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IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

      Civil Suit No.___________/2011

      Mst. Munaza Jabbar wife of Muhammad Jabbar D/o Haji Allah Ditta, R/o       House No. –, Mina Bazar, Hanjarwal, Multan Road, Lahore.

                                                                          Plaintiff

VERSUS

1. Public at Large.
2. Nadra through its Director General, Abot Road, Lahore.

                                                                     Defendants

* * *

SUIT FOR DECLARATION

RESPECTFULLY SHEWETH:-

1. That the plaintiff is a citizen of Pakistan & resided at above mentioned address.
2. That the plaintiff is a illiterate lady. The father of the plaintiff Muhammad Younas (Late) was moreover illiterate person & due to illiteracy he mentioned the date of birth of plaintiff 04-04-1974 instead of 15-06-1982 & name of plaintiff Naghma Younas instead of Naghma Rohi in NADRA & the same wrong name & date of birth was incorporated by the NADRA National I.D. Card of plaintiff.
3. That a fortnight ago it came into the knowledge of plaintiff that her wrong name & wrong date of birth was incorporated in her National I.D. Card number. The plaintiff with her brother approached the NADRA Head Office & requested to correct her name & date of birth in her National I.D. Card according to her original name & date of birth yet the NADRA department demanded declaratory decree for correction of name & date of birth of plaintiff from court of competent jurisdiction, hence this suit.
4. That the cause of action firstly arose in favour of plaintiff against the defendant when the plaintiff came to know the insertion of wrong name & date of birth of the plaintiff in the record of defendant No.2, it again accrued when plaintiff requested for correction the name & date of birth of the plaintiff yet the defendant demanded declaratory   decree for correcting name & date of birth, hence this suit.
5. That the cause of action accrued at Lahore, so this honourable court has jurisdiction to adjudicate upon the matter.
6. That the value of the suit for the purpose of jurisdiction & court fee is fixed at Rs. 200/- which is exempted from court fee.

PRAYER:

It is therefore, most respectfully prayed that  that a declaratory decree may kindly be passed in favour of plaintiff against the defendant No.2 & may kindly be directed the defendant No. 2 to correct the name & date of birth of plaintiff in his record & incorporate his original name & date of birth in his record.

Any other relief which this honourable court deems fit & appropriate in favour of the plaintiff may moreover be awarded.

Plaintiff

Through:-

COUNSEL

VERIFICATION:

Verified on oath at Lahore on this 9th day of Jun 2011 that the contents of the Suit are true & correct to the best of my knowledge, information & belief & nothing has been concealed so far.

Plaintiff

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