Application for Substitute Service

IN THE COURT OF VIIIth FAMILY JUDGE   KARACHI WEST

F.S.No.1393/2011

Mst. Rozina Begum ………….............. PLAINTIFF

V E R S U S

Muhammad Ashraf  .........………     DEFENDANT

APPLICATION FOR SUBSTITUTE SERVICE

            On behalf of the plaintiff, above named, it is submitted as follows:-

1.            That the plaintiff filed the above suit in October 2011.

2.            That the above suit is still in service since October 2011, and service for publication is pending since Feb,2012, and the plaintiff is very very poor un-educated lady and cannot pay, despite efforts to her level best, and afford Publication fee and she is only supporter to maintain six issues as follows:

1.    Samra (female)aged about 12 years

2.    Laraib  (male) aged about 10 years

3.    Laeba (female) aged about 10 years.

Laraib & Laeba are twins.

4.    Anas (male) aged about 07 years

5.    Aaesha (female) aged about 05 years

6.    Malaeka (female) aged about 04 years

PRAYER

It is respectfully prayed that this Hon’ble Court may be pleased: -

A)   To pass order of substitute service as this Hon’ble Court thinks fit and proper.

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

KARACHI.

Dated: 12/07/2012.

S M ZUBAIR

Advocate for the Plaintiff

AFFIDAVIT

I, Mst. Rozina Begum D/o. Abdul Ghaffar, Muslim, adult, R/o. Karachi, do hereby state on oath as under:

1.            That I am Plaintiff/Deponent in above titled suit and deponent of this affidavit, as such am fully conversant with the facts of the matter deposed herein:

2.            That the accompanying APPLICATION FOR SUBSTITUE SERVICE has been drafted and filed under my express instructions and contents whereof are true and correct and the same alongwith contents of the memo of plaint may please be treated as part of this affidavit for the sake of brevity.

3.            That I say that I have a good prima facie case, and balance of convenience lies in my favour and until and unless accompanying application is granted as prayed I will be seriously prejudiced and shall suffer irreparable loss.

4.            That I say that whatever stated above is true and correct to the best of my knowledge and belief.

Karachi.

Dated: ­­12/07/2012.

Deponent/Applicant

The deponent identified by me

S M ZUBAIR

ADVOCATE

Solemnly affirmed on oath before me at Karachi on this __ th day of _______ 2012, by the deponent abovenamed who is identified by Mr. S M 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