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IN THE COURT OF MR.

MUBASSHIR HUSSAIN CHISHTI, CIVIL JUDGE, (EAST)


ISLAMABAD

In the matter of:

ABC Versus XYZ

Suit for Declaration and Permanent Injunction

Application under Order 7 Rule 11 CPC

REPLY OF APPLICATION U/O 7 RULE 11 CPC ON BEHALF OF


PLAINTIFF/RESPONDENT

Respectfully sheweth:

PRELIMINARY OBJECTIONS

1. That the application lacks basic ingredients regarding Order 7 Rule 11 CPC, hence is liable to
be dismissed.
2. That the applicant has filed the instant application just to harass and pressurize the
respondent/plaintiff.
3. That the application is baseless, false and frivolous and has been filed malafidely and is liable to
be dismissed summarily.
4. That the above titled application is not fulfilling the requirements of Order 7 Rule 11 C.P.C
hence is liable to be dismissed.
5. That the above titled application is also against the law and facts and judgment of the superior
court and needs to be dismissed and the Respondent/Plaintiff is entitled to costs & special costs.
6. That the petitioners want to linger the matter and as a result are wasting the precious time of this
Honourable Court.

ON FACTS:

1. That Para No.1 of the application needs no reply.


2. That Para No.2 of the application is incorrect hence denied. The Plaintiffs have no cause of
action or locus standi to file the instant suit which is also clearly disclosed by the
Respondent/Plaintiff in the plaint.
3. That Para No.3 of the application is incorrect hence denied.
4. That Para No.4 of the application is incorrect hence denied. The suit of the Respondent/Plaintiff
is not barred by any law and no ingredients of Order 7 Rule 11 of C.P.C can be attracted to the
instant suit/plaint.
5. That Para No.5 of the application is incorrect, hence vehemently denied.
6. That Para No.6 of the application is incorrect, hence vehemently denied.
PRAY E R :

It is therefore, respectfully prayed that the instant application may kindly be dismissed with costs.

RESPONDENT/PLAINTIFF

Through

NEELAM AGHA SHUJAH-UD-DIN

Advocate High Court

LL.M. (London. UK)

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