Complaint Letter dj Redacted

[DATE REDACTED]

The Hon'ble [COURT REDACTED],

Karachi East,

City Courts,

Karachi.

Subject: Complaint of misconduct committed by the [COURT REDACTED]

regarding the Family Suit No. [REDACTED]/2021 which has been pending

adjudication before [COURT REDACTED], Karachi East.

Respected Sir,

The facts of subject complaint is narrated, on behalf of the Plaintiff in the following paragraphs:

BACKGROUND OF THE COMPLAINT

That the Plaintiff instituted a Family Suit No. [REDACTED]/2021 against the defendant title “Suit for dissolution of marriage by way of khula and recovery of maintenance allowance”.

That in the year 1991, the Company constructed a multi-storied building on Plot No. G-21, Block [REDACTED], Scheme No. 5, Clifton [REDACTED], Karachi, in the name of “AAshiana [REDACTED] Shopping Mall & Residency [REDACTED]” wherein The entire construction work, consisting upon approximately 170 shops on ground floor, 150 shops on Mezzanine floor and 198 residential flats, was completed in the year 1997.

That recently a group of encroachers started trespassing the unoccupied flats and shops in the project AAshiana [REDACTED]. They filed 80 collusive Civil Suits in different names of plaintiffs for Declaration, Specific Performance and Permanent Injunction, before the Learned [COURT REDACTED] Karachi South, impleading M/s. [COMPANY REDACTED] through its so-called General Manager, instead of the Applicant who is the real owner / builder, as defendant for different shops and flats as the suit properties in the AAshiana [REDACTED] Building. These suits were filed during the span of six months i.e. from 17th of [DATE REDACTED] to [DATE REDACTED] in the same Trial Court. All the 80 suits were based on forged and bogus documents of the suit properties. The defendant Mr. [REDACTED] is not the General Manager of M/s AGE & Sons (Pvt.) Ltd. as he has been fraudulently shown as General Manager of the Company for filing the collusive suits; the real owner / builder of the project ‘AAshiana [REDACTED]’ is the Applicant.

A copy of plaint of Suit no. 474/2013 is field herewith and marked as Annexure ‘C-2’.

That initially 9 civil suits were filed in the month of [DATE R