Counter Affidavit Anas (1)

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IN THE COURT OF IXth SENIOR CIVIL JUDGE

AT KARACHI (EAST)

Suit.No. 1087/2020

Syed Muhammad Anas…………..………………………………….Plaintiff

VERSUS

Eureka Global & Ors……………………………………………Defendant(s)

COUNTER AFFIDAVIT TO THE APPLICATION UNDER ORDER


VII RULE XI OF CIVIL PROCEDURE CODE, 1908

That the Plaintiff named above respectfully submits as under:

1. That the prayer clause of the instant suit is purely within the ambit of

civil jurisdiction.

2. That the suit of recovery of outstanding dues, damages, remuneration

& permanent injunction does not entertained/ having no authority to

any other court except this court.

3. That the instant application does not point out cause of action.

4. That the instant application having no merits is liable to be dismissed.

5. That in view of above submissions, this Hon’ble Court may be pleased

to dismiss the under reply application Under O. VII R. XI C.P.C 1908

with cost.

Karachi Advocate for the Plaintiff


Dated:
IN THE COURT OF IXth SENIOR CIVIL JUDGE
AT KARACHI (EAST)

Suit.No. 1087/2020

Syed Muhammad Anas…………..………………………………….Plaintiff

VERSUS

Eureka Global & Ors……………………………………………Defendant(s)

AFFIDAVIT:

I, Syed Muhammad Anas S/o Syed Muhammad Sarfraz, Muslim,

adult, R/o House No. D-68, Plot No. 14 PIB Colony, Karachi do hereby state

on oath as under:-

1. That I say that I am plaintiff in above suit, as such well conversant

with the facts of the above suit.

2. That I say that I have gone through the application Under O. VII R. XI

C.P.C, filed by the defendant, as such appose vehemently for reasons

stated hereafter.

3. That I say that it is submitted that the under reply application is

frivolous, after thought, malicious, misconceived, contrary to facts

and law, the same has been liable to be dismissed.

4. That I say that the suit of recovery of outstanding dues, damages,

remuneration & permanent injunction does not entertained/ having no

authority to any other court except this court.

5. That whatever stated above is true and correct to the best of my

knowledge and belief.

Deponent

Advocate for Plaintiff


IN THE COURT OF IXth SENIOR CIVIL JUDGE
AT KARACHI (EAST)

Suit.No. 1087/2020

Hafsa Johri………………………..………………………………….Plaintiff

VERSUS

Eureka Global & Ors……………………………………………Defendant(s)

COUNTER AFFIDAVIT TO THE APPLICATION UNDER ORDER


VII RULE XI OF CIVIL PROCEDURE CODE, 1908

That the Plaintiff named above respectfully submits as under:

1. That the prayer clause of the instant suit is purely within the ambit of

civil jurisdiction.

2. That the suit of recovery of outstanding dues, damages, remuneration

& permanent injunction does not entertained/ having no authority to

any other court except this court.

3. That the instant application does not point out cause of action.

4. That the instant application having no merits is liable to be dismissed.

5. That in view of above submissions, this Hon’ble Court may be pleased

to dismiss the under reply application Under O. VII R. XI C.P.C 1908

with cost.

Karachi Advocate for the Plaintiff


Dated:
IN THE COURT OF IXth SENIOR CIVIL JUDGE
AT KARACHI (EAST)

Suit.No. 1087/2020

Hafsa Johri………………………..………………………………….Plaintiff

VERSUS

Eureka Global & Ors……………………………………………Defendant(s)

AFFIDAVIT:

I, Hafsa Johri D/o Mazhar ul Islam, Muslim, adult, R/o Flat No. 2-A,

Second Floor, Mughlia Arcade, Plot No. 1/19, 3-A, Nazimabad No. 3, Karachi

do hereby state on oath as under:-

1. That I say that I am plaintiff in above suit, as such well conversant

with the facts of the above suit.

2. That I say that I have gone through the application Under O. VII R. XI

C.P.C, filed by the defendant, as such appose vehemently for reasons

stated hereafter.

3. That I say that it is submitted that the under reply application is

frivolous, after thought, malicious, misconceived, contrary to facts

and law, the same has been liable to be dismissed.

6. That I say that the suit of recovery of outstanding dues, damages,

remuneration & permanent injunction does not entertained/ having no

authority to any other court except this court.

5. That whatever stated above is true and correct to the best of my

knowledge and belief.

Deponent

Advocate for Plaintiff

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