LEGAL NOTICE

To,

-----------

-----------

                                 Sub:-          LEGAL NOTICE

Dear Sir,                                 

                    Under the instructions and On behalf of my Client, Mr. ___ son of  , resident of  , Karachi, I, the undersigned Advocate, do hereby serve you this Notice as under:- 

1.                                         That you, on 23.7.97, having adopted filthy language, gave

hurt, disgraced and threatened my Client, abovenamed,  in presence of general people of vicinity including men & women’s of the building in which both you and my Client, above named.

2.                                         That your this immoral, illegal act as described supra  caused

mental torture and agony, disgraceness, and defamation to my Client, abovenamed, in the eyes of general public.

                        So, you are directed to mend your ways and tender your unconditional apology otherwise I have definite instructions to report the matter in proper forum to either civil or criminal i.e. registration of FIR against you and your association and recovery of damages at your sole risk,  costs and consequences.

Sincerely yours,

( S M Zubair )

Advocate.

LEGAL NOTICE

LEGAL NOTICE

Dear Sir,

                 Under the instructions and on behalf of my client ___________ son of_________________ , I, the undersigned advocate do hereby address you as under:-  OR

             I have been instructed by my clientess Mst.____,Karachi, to write you as under:-

1.      That my abovesaid client’s relative namely Syed Arshad Ali s/o. Syed Hashmat Ali aged 55 years was admitted in Ward ICU/CCU=05,Case sheet No.003827, who was a cardiac patient.

2.      That on 13.10.2001.at 0500hrs. The above patient/deceased was suffering from Cardiac attack, the attendance M.Zahid informed to Dr.Razzaq who was sleeping on a very next Bed ICU/CCU=06 but he did not like to disturb himself and he carried on sleeping and whole staff of  ICU was also in sound sleep and he did not heed on this complaint  and the said patient at last expired at 0700 hrs. and then the said Dr.came to examine after expiry of the said patient.

3.      That the said patient was expired due to Dr.A.R`s negligence and the said Doctor made false report, and in this report cause of death, time of death has been mis-stated. P/c is annexed herewith.

4.      That due to this act of negligency of said Dr. and staff on duty the said patient was expired which is a black spot prestige of the Hospital and this act falls under Section 302 PPC which is murder of humanity.

                     

                                   So, I hereby call upon you that the said doctor and staff is working under your kind supervision, to pay Rs.3,00,000/=(Rupees three Lacs) as damages to the legal heirs of the deceased and a qualified apology in writing within seven days from receipt of this notice .Please take notice that in default of your compliance my client will be compelled to take action either to prosecute you in criminal or civil  court of law entirely at your risk as to costs and consequences.        OR

                             It is, therefore, called upon you through this notice that you are bound to pay the maintenance allowance to my clientess @ Rs.3,00,000/=(Rupees three Lacs).

Yours Faithfully,

(S M ZUBAIR)

Advocate.

LEGAL NOTICE

To,

Mr. Al- Haaj Abdul,

Muslim, adult, R/O. Karachi

Sub: -                                    LEGAL NOTICE

Dear Sir,

                          Under the instructions and on behalf of my client, Syed Falan Ahmad son of Syed Falaaan, I, the undersigned advocate, have been instructed by my Client to address you as under:- 

1.                  That you have stated in AL MADAAR, Karachi, Weekly, that “I am thank full to my fraternity/coterie who has elected me again for life-time President of JAMIAT AHL-E-SADAT.

2.                  That it is humbly inquired by my Client abovenamed that

(1)  WHEN  

(2)  WHERE

(3)  WHO

&   UNDER WHAT LAW You were elected? Prove it.

3.                  That the abovenamed scandalous statement has been issued in AL MADAAR, Karachi, Weekly, having adopted and self manufactured election just to harass him for ulterior motives and extort money.

4.                  That your this immoral, illegal act as described supra caused mental torture and agony, disgraceness, and defamation to my Client and fraternity/coterie, abovenamed, in the eyes of general public.

                             So, I hereby call upon you that, to mend your ways and tender your unconditional apology otherwise I have definite instructions to report the matter in proper forum to either civil or criminal and to pay Rs.200, 00,000/=(Rupees Two Crore Only) as damages to my Client the apology in writing within seven days from receipt of this notice. Please take notice that in default of your compliance my client will be compelled to take action either to prosecute you in criminal or civil court of law entirely at your risk as to costs and consequences.       

     Sincerely yours,

SM ZUBAIR 

(ADVOCATE)

BAIL APPLICATION

IN THE COURT OF … JUDICIAL MAGISTRATE KARACHI  ...…..

Case No.145/2002.

The STATE                             VERSUS                                  Syed Farid-ur-Rehman 

S/o. Syed A. Qadir Shah, 

R/o. Karachi.

Presently confined in

Central Jail

                   FIR No.254/02

                   U/S. 324,353/34 PPC

                   P.S. Bufffer Zone

BAIL APPLICATION U/S. 497 CRPC

                                It is respectfully submitted on behalf of the abovenamed accused/Applicant that this Hon’ble Court may be pleased to enlarge him on bail in consideration of the following facts and grounds: -

BRIEF FACTS

As per an FIR No.254/02, on 20-4-2002, at about 1530 hrs., the incident took place at about 1430 hrs. the Complainant with employees was on patrolling to check/control the crime, During patrolling, he reached at 1430 at near House No. R-513, Sector 15/A Bufferzone, two suspected motor cyclists were stopped, on behind seat of the said motor cycle, bearing No. KCF-835, the accused was beseated whose name was known later on as Syed Farid-ur-Rehman S/o.S.A.Qadir Shah who having resisted started to fire to kill with TT pistol on police party, having reserved right of Self-defence the police counter fired due to this the said accused was wounded & fallen on earth, while the other co-accused whose name was known as Nadeem S/o. Waheed later on having fired & left the abovesaid motor cycle got his escaped, and while the other two companions to whom their names were known as Sona and Imran later on escaped on motor cycle bearing No. Unknown. The injured accused had hold in his right hand one pistol 30 bored bearing No.31241 loaded magazine three bullets, one chamber bullet without license alongwith Rs.500/ & Rs.30/ were recovered by the police, the recovered pistol was sealed on the spot and the accused Syed Farid-ur-Rehman was duly arrested, investigation was self hand over, the arrested accused was medical treated in Abbasi shaheed Hospital on 20-4-2002, after medical treatment during investigation, the Complainant, recorded statements of the witnesses, the interim-challan is hereby submitted.

GROUNDS

1.)          That the applicant is quite innocent and this case is false and

fabricated by the police officers and police subordinates due to enmity by the A.S.I.

2.)           That the applicant is a poor person and belongs to respectable Family,

the alleged recovery is foisted one by the police officials, due to enmity as the accused Farid-ur-Rehman is a motor cycle mechanic, the said ASI made/got repaired the SHO's friend's motor cycle by the accused, and on demand of repair charges & service charges but the said ASI refused to pay and said the accused will have to face dire consequences and will be involved/implicated in false cases, Hence this false case, the accused was arrested from his Shop/workshop. So it is a fit case of further inquiry.

3.)         That in the alleged encounter no police official/Sub-ordinate has been neither murdered nor injured but the accused, nor empty cartridges has been recovered.

4.)       That the challan has been submitted in the matter, and no further required

for the investigation.

5.)       That the complainant is, himself, I.O. (Investigation Officer) of the case,

which is mockery in the eyes of law.

6.)        That there are all police Officials/Sub-ordinates has been shown witnesses

in the above matter, So there is violation of Mandatory Provisions  Section 103 Cr.Pc., while the place of occurrence is well-populated area of the locality, at the time of incident is a day time and I.O has not said to any person to make witness.

7.)        That the mushirs are not resident of locality/vicinity but the Police

Officials/Subordinates while incident took place in daytime.

8.)        That from perusal of the FIR it is very clear that the prosecution has

concocted/conceived a story. That the empty cartridges fired by alleged foisted pistol have not been shown/recovered in mushirnama, it means no encounter has been taken place between the Police party and accused, and no Police official or Sub-ordinate has been injured in the alleged encounter, so at this stage it is a fit case of further probe.

9.)          That the alleged weapon had neither been sealed on the spot nor sent it to

the Ballistic Expert and the alleged weapon are country made which are easily available to purchase.

10)            That from  perusal of the contents of FIR, no prima facie case is made out under Section 324,353,34 PPC.

11.)           That the offence does not fall under prohibitory clause of Section 497 Cr.PC

12.)           That the applicant is not a previous convicted  nor a hardened criminal

and neither he will temper with P.Ws nor he will abscond, as he is permanent resident of Karachi.

13.           That if the accused/applicant is not released on bail he will not be able

to defend himself properly.

14.)         That the applicant/accused is ready to furnish solvent surety to the entire

satisfaction of this Hon'ble court.

15.)         That other grounds may be argued at the time of hearing of this bail

application.

PRAYER

                                   It is, therefore, most respectfully prayed that this Hon'ble Court may be pleased to grant him bail in the interest of Justice.

Karachi.

Dated:23/05/2002.                                   

Advocate For the Accused/Applicant.

BAIL APPLICATION

IN  THE  COURT  OF  …  JUDICIAL  MAGISTRATE KARACHI  …..

Bail Application … / 04.

The STATE                             VERSUS                                                          Syed Aamir Ali

                                                                                                                     S/o. Syed Liaqat Ali

         Presently Confined in
         ________ PRISON

FIR No.  07/04

U/Section 13-D.

P.S. LIAQATABAD

BAIL APPLICATION U/S. 497 CRPC

                                It is respectfully submitted on behalf of the abovenamed accused/Applicant that this Hon’ble Court may be pleased to enlarge him on bail in consideration of the following facts and grounds: -

BRIEF FACTS

As per an FIR, the Complainant, SI, Gulbahar, alongwith other police employees, was on patrolling to stop & check crime, at 1110 hrs. reached at inside service Firdaus colony, Post Office, then saw one person, suspected, to whom was arrested, disclosed his name Syed Aamir Ali S/o. Syed Liaqat Ali who was searched before other police party, in right side of his wearing shalwar, tucked up, one TT pistol, three alive rounds, loaded magazines, up turned, without numbered,  was recovered, of which no license was showed, so, this act of the accused falls within Section 13-D, Arms Ordinance, was arrested duly under process, this case will be investigated by ASI, Maqbool Ahmed, copy of FIR was delivered duly, recovered weapon was taken in custody for investigation.

GROUNDS

1.                  That the Applicant is quite innocent and this case is false and fabricated by the police officials and police subordinate due to enmity by the ASI who demanded Rs.30,000/= from the accused/Applicant refused to give any amount hence he arrested him.

2.                  That the Applicant is a poor person and belongs to respectable family and the alleged recovery is foisted one by the police officials.

3.                  That there is a violation of mandatory provisions of Section 103 Cr.PC while the place of occurrence is well /thikly populated area of the vicinity.

4.                  That the mushirs are not resident of the locality but the police officials and subordinates.

5.                  That from perusal of the contents of FIR it is very clear that the prosecution has concocted a story, the alleged recovery is foisted one, and no prima facie case is made out under Section 13-d Arms Ordinance.

6.                  That the alleged weapon had neither been sealed on the spot nor sent it to

the Ballistic Expert and the alleged weapon are country made which are easily available to purchase.

7.                  That the present crime is not punishable with 10 years or R.I or more, hence it does no fall within ambit of prohibitory clause of section 497 Cr.PC.

8.                  That the applicant is not a previous convicted nor a hardened criminal and neither he will temper with P.Ws nor he will abscond, as he is permanent resident of Karachi.

9.                  That if the accused/applicant is not released on bail he will not be able to defend him properly.

10.             That the applicant/accused is ready to furnish solvent surety to the entire satisfaction of this Hon’ble Court.

11.             That other ground may be argued at the time of hearing of this bail application.

PRAYER

                                    It is, therefore, most respectfully prayed that this Hon'ble Court may be pleased to grant him bail in the interest of Justice.

Karachi.

Dated: - ---/---/04                                        

ADVOCATE For the Accused

Application U/S. 10(3) SRPO 1979

IN THE COURT OF ….. RENT CONTROLLER  KARACHI ....

Misc. Application No. ---/04

     

HAMID Ali                  ………………………………                           APPLICANT 

 

VERSUS

Haji Abdul WAHEED     ………………………………                     OPPONENT

APPLICATION U/S. 10(3) SRPO

The Applicant, abovenamed, submits as under: -

1.                 That the Opponent is the Landlord of Shop No.97, B road, Liaqatabad, Karachi  (Hereinafter referred to as the “Tenement Premises”), and the Applicant is the Applicant is Statutory Tenant.

2.                 That the Tenement Premises was obtained by the Applicant on monthly rent of Rs. 2500/= (Rupees Two Thousand Five Hundred only), with effect from 07-11-1995, & the Applicant paid Rs.40,000/= as Refundable Security Deposit and Tenancy Agreement was duly executed in this regard.             

Photocopy of Tenancy Agreement is annexed herewith and marked as Annexure “A/1”.

3.       That it was agreed mutually that the monthly rent would be paid in advance on or before 10^th of the calendar month. The Opponent paid rent regularly till April 2004, but the Opponent failed to tender, issue receipt willfully from March 2004, despite of several requests, from 01.03.2004 200 to till filling of this application.

Photocopies of Paid Bills are     annexed     herewith and marked as Annexure “A/2” “A/   ” respectively.

4.     That cause of action accrued firstly from March 2004, when the Opponent stopped to tender, issue the receipt of paid rent and finally refused and flatly to pay & continuous day to day till today. Hence this application.

5.                      That the Tenement Premises is situated within limits of P.S. _______________, which is within jurisdiction of this Hon’ble Court.

6.     That the prescribed Court-fee has been affixed as per law.

P R A Y E R

                                 It is, therefore, respectfully prayed that this Hon’ble Court may be pleased to pass judgment and Decree in favoure of the Applicant against the Opponent: -

A)               To allow to deposit the rent in the Court in respect of the said Tenement Premises.

B)               Costs of the Application.

C)               Any other relief, which this Hon’ble Court deems fit and proper in     the circumstances of the case.

Karachi.

Dated:----/04/04.                                                                              

APPLICANT

ADVOCATE For the APPLICANT

V E R I F I C A T I O N

           I, HAMID Ali son of …. , Muslim, adult, resident of Karachi, do hereby verify and state on oath that whatever stated above is true correct to the best my knowledge and belief.

Karachi    

Dated: ----/04/04.                                                    

Deponent/Applicant

                                                          The deponent identified by me.

                                                                            

(ADVOCATE)

                                  

Solemnly affirmed on oath before me at Karachi on this __ th day of _______ 2004, by the deponent abovenamed who is identified by Mr. SM ZUBAIR, Advocate whom I know personally.

                               The contents of the Plaint have been read over and explained to the Deponent in Urdu too and he/she seems to be understood the same and set his/her signature/thumb impression.

COMMISSIONER FOR TAKING AFFIDAVITS

DOCUMENTS FILED                  :   Annexure “A/1 to A/    ” 

DOCUMENTS RELIED UPON     :   ALL RELEVANT DOCUMENTS  

ADDRESS OF OPPONENT          :   AS PER TITLE OF THE SUIT.

FOR SERVICE.

ADDRESS OF THE COUNSEL     :     AS PER VAKALATNAMA.

FOR THE APPLICANT                                                                   

Terminating An Agreement: Unsatisfactory Product

 [DATE …...]

[NAME of COMPANY

AND ADDRESS,

Dear [NAME, ……],

     We refer to the Manufacturing Agreement between [NAME OF FIRST PARTY TO AGREEMENT] and [NAME OF SECOND PARTY TO AGREEMENT] dated [DATE OF AGREEMENT, ex. January 5, 1996].

As you are aware, we have been experiencing numerous problems with the [NATURE OF PRODUCT, ex. polymer resins] you have been supplying. The details of these problems have been communicated to you in our previous correspondence, and you have not satisfactorily addressed the problems, despite repeated requests by us.

Please accept this letter as our formal notice to you that we will be terminating the Agreement effective [EFFECTIVE DATE OF TERMINATION OF AGREEMENT, ex. August 1, 1998].

We regret having to take these measures, however our previous requests do not appear to have been met.

Sincerely,

[YOUR NAME, xyz]

Affidavit in Support of Application U/S. 12 (2) CPC

IN THE COURT OF SENIOR CIVIL JUDGE KARACHI …….....................................................…

SUIT NO.----/2004

Abdullah   …..........................................………………………………....……….…   APPLICANT

VERSUS

Zakar s/o. Bakar   …………......……..............................................…………………   RESPONDENT

AFFIDAVIT           

                 I, son of , Muslim, adult, R/O.  Karachi, do hereby state as under: -

1.                  That I am the Applicant/Intervener in the above matter and as such am fully conversant with the facts of the matter deposed herein.

2.                  That I say that the accompanying application under Section 12 (2) CPC R/W Section 151 CPC has been drafted and filed under my specific instructions. For the sake of brevity the contents of the same may please be treated as forming part of this Affidavit.

3.                  That I say that I am bonafide purchaser of half portion of Plot No. Drigh Rd, Karachi. through Sale Agreement dated  13-12-2002 from Shabbir Ahmed , consisting about 110 Square yards as the same Plot is divided into Two equal Parts, which is shown in this matter as Plot No. A-148, Block ‘A’ measuring 120 Square yards. Copy of Sale Agreement is annexed herewith as Annexure “A”.

4.                  That I say that after that, I have constructed the House on portion of Plot in question and also installed electricity and Sui-Gas connection in it. Copies of Bills are annexed herewith & marked as Annexures “B/1 & B/2” respectively.

5.                  That I say that the Defendant namely Shabbir Ahmed died in the year 2002 during the pendency of the proceeding of this matter & the Plaintiff, who is also Naib Nazim of same Union Council, also present in the burial/soium of the Defendant but not brought this fact in the knowledge and record of this Hon’ble Court and continue the proceeding just to achieve some evil aims. Copy of death Certificate is attached herewith as Annexure “C”.

6.                  That I say that being a resident of same locality & Naib Nazim of Union Council, it was in fully knowledge of the Plaintiff that the Plot in question is purchased by me from the Defendant & construction of my house consisting upon bed room alongwith kitchen, drawing and bathrooms were also made in the front of the Plaintiff but he never raised any Objection with me, neither reported the matter in concerned Police Station or any other authority about the illegal construction forcible possession of my even Defendant upon the said Plot, even not moved a single application before this Hon’ble Court during this long period which can justify/confirm this Hon’ble Court by appointing Commissioner. It is also pertinent to mention here that, the other portion of the said Plot is also a constructed house but deliberately, willfully with mala fide intention the Plaintiff concealed this fact from this Hon’ble Court.

7.                  That I say that the Plaintiff filed this suit on the basis of forged and manipulated lease deed which location is also entirely different from Page No.3 of Lease Deed & the Site Plan himself produced by the Plaintiff without making the party to the execution of this Deed either Lessor or Sub-Registrar nor produced one of them a Witnesses, it is also pertinent to mention here that the Plaintiff is also failed to produce himself before this Hon’ble Court for recording of his evidence with the original Lease Deed instead of this he only filed affidavit for ex parte proof without any order which is only is not permissible & no decree can be issued only on it even the same was also not the exhibit of the record of proceeding, & I have a option to file a case for cancellation of said false & forged Lease Deed,  it is also very interested that the so-called Lessor had shown the total area of his possession in Lease Deed is 14  Acres & 19 Ghuntas, but the Plaintiff obtaining instead of a Sub-Lease of 120 Square yards directly got the full Lease Deed which is also beyond the imagination as well as law of registration even the Witness of Deed is also bogus as due to his illegal & unreligious activities he was kicked out from the Mosque on 04-02-1993. Copy of Newspaper  is attached herewith as Annexure  “D“.

8.                  That I say that it has come to my knowledge on 13.9.2003 that proceeding in instant matter is pending by one Bailiff of this Hon’ble Court so without any delay I approached to this Hon’ble Court.

9.                  That I say that the value of Plot is about more than Rs.5,00,000/= (Rupees five lacs only), but he suggested value only Rs.40,000/= (Rupees forty thousand only) which is also out of the jurisdiction of this Hon’ble Court.

10.             That unless the accompanying application is not allowed I shall be prejudiced and bear irreparable loss, which cannot be measured monetarily.

11.             That whatever stated above is true and correct to the best of my knowledge and belief.

     

Karachi.

Dated: -                                                            

DEPONENT

Solemnly affirmed on oath before me at Karachi on this __ th day of_______ 2004, by the deponent abovenamed who is identified by Mr. S M ZUBAIR, Advocate whom I know personally.

 

      COMMISSIONER FOR TAKING AFFIDAVITS