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IN THE LAHORE HIGH COURT, MULTAN BENCH,

MULTAN.

W.P. No.____________/2003

Amanat Ali Vs Director General, M.D.A. etc.

INDEX
S. No. DESCRIPTION OF DOCUMENTS ANNEXES PAGES
1 Urgent Form
2 Stamp Paper worth Rs. 500/-
3 Writ Petition.
4 Affidavit.
5 Power of attorney.

PETITIONER,
Dated: ________

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

W.P. No.____________/2003

Amanat Ali S/o Inayat Ali, R/o Basti Sharif Pura, Mohallah Momin
Abad, Multan.
……PETITIONER
VERSUS
1. Director General, Multan Development Authority, Multan.
2. Director, Estate Management, M.D.A. Multan.

…RESPONDENTS

Writ Petition under Article 199 of


the Constitution of Islamic Republic
of Pakistan, 1973 directing the
respondent authorities to allocate 3
Marla plot to the petitioner as per
decision of the Govt. against his land
and built up house acquired by the
respondents for the construction of
Scheme Shah Rukn-e-Alam Colony,
Phase-II, Multan.

Respectfully Sheweth: -

1. That the names and addresses of the parties have correctly been
given for the purpose of their summons and citations.

2. That petitioner purchased a 3 Marla plot vide registered deed


dated 8.10.1981and constructed a residential house and started
living in it. The original registered deed was delivered to the
respondents and which is still with them.
3. That sometime thereafter, land including petitioner’s built up
house was acquired by the respondents for the construction of a
Colony known as Shah Rukn-e-Alam Phase-II, Block “J”.

4. That respondents, vide letter No. 11671 dated 12.7.88 directed the
petitioner to demolish his house and hand over the possession of
the plot, which was numbered as J-98 S.R.A. II, to the allottee of
the same plot.

5. That in compliance of the directions, the petitioner demolished


the superstructure and handed over the possession of the plot to
its allottee through officers of the respondents.

6. That under policy of the Govt., the petitioner was entitled to the
grant of compensation for the superstructure of land acquired
from him, and he shall also be entitled for the allotment of 3
Marla plot against his acquired plot. The Govt. policy further
goes that a sum of Rs. 3500/- per Marla will be charged as
development charges from such allottee after deducting the
amount of compensation due to him. The remaining sum will be
charged from him in 3 equal yearly installments.

7. That name of the petitioner exists in the Survey List of structure


of 1986 and he is entitled to 3 Marla plot as per policy decision of
the Govt.

8. That since 1988, the petitioner is regularly pursuing to get his


right of 3 Marla plot, but the respondents have adopted a very
slack attitude and uptil now the respondents have failed to
comply with the Govt. policy. It is the duty of the public
functionaries to decide the petitioner’s case expeditiously and
within a reasonable time as envisaged by article 4 of the
Constitution read with Sec-24(a) of the General Clauses Act, as
per principle laid down by the Hon’ble Supreme Court in M/s Air
Port Support Service’s case 1998 S.C.M.R. 2268.

9. That agony of the petitioner enhanced as he is homeless since


1988 while cost of construction material raised many times
making it much difficult for the petitioner to raise proper
construction over the plot which is still be allotted to him by the
respondents.
10.That the petitioner is left with no other alternate, adequate,
efficacious or speedy remedy except to invoke the extraordinary
constitutional jurisdiction of this Hon’ble Court, for the redressal
of his grievance.

Wherefore, it is respectfully prayed that this


Hon’ble Court may be pleased to call for the record of
the petitioner’s case and after its perusal, direct the
respondents to decided the petitioner’s pending matter
within a shortest possible time fixed by this Hon’ble
Court.

It is further prayed that keeping in view the


petitioner’s matter pending for 13 long years without
any fault on his part, to award exemplary cost to the
petitioner from the respondents.

Any other writ, direction, order or relief, which


this Hon’ble Court deems fit may graciously be
awarded in the interest of justice and equity.

HUMBLE PETITIONER,

Dated: ________

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.

Certificate: -
Certified as per instructions of the client,
this is the first petition on the subject matter.
No such petition has earlier been filed
before this Hon’ble Court.
Advocate

Books: -
1. Constitution of Pakistan, 1973.
2. General Clauses Act.
3. C.P.C.
4. 1998 S.C.M.R. 2268
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

W.P. No.____________/2003

Amanat Ali Vs Director General, M.D.A. etc.

AFFIDAVIT of: -
Amanat Ali S/o Inayat Ali, R/o Basti Sharif Pura,
Mohallah Momin Abad, Multan.

I, the above named deponent do hereby


solemnly affirm and declare that the contents of
the above-titled petition are true and correct to
the best of my knowledge and belief and nothing
has been kept concealed thereto.

DEPONENT

Verification: -
Verified on oath at Multan, this _____ day
of March, 2003 that the contents of this affidavit
are true & correct to the best of my knowledge
and belief. Nothing has been kept concealed
thereto.

DEPONENT
IN THE LAHORE HIGH COURT, MULTAN BENCH,
MULTAN.

W.P. No.____________/2003

Amanat Ali Vs Director General, M.D.A. etc.

Writ Petition under Article 199 of


the Constitution of Islamic Republic
of Pakistan, 1973.

Through: -
Zafar Iqbal Khan,
Advocate High Court,
124-District Courts,
Multan.

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