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smaple declatratory suit

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Subject: suit for specific contract in the court of senior civil judge/aala ilaqa qazi dstrict court swat kpk name : hameed s/o nasar address : moh qazibaba landikotal peshawer (plaintiff) name :sahar gul s/o qamar gul address mohalla bami khel qazi baba landikotal( defendant ) the plaintiff stating as follow :; 1. that the defendant have a property which i purchased it by document no xyz listed to plaint on r.s 50,00,00,0 the contract made at 29 july 2010 and it had decided through an affidavit of sahar gul in which he stated that i solemnly agree for the registry of the property and that i will give you a registered deed of the property attested from land revenue but now the defendant didn,t give the registry of property . 2. the cause of action arose when defendant didn,t response to my mail on 26 dec 2010 the document prefixed ,with plaint and also not cooperating in this regard . 3. the cause of action arose in landikotal and the court have jusrisdiction in the said matter 4.for the purpose od jurisdiction and court fees is rs 25000 5. it is requested from honorable court for specific performance of the contract and expenses of the court as court considered fit and just. I solmnly affirmed that the content of pahara 1 to 2 is true to my belief and knowledge and from 3 to 4 is also true to the best of my knowledge name : hameed s/o nasar signature attorny name naseer adv signature name hameed signature

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