupt lady,
she denied to return the same when plaintiff no 3 demanded to return from
defendant no 1. It’s a matter of fact that Defendant no 3 being government
employee also deceive to State of Islamic Republic of Pakistan in term of
financial lose by claiming Medical Allowances and House Rent Allowance/
Hiring as she is not entitled for same for almost last 37 Years by curtailing
the fact.

20. That the plaintiffs sent a legal notice and demanded written apologies on
their concocted allegations but the defendants constantly defaming plaintiffs
via slanders and libels by leveling allegation.

21. That thereafter the plaintiffs communicated the defendants either to request
for forgiveness or pay the titled amount to the plaintiffs on their baseless,
frivolous, fake and concocted allegations, slanders and libels, but two days
ago, the defendants refused to apologies or to pay losses, hence this suit.

22. That the plaintiffs faced the anguish and hardships in society, family, friends
and workplace due to baseless, frivolous, fake and concocted allegations,
slanders and libels, moreover, plaintiffs have also suffered huge financial
 loss, mental torture and also loss of reputation, which cannot be
compensated in the shape of money. But acts of defendants not to apologies
and ongoing to defame plaintiffs by slanders and libels, its only option that
defendants either should written apologies or to compensate plaintiffs as
under: -
Ser Losses in term of Amount for all Plaintiff (Rs.)
a. Reputation 90,000,000.00
b. Financial 5,000,000.00
c. Mental torture 5,000,000.00
Total amount (Rs.) 100,000,000.00

23. That the cause of action lastly accrued two days ago, when the defendant
refused to accede the lawful request of the plaintiff, which is continuing day
by day.

24. That the cause of action accrued at Rawalpindi and the parties are also
resident of Rawalpindi, hence this honorable court has jurisdiction to
entertain the matter.

25. The court fee of worth RS: 15000/- hereby affixed.

PRAYER
It is therefore respectfully prayed that defendant should apologies in writing
on their baseless, frivolous, fake, concocted allegations, acts, slanders and
libels leveled against plaintiffs within two weeks after process of court
notices, otherwise suit for the recovery of damages of Rs. 100,000,000/-
may kindly be decreed in favour of the Plaintiffs as against the Defendants.
it is further prayed that decree for causing mental torture, loss of reputation,
money and good-will in the favour of Plaintiffs and against the Defendants
with exemplary cost under section 35-A CPC. Any other relief which this
Honorable Court may deem fit and proper be also granted to the Plaintiffs in
the interest of justice.

Plaintiffs
 Through

Advocate High Court

Rawalpindi

VERIFICATION:
Verified in oath that contents of the plaint are true and correct to the best of
my knowledge and belief and nothing has been concealed therefrom.

PLAINTIFF