IN THE COURT OF SENIOR CIVIL JUDGE

(WEST), ISLAMABAD

Mst. Kousar Noor Muhammad wife of Qazi Muhammad

Nazeef Arshad, daughter of Noor Muhammad, Resident of
House No. B-1, Street No. 6, Gulshan-e-Khuda Dad, E-11/1,
Islamabad.

………PLAINTIFF

VERSUS

1. National Database and Registration Authority, Ata-Turk

Road, G-5, Islamabad through its Chairman.

2. Public at Large.

.............DEFENDANTS

SUIT FOR DECLARATION AND PERMANENT

INJUNCTION

Respectfully sheweth:

1. That the Plaintiff namely Kousar Noor Muhammad (old name

“Parveen Kousar”)was born on 01-11-1991 and the same
date of birth and name of Plaintiff was written in the record
of Board of Intermediate and Secondary Education
Sargodha and Alama Iqbal Open University. The defendant
No.1 issued the “CNIC” bearing No. 38406-0578708-6 to the
plaintiff and mentioned the date of birth as 18-8-1988 and
the name of plaintiff as “Parveen Kousar” which was
factually incorrect.

2. That the plaintiff was student and married on 21-4-2012 and

did not noted the said mistake but few months ago by
realizing the said mistake as to the date of birth and the
name of plaintiff by the Examination team of Allama Iqbal
 Open University as the same were not correctly mentioned
by the National Database and Registration Authority, hence
the plaintiff approached the office of National Database and
Registration Authority for correction of date of birth as well
as the name of plaintiff. The plaintiff approached the
defendant No.1 (NADRA) for correction in the “CNIC” as per
Educational Certificates issued by the Board of Intermediate
and Secondary Education Sargodha and Alama Iqbal Open
University and issue the fresh “CNIC” after making
necessary correct entries as per Educational Certificates but
the defendant No.1 linger on the matter on one pretext or
the others and finally refused/declined to correct the date of
birth of Plaintiff as well as the name of plaintiff, hence the
cause of action and the instant suit.

3. That the cause of action accrued in favour of plaintiff as

against the defendant No.1 on refusal of the defendant to
accede the lawful demands of the plaintiff few days ago and
the same continues.

4. That the cause of action accrued in favor of plaintiff as

against the defendants at Islamabad. The office of the
defendants No.1 is at Islamabad. Necessary entries in the
record are to be made at Islamabad. Therefore, this
honourable Court has the jurisdiction to entertain and
adjudicate upon the instant Suit.

5. That the value of the Suit for the purposes of Court fee and
jurisdiction is fixed at Rs.25,000/- and the appropriate
Court fee shall be paid, if chargeable on the plaint.

PRAYER:
It is, therefore, most respectfully prayed that this
honourable Court may kindly be pleased to pass a judgment and
decree in favour of plaintiff as against the defendant with the
declaration that the dates of birth and the name of Plaintiff is
correct as per Educational Certificates issued by the Board of
Intermediate and Secondary Education Sargodha and Alama Iqbal
Open University and also declared that the plaintiff is entitled to
get the “CNIC” as per Educational Certificates issued by the
Board of Intermediate and Secondary Education Sargodha and
Alama Iqbal Open University and the defendant No.1 be directed
to issue “CNIC”. A decree for permanent injunction may also be
passed directing the respondents to refrain from acting against
law and a decree by way of mandatory injunction may be passed
directing the respondents to incorporate and correct necessary
entries in the record concerned and incorporate the plaintiff’s
date of birth as 01-11-1991 as well as the name of plaintiff as
“Kousar Noor Muhammad” in place of her old name “Parveen
Kousar” and to issue necessary certificates pursuant thereto.

Any other relief, found appropriate and just, in the facts and
circumstances of the case, may also be awarded.

Plaintiff
Through

Tariq
Mahmood
Advocate High Court

THE LAW CONCERN

Mezzanines1A, 1B, 2A & 2B, Golden Plaza,
Blue Area, Jinnah Avenue, Islamabad
Phones: 2347130, 2347131, 0332-5211014
Fax: 2875461

VERIFICATION:
Verified on Oath on this _____ day of June, 2016, that the contents
of the Paragraph 1 to 3 are true and correct to the best of my
knowledge and belief and those of the rest of the paragraphs are
believed to be true as per information furnished.

Plaintiff
 IN THE COURT OF SENIOR CIVIL JUDGE
(WEST), ISLAMABAD

Mst. Kousar Noor Muhammad

VERSUS

National Database and Registration Authority etc

SUIT FOR DECLARATION AND PERMANENT INJUNCTION

MEMO OF ADDRESS
Mst. Kousar Noor Muhammad wife of Qazi Muhammad Nazeef

Arshad, daughter of Noor Muhammad, Resident of House No. B-

1, Street No. 6, Gulshan-e-Khuda Dad, E-11/1, Islamabad.

Plaintiff
Through

Tariq Mahmood,
Advocate High Court
 IN THE COURT OF SENIOR CIVIL JUDGE
(WEST), ISLAMABAD

Mst. Kousar Noor Muhammad

VERSUS

National Database and Registration Authority etc

SUIT FOR DECLARATION AND PERMANENT INJUNCTION

CERTIFICATE:

It is certified as per information received that this is the first

suit, which is being instituted on behalf of the plaintiff in this
Honorable Court, no other petition, appeal & revision
regarding the same cause of action is pending or has been
decided between the parties or predecessor in interests by
this or in any other court of competent jurisdiction. Further
the subject matter is never been decided before the
Honorable High Court or the Supreme Court.

COUNSEL
 LIST OF DOCUMENTS RELIED UPON
Filed by plaintiff

IN THE COURT OF SENIOR CIVIL JUDGE

(WEST), ISLAMABAD

Mst. Kousar Noor Muhammad

VERSUS

National Database and Registration Authority etc

SUIT FOR DECLARATION AND PERMANENT INJUNCTION

Documents filed Documents to be produced and are in Documents to be

with the Plaint. possession. And/or in whose relied upon and in
possession whose possession
Yes Yes Yes

As per list of 1. All the Documents, the photocopies Documents as per

Documents whereof have been appended with column No.1 & 2.
the plaint placing on file mentioned
in the list of documents filed with More documents,
the plaint. if required, after
framing of Issues.
2. Any other document/ documents
required to be filed after framing of
issues.

3. Documents and record presented

by the plaintiff.

4. Oral and Documentary evidence

relevant with disputed issues.

5. All record being in possession of

District Court, Islamabad.

Plaintiff

Through

COUNSEL
 List of Documents Filed
Filed by Plaintiff

IN THE COURT OF SENIOR CIVIL JUDGE

(WEST), ISLAMABAD

Mst. Kousar Noor Muhammad

VERSUS

National Database and Registration Authority etc

SUIT FOR DECLARATION AND PERMANENT INJUNCTION

For Plaintiff

Sr. Description of Date, If The Exhibit If any Signatu

No. Documents any Purpose of No. documen re of
which Production ts were party
the of not or
docum Document exhibited pleader
ent , date of
bears return
1 Copy of CNIC
Proof
2 Copy of Matriculation
Certificate

3 Copy of Marriage
Registration Certificate

Plaintiff

Through

Tariq
Mahmood
Advocate High Court

THE LAW CONCERN

Mezzanines1A, 1B, 2A & 2B, Golden Plaza,
Blue Area, Jinnah Avenue, Islamabad
Phones: 2347130, 2347131, 0332-5211014
Fax: 2875461
 IN THE COURT OF SENIOR CIVIL JUDGE
(WEST), ISLAMABAD
Mst. Kousar Noor Muhammad

VERSUS

National Database and Registration Authority etc

SUIT FOR DECLARATION AND PERMANENT INJUNCTION

On the Behalf of ………………………….…....................................…… Plaintiff

_________________________________________________

I, the undersigned do hereby nominate and appoint TARIQ MEHMOOD

Advocate High Court to be the counsels in the above matter for me and
on my behalf to appear, pursue, plead, act and answer in the above matter,
and to sign and file petitions, statements, accounts, exhibits, compromises or
other documents whatsoever, in connection with the said matter or any
matter arising therefrom and also to apply for and receive all documents or
copies of documents, dispositions etc., and to apply for an issue summons,
notices, interrogatories and other sub-poena and to apply for and get issued
any arrest, attachment or other execution, warrant or order and to conduct
any proceedings that may arise therefrom; and to apply for and receive
payment for all sums or submit for the above matter to arbitration, and to
employ any other Legal Practitioner authorizing him to exercise the power
and authorities hereby conferred on the Advocate whenever he may think fit
to do so.

AND to do all acts necessary to manage and conduct the said case in
all respects, whether herein specified or not, as may be proper and
expedient.

AND I hereby agree to ratify and confirm all lawful acts done on
my/our behalf under or by virtue of these presents or of the usual practice in
such matter

PROVIDED always that, if the case may be dismissed in default, if it

be proceeded ex-parte the said counsel shall not be held responsible for the
same, and hereby agree that in the event of the whole fee agreed by me/us
to be paid to the Advocate remaining unpaid he shall be entitled to withdraw
from the prosecution of the said case until the same is paid.

IN WITNESSES whereof I have hereto signed at Islamabad this June

……., 2016

Executant:………………..……………………………………..………. Plaintiff

Kousar Noor Muhammad

(Through Attorney)
Qazi Muhammad Nazeef
Accepted:
Tariq
Mahmood
Advocate High Court

THE LAW CONCERN

Mezzanines1A, 1B, 2A & 2B, Golden Plaza,
Blue Area, Jinnah Avenue, Islamabad
Phones: 2347130, 2347131, 0332-5211014
Fax: 2875461
 IN THE COURT OF SENIOR CIVIL JUDGE
(WEST), ISLAMABAD

Mst. Kousar Noor

Muhammad
VERSUS

NADRA etc.
SUIT FOR DECLARATION AND PERMANENT INJUNCTION

Sr. Date Proceedings Sr. Date Proceedings

No No
. .
1. 18.

2. 19.

3. 20.

4. 21.

5. 22.

6. 23.

7. 24.

8. 25.

9. 26.

10. 27.

11. 28.

12. 29.
13. 30.

14. 31.

15. 32.

16. 33.

17. 34.

Through

Tariq
Mahmood
Advocate High Court

THE LAW CONCERN

Mezzanines1A, 1B, 2A & 2B, Golden Plaza,
Blue Area, Jinnah Avenue, Islamabad
Phones: 2347130, 2347131, 0332-5211014
Fax: 2875461