SUIT FOR DECLARATION AND MANDATORY INJUNCTION AGAINST NADRA



IN THE COURT OF SENIOR CIVIL JUDGE, HYDERABAD
F.C Suit No._________ of 2017


Akbar Ali S/O Mohammad Qasim By Caste Bapar R/O 
Bhittai Town Taluka Qasimabad 
District Hyderabad - - - - - - - - - - -- - - - - - - - - - - - - PLAINTIFF

V E R S U S

1. Secretary Interior Ministry, Govt of Pak: Islamabad
2. The Chairman NADRA Islam Abad.
3. Regional Manager, NADRA at Hyderabad
4. Assistant Manager NADRA, Hyderabad - - - - - -DEFENDANTS

SUIT FOR DECLARATION AND MANDATORY INJUNCTION

That the plaintiff above named begs to submit as under: -

1. That the suit is not barred by any disabling enactment and no suit of such nature has been filed earlier.

2. That plaintiff is residing at above mentioned address within the jurisdiction of this Honourable Court.

3. That the Plaintiff has obtained Computerized National Identity Card (CNIC) from the defendant NADRA bearing No. 43503-0000000-3 , in which name of Plaintiff is mentioned as Ali Akbar instead of “Akbar Ali”.

4. That so many times Plaintiff approached to the Def. No.4 Assistt: Manager NADRA at Hyderabad for correction of his name as “Akbar Ali” instead of Ali Akbar and issuance of fresh CNIC with correct name, but Def. No.4 refused, stating that to approach before Honourable Court for Declaration.

5. That cause of action accrued to the plaintiff firstly when name of Plaintiff was wrongly mentioned by NADRA in CNIC issued to Plaintiff by Def. No.4 and secondly about 15 days ago when Plaintiff approached to Def. No.4 at Kandhkot Office for correction of name as “Akbar Ali” instead of Ali Akbar and also for issuance of fresh CNIC, but Def. No.4 refused stating that to obtain decree from Court having jurisdiction and is occurring day by day till today.

6. That value of subject matter is Rs.400/- for declaration and Rs.200/- for mandatory injunction, Totaling to Rs.600/-. Hence the matter is below of Rs.50,000/- and Court fee is exempted.

7. That plaintiff therefore prays for Judgment and Decree as under:-

P R A Y E R

A) To declare that the actual name of Plaintiff is “Akbar Ali”. instead of “Ali Akbar” as mentioned in Educational Certificates.

B) To direct the Def.No.4 Asstt: Manager NADRA to issue a fresh CNIC to the plaintiff with correct name.

C) To award costs of the Suit.

D) Any other relief, which this Honourable Court deems fit & proper under the circumstances of the case.

HYDERABAD                                                  P L A I N T I F F

Dated: 2017

CERTIFICATE

This is to certify that this is a first application for declaration and mandatory injunction and no such application of same nature has been preferred by undersigned on behalf of the present applicant.




HYDERABAD                                                 (SAJID MIR)

Dated 00.00.0000                                  Advocate for the 
Plaintiff


LIST OF DOCUMENTS PRODUCED:-
  1. P.S Copy of Intermediate Provisional Certificate of Mohammad Aslam ( Son).
  2. P.S Copy of provisional Certificate of Matriculation of Saira ( Daughter).
  3. P.S Copy of CNIC.

LIST OF DOCUMENTS RELIED UPON:-
  1. Any document, which rebut the case of defendants & prove the case of plaintiff.

                                                                Advocate for Plaintiff
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