Sample Suit to get Old Record

IN THE COURT OF SENIOR CIVIL JUDGE, DISTRICT LAYYAH

CIVIL SUIT NO. ______ OF 2024

Bashir Ahmad
S/o ________________
R/o ________________
Tehsil & District Layyah.
...Plaintiff

VERSUS

1. Deputy Commissioner
   District Layyah.
2. Patwari
   Circle ________________,
   Tehsil & District Layyah.
   ...Defendants

SUIT FOR DECLARATION WITH MANDATORY INJUNCTION

Respectfully Sheweth:

1. The Plaintiff: The Plaintiff, Bashir Ahmad, is a resident of Tehsil & District Layyah, and is the grandson of the late Mohammad Faiz, who was the original owner of certain agricultural lands in District Layyah.
2. The Defendants:
• Defendant No. 1 is the Deputy Commissioner of District Layyah, responsible for maintaining public records including Jamabandis and other land records.
• Defendant No. 2 is the Patwari of Circle ___________, responsible for the upkeep of land records within his jurisdiction.
3. Cause of Action:
• The Plaintiff's grandfather, Mohammad Faiz, was the owner of various agricultural lands in District Layyah. These lands were subject to various mutations and entries in the official records, including Jamabandis, over the years.
• Recognizing his right as a legal heir, the Plaintiff, on 30th August 2024, formally approached the Defendants by submitting an application for access to the Jamabandis and related records pertaining to the land of his grandfather, Mohammad Faiz, in Mauza Khan Wala. The application was duly registered with Diary Number 02 at the Patwari's office.
• Despite the passage of more than a week since the application was submitted, the Defendants have failed to provide the requested access. The authorities have shown a complete lack of response, deliberately ignoring the Plaintiff's legal request.
• Worse still, it has come to the Plaintiff’s knowledge that the Defendants, in an unlawful attempt to extract money from the Plaintiff, have threatened to withhold the records and potentially alter or forge the existing records to the Plaintiff's detriment. Such malafide actions are intended to obstruct justice and deny the Plaintiff his rightful access to the land records.
4. Relief Sought:
• The Plaintiff seeks a declaration from this Honorable Court that he is entitled to access the Jamabandis from 1947 up to the present date, along with all mutations and other relevant records pertaining to the lands of his grandfather, Mohammad Faiz, as a matter of legal right.
• The Plaintiff requests that the Defendants be directed to produce before this Honorable Court a complete list of mutations pertaining to the sale and purchase transactions of Mohammad Faiz from the year 1947 to the present date before providing copies to the Plaintiff.
5. Prayer: In light of the above facts and circumstances, it is respectfully prayed that this Honorable Court may be pleased to:
• Declare that the Plaintiff, Bashir Ahmad, is entitled to access the Jamabandis from 1947 to the present date, along with all mutations and relevant records pertaining to the lands of Mohammad Faiz, his grandfather.
• Direct the Defendants through a mandatory injunction to provide immediate and unhindered access to the said records located in the Deputy Commissioner’s office and the Patwari's record room.
• Direct the Defendants to produce before this Honorable Court a complete list of mutations pertaining to the sale and purchase transactions of Mohammad Faiz from the year 1947 to the present date before providing copies to the Plaintiff.
6. Verification: I, Bashir Ahmad, the above-named Plaintiff, do hereby verify that the contents of paragraphs 1 to 7 are true and correct to the best of my knowledge and belief.

Dated: ____________
Place: Layyah

_________________________
Bashir Ahmad
(Plaintiff)

Through Counsel:
_________________________
Advocate High Court,