SAMPLE OF CONTEMPT PETITION

IN THE COURT MR. _____________ CIVIL JUDGE LAHORE

In re;

age 52 Years son of Sh. ________r/o Village Beganwali, Tehsil Fazilka, Distt. Ferozepur. .......

…..PETITIONER

Versus ________ resident of Village Hiranwali Tehsil Fazilka resident of Village Hiranwali Tehsil Fazilka , Distt. Ferozepur. .........

…..RESPONDENTS

PETITION UNDER ORDER 39 RULE 2 A C.P.C. FOR ATTACHMENT OF THE MOVEABLE AND IMMOVEABLE PROPERTY OF THE RESPONDENTS AND ALSO TO DETAIN THE RESPONDENTS IN CIVIL PRISON FOR SHOWING DISOBEDIENCE AND TO BREACH THE TERMS OF INJUNCTION ORDER DT. 27.04.2007 PASSED BY THIS HON'BLE COURT

Respectfully Sheweth:-

1.   That petitioner has filed a suit for permanent injunction titled as " Name of the main suit. " seeking permanent restraint against the defendants now imp leaded as respondents no. 1 to 4 in the present petition from cutting ,uprooting and from lifting 42 trees which includes 35 Shisam trees and 07 lacura trees standing in the land measuring 151 Kanals detailed as mentioned in the suit situated at Village Hiranwali Tehsil Fazilka own and possessed by the petitioner and his brother Subhash Chander.
2.   That along with the suit the petitioner has also filed an application under order 39 Rule 1-2 read with section 151 C.P.C. seeking ad interim injunction against respondent no. 1 to 4 during the pendency of the suit. On 27.04.2007 while passing the order on the application this Hon'ble court was pleased to issue an order which is as "Present counsel for plaintiff. Suit received by entrustment. Office report seen. It be registered and notice of the same be issued for 17.05.2007 and till then parties are directed to maintain status -quo till then. Sd/- CJ (JD) 27.04.2007. " As ordered by this Hon'ble court the petitioner while making compliance under order 39 Rule 3 C.P.C. sent registered cover enclosing therein the documents relied upon and copy of the plaint and application under order 39 Rule 1 -2 C.P.C. intimating also the next date of hearing . In this way the respondents’ no. 1 to 4 are in the knowledge as to the filing of the suit and of also issuing of injunction order against them.
3. That on 12.05.2007 at about 5:00 PM when the petitioner was present in his field. Respondents no. 1 to 4 along with respondents no. 5 to 7 who were also fully aware as to the passing of injunction order by this Hon'ble court came on tractor trolley and also brought with them highly technical advance machinery especially meant for uprooting standing trees. The respondents asked the driver of machinery to start the machinery with a purpose to uproot the trees. Whereupon the petitioner came to them and asked the respondents not to uproot any tree as the petitioner and his brother are only lawful owner of the trees standing in their land and also asked the driver to take back the machinery from the field. At that time Om Parkash s/o Sh. Daulat Ram & Brij Mohan s/o Daulat Ram and Soma Ram came at the spot in their presence the petitioner showed the copy of stay order issued by this Hon'ble court and also asked not to remove the trees. The witnesses present there also asked the respondents not to uproot the trees and should respect to the order. However the respondents who are stubborn type of persons stated that" they do not bother about any order as to injunction passed by the Court. So they will not allow the trees to remain standing in this land and asked the driver to start the work of uprooting the trees". When petitioner tried to intervene the respondents no. 1 to 7 behaved roughly with the petitioner so in this way the respondents no. 1 to 7 in clear violation of the injunction order uprooted 5 tahli trees out of which they loaded the four trees in the trolley whereas one uprooted tahli tree is lying in the land of petitioner as the same could not bee loaded in the trolley being of heavy weight.

PRAYER:

Hence, it is, therefore, prayed that as the respondent no. 1 to 7 in clear violation of the stay order have uprooted five tahli trees standing in the land of petitioner and have made themselves liable for punishment as provided under order 39 Rule 02 A C.P.C. so the moveable and immoveable property of the respondents may kindly be ordered to attached and also to detain the respondents in civil prison for showing disobedience and to breach the terms of injunction order dt. 27.04.2007 passed by this Hon'ble court.

PETITIONER

THROUGH:

Advocate

Dated:                                                           

SAMPLE OF SUIT FOR DECLARATION TO DECLARE PLAINTIFFS AS LEGAL HEIRS

IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

Civil Suit No.________________/ 2015

Name of Plaintiff or Plaintiffs son of ………… resident of ……………………

                                                                         …PLAINTIFFS

Versus

     Public at Large

…DEFENDANT

SUIT FOR DECLARATION TO DECLARE PLAINTIFFS AS LEGAL HEIRS OF LATE …………………………..

Respectfully Sheweth:-

1.  That the addresses of the parties have been given correctly for the purpose of service of notices / summons etc.
2. That the husband of plaintiffs No. 1 and 2 and real father of plaintiffs No. 3 to 8 namely ………………….. died on 23-03-2007. Copy of death certificate is annexed as Annex-A.
3. That the plaintiffs required the declaration to the effect that the plaintiffs are lawful legal heirs of deceased and no other person is legal heir of deceased except them and if they are not declared as legal heirs of the deceased named above they shall suffer an irreparable loss.
4. That the cause of action accrued when husband of plaintiffs No. 1 and 2 and real father of plaintiffs No. 3 to 8 died which is still continuing.
5. That the parties reside, cause of action accrued and deceased died in Lahore, hence, this Honourable Court has jurisdiction to entertain and adjudicate upon the matter.
6. That the subject matter of the suit for the purposes of court fees and jurisdiction is fixed at Rs. 400/- which is exempted for the payment of court fee.

PRAYER

In view of above submissions, it is most humbly prayed that judgment may very kindly be passed in favour of the plaintiffs and against the defendant declaring the plaintiffs No. 1 to 8 the only legal heirs of the deceased ………………… in the larger interest of justice

Any other relief which this Honourable Court may deems fit may also be granted to the plaintiffs.

      Plaintiffs         

                                                                   Through      

Advocate

                                                                  

VERIFICATION:

Verified on Oath at Lahore on 17^th day of December 2014 that the contents of the plaint from Paras No. 1 to 3 are correct as per my knowledge and belief, rest of the paras are also correct as per my information.

                                                 PLAINTIFFS