SARDAR TARIQ MEHMOOD

Advocate High Court & Federal Shariat Court

Address: Office No.1, First Floor, Quaid-e-Azam Block, District Courts,

Rawalpindi. Cell No. 0333-5714559
_______________________________________________________________
Ref No.________ Dated: __________
To,

Muhammad Adil Aslam

Manager A.F Ferguson & Co
Chartered Accountants, a member firm of PwC network
State Life Building No. 1-C, Chundrigar Road,
PO Box 4716, Karachi.

Subject: Reply of Letter Dated 28 December 2017

Dear Sir,

In reply of your letter dated 28 th December 2017 wherein you have

asked to provide information of any litigation, existing or anticipated
regarding Agility Logistics (Pvt) Limited. In this respect, it is submitted thatat
present, Naqvi Law Associates is not dealing with any litigation, existing or
anticipated regarding Agility Logistics (Pvt) Ltd.

SYED ZULFIQAR ABBAS NAQVI

Advocate Supreme Court of Pakistan
Office No.24-B/1, Haider Road,
Behind Fleshman’s Hotel
Saddar, Rawalpindi Cantt.
To,
M.S Corporation
Tube Well Consultants & Contractors
Through its Proprietor Mr. Mudassir
786-K-11, Afshan Colony,
Rawalpindi Cantt.

Subject: LEGAL NOTICE

On the instructions of my client, Basharat Hussain Awan,

CEO Terralink, Office at Abbas Arcade, 5 th Road, Rawalpindi, I
hereby served you with the following legal notice:-

1. That an agreement has been signed between you and my

client on 31-07-2017 which was actually written quotation
of your services and has been finalized with mutual consent
of the parties, you also received an amount of Rs.
6,17,000/- out of total estimated cost against the work of
water well drilling and tube well installation at Saddar PTCL.

2. That you have started the work on site but left the project
incomplete and removed your machinery from the work site
without prior intimation or permission to my client.

3. That your above said act is clear violation of the terms and
conditions settled between you and my client for the
completion of said project. You are legally bound to complete
the project within stipulated period.

4. That due to your negligence, non compliance of the contract

and leaving the project incomplete, the PTCL authorities are
pressing hard to my client and also said that they will
blacklist the firm of my client and in such an eventuality,
my client will have to suffer irreparable loss.

5. That my client contacted to you several times and asked you

to complete your work but you are demanding more and
excessive amount from client and are blackmailing and
pressurizing my client for obtaining undue gains.

Keeping above in view, you are hereby called upon through

this legal notice to immediately install the required
machinery at the work site and start work on the remaining
project immediately after receiving this legal notice,
otherwise my client will initiate legal proceedings against
you at your risk and costs.

SYED WAQAS HAMDANI

Advocate High Court
Rawalpindi

Note
One copy of this legal notice is retained in my office for record and
necessary proceeding.
To:
The Manager
Bank Alfalah Limited, Murree Road
Faizabad Branch, Rawalpindi.

Subject: REQUEST FOR THE PROVISON OF BANK

STATEMENT

Respected Sir,
It is stated that the undersigned is going to file an application for
obtaining succession certificate in the court of Senior Civil Judge
Rawalpindi on behalf of my client Mst. Naz Shahid who is widow/one
of the legal heir of deceased Sh. Shahid Pervez son of Sh. Riaz ud Din.

You are hereby requested to provide Bank Statement of Account

No. 0267-1003285479, Account Type 1150-CA, Alfalah Kamyab
Karobar (AKK).

Thanking you in anticipation.

QAISER ABBAS SHAH

Advocate High Court
Office # 37-G, Ground Floor
Madina Block District Courts
Rawalpindi
To:
Muhammad Ashraf son of Ghulam Muhammad
R/o House No.2745, Street No.8-A, Allama Iqbal
Colony, Tench Bhatta, Rawalpindi.

Subject: Notice for Vacation of Shop No.3 (half portion of

Shop No.4) situated at Liaqat Bagh, Murree Road,
Rawalpindi.

You are my tenant in shop No.3 (half portion of Shop No.4)

situated at Liaqat Bagh, Murree Road, Rawalpindi against rent of
Rs. 15,000/- per month. It is pertinent to mention here that
earlier, the tenancy was oral between you and me but now the
terms and conditions of the tenancy was reduced into writing vide
rent agreement dated 07-10-2017. The period of tenancy was
fixed for two years w.e.f. 07-03-2016 to 07-03-2018.

That the above said shop is bonafidely required by me for

my personal use/business therefore you are asked to vacate the
rented shop within one month.

That as per Clause 7 of the rent agreement dated 07-10-

2017, either party

Sardar Tariq Mehmood

Advocate High Court
Rawalpindi
Note:-
One copy of this legal notice is retained in my office for record
and necessary proceeding.
On the instructions of my client Shoukat Ali son of Muhammad
Latif resident of House No.309/16, Tulsa Road, Lalazar,
Rawalpindi Cantt, I hereby served you the following legal notice:-

1. That you and my client entered into a contract dated 17-08-

2015 in respect of business of dairy farming. As per
contract, my client purchased seven buffalos worth
Rs.800,000/- and handed over to you on the terms and
conditions duly mentioned in the said contract.

2. That thereafter you failed to perform your part of contract

and subsequently another agreement dated 15-10-2016 was
executed between you and my client. As per the said
agreement, you were bound to pay back the amount of
buffalos Rs. 10 Lac to my client within three months.
Moreover you was also bound to pay the amount of milk to
my client which was calculated as Rs.7000/- per month.
You also undertake that if you fail to pay back the aforesaid
amount to my client then you shall transfer your property
measuring 30 Marlas situated in Girja Road in the name of
my client at the rate of Rs. 30,000/- per Marla. On the said
date, you also handed over a cow worth Rs. 80,000/- to my
client as earnest money.

3. That again you failed to fulfill your part of contractual

obligations and neither paid the amount to my client nor
transferred you land in his favour.

4. That my client always fulfilled his contractual obligations

and never made any default on his part but you have not
honoured your commitments and failed to fulfill your
obligations whereas you are legally and lawfully bound to
fulfill you obligations.
In view of above, you are hereby advised to pay the amount
of Rs. 10,00,000/- along with amount of milk @ Rs. 7000/-
per day or in alternate transfer your property as per
agreement dated 15-10-2016 within 07 days of the receipt of
this legal notice, otherwise my client will initiate legal
proceedings against you before the courts of competent
jurisdiction at your risk and cost.

With regards

SYED WAQAS HAMDANI

Advocate High Court
Rawalpindi/Islamabad
Office # 37-G, Ground Floor
Madina Block District Courts
Rawalpindi

Notes
A copy of this legal notice is retained in my office for record and further
proceedings.

Advocate
To:
Secretary IB Employees Cooperative Housing Society
Islamabad.
Office No. 26-27, First Floor, Beverly Centre, Blue Area,
Islamabad.

Subject: LEGAL NOTICE

On the instructions of my client Mrs. Farah Naz Naqvi daughter

of Fazal-ur-Rehman resident of Iqra Apartment, R-2, NUST University
Islamabad, I hereby served you the following legal notice:-

1. That my client had been allotted a residential Plot No. 2624,

Street No.60, Block P, measuring 30`x50`, in Gulberg Islamabad,
the project of IB Employees Cooperative Housing Society Ltd,
vide Provisional Allotment Letter dated 14-05-2013 with
Registration No. Gulberg*/3933/3060/2013.

2. That my client has paid all the installments as per schedule

given by the society and never made any default in payment of
installments.

3. That more than three years have been passed after the allotment
of aforesaid plot to my client, but till date the possession of plot
has not been handed over to my client.

4. That my client want to construct a house on the aforesaid plot

for her residence because she has no residence in the city and
she is facing loss and hardships. My client contacted you and
other administration of the Society and requested to address the
said issue and to handover the possession of her plot but you
made promised many times that the possession will be handed
over to the allottees till December 2016 but you again failed to
handover the possession of above said plot to my client.

In view of above, you are hereby asked to handover the physical

possession of the aforesaid plot to my client within 15 days of the
receipt of this legal notice, otherwise my client will initiate legal
proceedings against you/Society before the courts/forum of
competent jurisdiction at your risk and cost.

With regards

SYED WAQAS HAMDANI

Advocate High Court
Rawalpindi/Islamabad
Office # 37-G, Ground Floor
Madina Block District Courts
Rawalpindi

Notes
A copy of this legal notice is retained in my office for record and further
proceedings.

Advocate
 CERTIFICATE

It is certify that the undersigned has charged Rs. 65,000/-

in mater of the Bank of Khyber Vs. Abdul Wadood etc as

professional fee from the Bank.

SYED ALI ABBAS KAZMI

Advocate High Court
Rawalpindi

Office 29-B-5, Back side Flashmen’s Hotel, Haider Road, Saddar

Rawalpindi Cantt.
 Dated: 24-03-2017

To,
Haseeb Shakoor Paracha,
Advocate High Court
Office No.20, 21, Asian Business Centre,
Near Toyota Rawal Motors, Rawalpindi.

Subject: REPLY OF LEGAL NOTICE DATED 27-02-2017

Dear Sir,
My client Shan-e-Elahi son of Sheikh Abdul Sattar resident
of House No. 26-B, Street No. 22, Safari Homes, Bahria Town,
Phase-8, Islamabad, is in receipt of your above said legal notice
and instructed me to inform you that my client is in contact with
your client and they are negotiating the matter. There is every
hope that they will reach on a just conclusion amicably and with
mutual consent.

Keeping above in view, you are hereby asked to withdraw the

said legal notice.

With regards

BASHIR AHMED RAJA

Advocate High Court
Office No. 213, Iftikhar Ch. Block
District Courts Rawalpindi
Cell #: 0333-5256782

Notes
A copy of this reply is retained in my office for record.

Advocate
To:
The Manger Collection/Recovery Department
Muslim Commercial Bank (Pvt) Ltd
1st Floor, Al-Gilan Building, Satellite Town Branch
Murree Road, Rawalpindi.

Subject: LEGAL NOTICE

On the instructions of my client Syed Shahzad Haider Hamdani

son of Syed Alamdar Hussain, resident of House No. 823, Street No.7,
Sector I-9/1, Islamabad, I hereby served you the following legal
notice:-

1. That my client has availed the facility of personal loan vide PL

No. 0000116430 (Old No. 3-01-0006185) from your bank branch.

2. That after availing the facility of personal loan my client has paid
the installments regularly to your bank but later on, my client
suffered with severe spinal injury and remained under medical
treatment for a long time of about 8 years therefore he could not
pay the aforesaid loan amount.

3. That after recovery from the said diseased, my client has

contacted you with intention to pay the remaining principal
amount. Thereupon a settlement has been taken place between
you and my client and it was agreed that my client will pay you
the principal amount and your bank was pleased to withdraw the
markup amount. Subsequently your bank has received an
amount of Rs. 134,628/- from my client on account of balance
principle amount.

4. That later on your bank have sent a letter dated 04-07-2016

which was received by my client on 30-07-2016 wherein it was
mentioned that you have received an amount of Rs. 39,628 as
markup from my client along with the principal amount.

5. That you have played fraud and misrepresentation with my client

and also committed breach of trust of my client.
 6. That my client also availed credit card facility vide No.
4789720000770117 for a limit of Rs. 52,000/- from your bank
branch. My client also moved an application to your bank for
settlement of the said facility in which my client prayed for
making reasonable installments of the outstanding amount but
no response has been received to my client till date.

7. That as you have received markup amount of Rs. 39628/- from

my client through misrepresentation, fraud and cheating
therefore your bank is liable to return the said amount to my
client or adjust the said amount in the settlement of credit card
facility, hence this legal notice.

In view of above, you are hereby called upon to either return the
aforesaid amount of Rs. 39628/- to my client or adjust the same
in the settlement of credit card facility, otherwise my client will
initiate legal proceedings against you before the court of
competent jurisdiction for the recovery of aforesaid amount and
your bank is responsible for all costs and risk.

SYED WAQAS HAMDANI

Advocate High Court
Rawalpindi.
Cell # 0344-8868563
Office No. 37-G, Madina Block,
District Courts Rawalpindi.
Note
One copy of this legal notice is retained in my office for record and necessary
proceeding.
To:
M/S NEO MEDIX through Proprietor
Mr. Shoukat Nazir Sindhu s/o Ch. Nazar Muhammad
Resident of House No. 105, Street No.6, Lane No.2,
Gulraiz-III, Rawalpindi.

Subject: Legal Notice

Through this communiqué as per instructions of my client

i.e. SME Leasing Limited (A subsidiary of SME Bank Ltd), you are
hereby served with the following legal notice:-

1. That on your request for financing, my client vide letter

dated 12-06-2007 approved a lease facility whose
amortization was agreed in four years in shape of
48 monthly installments. In view whereof, you executed the
following documents:-
i. Demand Promissory Notice of Rs. 7005152/-.
ii. Letter of Continuity.
iii. Letter of Revival.
iv. Undertaking.
v. Lease Agreement dated 27-06-2007.
vi. Letter of Guarantee.
vii. MOTD of Property i.e. All the piece and parcel of
Plot/land bearing No.102, measuring 1 Kanal,
Khewat No. 852, Khatooni No. 1880, Khasra No.
4491/4333, 4336/4216/69 measuring 117 Kanal
5 Marla share being 20/23/45 Mouza Kotha Kalan
Tehsil and District Rawalpindi situated at Gulraiz
Housing Scheme No. III.

viii. Mortgage Deed.

ix. Equitable Mortgage Deed, etc.

2. That after availing the above said lease facility, you

defaulted in payment of monthly installments and inspite of
various commitments made by you on several occasions you
have not adhered to the same, as a consequence whereof my
 client has become entitled to claim the whole outstanding
amount against you to the tune of Rs. 4355803/- which
through this notice you are hereby required to deposit/
return the same within 15 days of receipt of this notice to
my client, otherwise my client will proceed against you for
recovery of the outstanding liability mentioned hereinabove
at your own risk and cost in accordance with law.

SYED ALI ABBAS KAZMI

Advocate High Court
Note:-
One copy of this legal notice is retained in my office for record and necessary
proceeding.

_______________________________________________________________________
Office # 24-B1, Back Side Flashmen Hotel, Haider Road, Saddar, Rawalpindi.
Phone # : 0333-5612733
 MALIK SAAD HUSSAIN
Advocate High Court
Office # 213, First Floor, Justice Iftikhar Ch. Block,
District Courts Rawalpindi.
Phone # : 0311-1383377
Ref: ___________ Dated: __________
To,
Muhammad Ikram son of Muhammad Siddique
R/o House No. 335, Street No.41, Sector G-10/1,
Islamabad.

Subject: FINAL LEGAL NOTICE

I have been instructed by my client Asif Mehmood Khan son of

Sultan Mehmood Khan resident of Chak No.78/10-R, Post Office Chak
No. 80/10-R, Tehsil and District Khaniwal, to serve you the following
legal notice:-

1. That you have entered into an agreement dated 05-04-2017 with

my client for the purchase of Plot No. 33, measuring 30x60 Sq ft,
situated in Sector I-12/2, Islamabad, against total sale
consideration amount of Rs. 34,00,000/- (Rupees Thirty Four
Lac only).

5. That you have paid an earnest money of Rs.600,000/- to my

client and remaining payment was to be paid at the time of
transfer of said plot in your favour.

6. That as per the aforesaid agreement, it was settled between the

parties that right after the issuance of allotment letter of the said
plot from CDA, you are legally bound to get transfer the said plot
in your name while paying the remaining sale consideration
amount to my client.

7. That my client has got issued the allotment letter of the above
said plot from CDA and thereafter contacted with you several
times for the completion of above said agreement but you are
lingering the matter on one pretext or the other. You are showing
lack of interest in this regard.

8. That you have failed to perform your part of contractual

obligations and also failed to arrange the remaining sale
consideration amount of the said plot whereas my client is ready
to transfer the same in your favour. In this way you have violated
the terms and conditions of the agreement.
9. That my client has already performed his part of contract but you
are not honouring your commitment. It is clearly written in the
agreement dated 05-04-2017 that in case of failure in payment of
remaining amount of Rs. 28 Lac on your part, the agreement
shall stand cancelled and the earnest money shall be forfeited.

10. That earlier, a legal notice No. 6/17 dated 07-10-2017 on the
subject was also sent to you vide Registered Postal Receipt
No.1266 but you even did not bother to reply the same.

In view of above, you are hereby informed that due to your

irresponsible conduct and non compliance of the terms and
conditions of agreement dated 05-04-2017, the said agreement
stands cancelled and your earnest money is forfeited in favour of
my client. Now my client is free from the agreement dated
05-04-2017 and now you have no concern whatsoever with the
above said plot.

SARDAR TARIQ MEHMOOD

Advocate High Court
Rawalpindi
Notes
A copy of this legal notice is retained in my office for record and necessary
proceeding.

Advocate
To:
Malik Muhammad Usman son of Rehmat Khan
R/o House No. ZB-541, Mohallah Rehmat Colony
Pirwadahi, Rawalpindi.

Subject: LEGAL NOTICE

That one Aurangzeb filed a petition u/s 22-A&B Cr.P.C for registration
of criminal case against you in the court of learned Sessions Judge
Rawalpindi which was entrusted to the court of Mr. Irfan Saeed, learned ASJ
Rawalpindi.

That you have approached the undersigned through Muhammad

Mushtaq, for contesting the said petition.

That you have appointed me as counsel and I have filed Vakalat Nama
on your behalf and contested the said petition u/s 22-A&B Cr.P.C and the
said petition was dismissed.

That a sum of Rs. 20,000/- as legal/counsel fee was settled between

you and me but nothing has been paid from you.

That you promised to pay my legal fee before the conclusion of the
case but you never bother to contact me nor paid my fee till to-date. I try my
best to make contact with you through Muhammad Mushtaq but you turned
deaf ears in this respect. Your said acts have established the fact that you by
utilizing my precious time and professional abilities misuse the same.

That you are hereby advised in your own interest to make payment of
legal fee of Rs. 20,000/- within 07 days of receipt of this Notice other wise all
legal options are available to me for the recovery of the same.

SARDAR TARIQ MEHMOOD

Advocate High Court
Rawalpindi

Note: A copy of the legal notice is kept in my office for record and further
legal action.
To:

(1) Imran

(2) Samraan sons of Munawar Hussain (late) residents of

House No.31-A, Satellite Town, Rawalpindi.

(3) Malik Waseem son of name unknown, resident of Shop

No. 12 & 13, Abbas Haider Market, Jinnah Road,
Rawalpindi

Subject: LEGAL NOTICE

Mr. Zafar Ali Shah son of Qalandar Ali resident of House

No.77, Millat Colony, Mukha Singh Estate, Rawalpindi, presently
residing at England, has instructed me through his Attorney Syed
Ali Mustafa Kazmi son of Syed Ali Zafar Kazmi, to serve you the
following legal notice:-
1. That my client is owner of Shops No. 12 & 13, Abbas Haider
Market, Jinnah Road, Rawalpindi. The said shops were
rented out to Mr. Munawar Hussain in the year 1994
against monthly rent of Rs.4000/- per month vide Rent
Agreement dated 17-01-1994. Now the present rate of rent is
Rs. 22,800/- per month.

2. That the said Munawar Hussain died approx. 05 years ago

and you Imran and Samraan were doing the business in the
aforesaid shops being sons of deceased. Later on you have
subletted the rented shops to Malik Waseem who is son-in-
law of deceased Munawar Hussain.

3. That the rent agreement executed between the parties in the

year 1994 had already been expired and thereafter no fresh
rent agreement was ever executed between the parties.

4. That during the life time of Mr. Munawar Hussain, my client

many times asked him to execute a fresh rent agreement
and after his death, he again requested both of you i.e.
 Imran and Samraan, to execute fresh rent agreement but
you delayed the matter on one pretext or the other and took
undue benefit of abroad residence of my client.

5. That both of you have subletted the rented shops to Malik

Waseem and all of you are not willing to execute fresh rent
agreement with my client.

6. That my client is not willing to continue the tenancy with

you therefore you are liable to be ejected from the rented
shops.

7. That you have failed to comply the terms and conditions of

the rent agreement

Therefore, through this legal notice, you are hereby advised

to vacate the rented shops within one month after the
receipt of this legal notice, otherwise my client will initiate
legal proceedings against you at your risk and costs.

SARDAR TARIQ MEHMOOD

Advocate High Court
Rawalpindi
Note:-
 Original Notice is sent to you Mr. Imran and Samraan whereas a copy of this
legal notice is sent to you Mr. Malik Waseem.

 A copy of this legal notice is retained in my office for record and further
proceedings.

1.

2.

3. That you entered into an agreement dated 24-03-2016 with my

client for purchase of Plot BUP No. 86/5 situated at Mouza
 Sorian, Tehsil and District Islamabad against total sale
consideration of Rs. 26,00,000/- and a sum of Rs. 10,00,000/-
was fixed as earnest money.

4. That you paid earnest money of Rs. 500,000/- in cash and a

Cheque bearing No. 36704589 amounting to Rs. 500,000/- dated
04-04-2016, Habib Bank Ltd, Sector G-13 Branch Barkat Plaza,
Islamabad to my client. On presentation the said cheque was
dishonoured due to insufficient funds in your account.

5. That it was agreed between you and my client that you will paid
the remaining amount of Rs. 16,00,000/- to my client within two
months and grace period of 15 days was also given to you and
my client will transfer the above said plot in your name after
receiving the remaining amount but you have no paid the
remaining sale consideration amount to my client within
stipulated period. Moreover your aforesaid cheque was also
dishonoured, therefore you have failed to perform your
obligations as per terms and conditions of the aforesaid
agreement and have committed breach of agreement.

6. That as per terms and conditions of the agreement, my client is

no more bound to deal with you and your earnest money of Rs.
500,000/- is forfeited in favour of my client but keeping a
sympathetic heart, my client wants to give you a final chance to
fulfill your part of contractual obligations.

In view of above you are hereby adviced to perform your complete

part of contractual obligations and pay the total outstanding
amount of Rs. 21,00,000/- to my client within Seven days of the
receipt of this legal notice, otherwise your earnest money would
be confiscated as per the terms and conditions of the agreement
and the agreement stands cancel and further you will also
responsible for any legal proceedings in case of non reply of this
legal notice.
To:
Col (R) Muhammad Nazar
President Federal Employees Cooperative Housing Society
Islamabad.
PO Box No. 2285, Islamabad.

Subject: Legal Notice

That my client Sardar Tahir Mehmood son of Sardar Sakhi

Muhammad Khan, resident of House No. 398, Street No. 73, Sector F-
11/1, Islamabad, has instructed me to serve you the following legal
notice:-

1. That my client applied for allotment of plot in your society and in

this regard my client deposited all the dues and other
miscellaneous charges/expenses so that plot could be allotted in
the society.

2. That the payment schedule as prescribed in the allotment letter

was as under:-

(i) First Installment of Rs. 1,83,334/- on 26-01-2009.

(ii) 2nd Installment of Rs. 1,83,334/- on 26-05-2009.
(iii) 3rd Installment of Rs. 1,83,334/- on 26-09-2009.

3. That vide letter No. FECHS/20(30X60)/JG-I(Ext)/08 dated 26-09-

2009 you issued my client a provisional allotment letter for
residential plot at Jinnah Garden Phase-I (Ext) Islamabad in which
the plot number was not mentioned as there it was mentioned in
shape of “NIL”.

4. That despite depositing all the due amounts to the Society, my

client was not told by you the number of plot which was allotted to
him. Later on, in the year 2015 my client was told by the Society
that he was allotted a Plot No.36, Street No.284, Jinnah Garden,
Phase-I (Ext).

5. That when my client visited the place of plot as shown and allotted
by your society in the letter, it came to the knowledge of my client
that no plot as numbered and location is in fact available or
existing on the spot, which is mis-commitment and fraud on your
 part not only with my client but also with the General Public as
there are a number of other such affectees.

6. That all installments with regard to the payment of above said plot
is with you which my client deposited as a Trust money because
the relationship between the Society and the client is a relationship
of trust, so your Society and you collectively misappropriated the
amount of my client for your own benefits resultantly my client is
standing no where.

7. That since 2009, my client is in hope of allotment of plot with

possession from the Society but now it revealed that you and your
society continuously been playing fraud with my client and
misappropriated all his hard earning money which was deposited
with you as Trust.

Therefore, through this legal notice, you are hereby advised to allot
a plot with specific possession to my client within a period of 15
days, otherwise my client would have a right to initiate criminal
and civil proceedings against you and your society before the
forums/courts of competent jurisdiction at your risk and costs.

SARDAR TARIQ MEHMOOD

Advocate High Court
Rawalpindi
Note:-
 A copy of this legal notice is sent to Director General National Accountability
Bureau.
 A copy of this legal notice is sent to Director General Federal Investigation
Agency.
 One copy of this legal notice is retained in my office for record and necessary
proceeding.
 CERTIFICATE

It is certified that MR. RABIA NAQVI D/O SYED ZULFIQAR

ABBAS NAQVI is known to me since last 02 years. She is having

a good moral character and a Fit person to be enrolled as an

advocate of High Court.

Name: Sardar Tariq Mehmood

Advocate High Court
Rawalpindi

Dated: 29-03-2016
To:
Noor Khan son of Abdul Ghaffar Khan
Presently r/o House No. 1-F/3-CB, 1st Floor near 1-F
Market, Wah Cantt, Tehsil Taxila, District Rawalpindi.

Subject: Legal Notice

That my client Shahid Mehmood Dar son of Muhammad Rafi

Dar, resident of House No. 38/251, Anwar Chowk, POF Wah
Cantt, Rawalpindi, general attorney of Mst. Jamila Naeem Dar
wife of Abdul Naeem Dar, has instructed me to serve you the
following legal notice:-

2. That my client is general attorney of Mst. Jamila Naeem Dar

who is owner/landlady of House No. 1-F/3-CB, near 1-F
Market, Wah Cantt, Tehsil Taxila, District Rawalpindi,
whereas you are tenant in the 1st Floor of said house.

3. That you have taken the above said house (1 st Floor) on rent
of Rs. 8,500/- per month for a period of one year. In this
respect a rent agreement was also executed between you
and Muhammad Rafi Dar in July 2010. Now the rent is Rs.
10,500/- per month.

4. That the owner of the above said house namely Mst. Jamila
Naeem is coming back to Pakistan and the above said house
is required for her residence.

5. That the period of tenancy is also expired and my client did

not want to further extend the tenancy with you.

You are therefore advised to vacate the above said rented

premises within one month from the receipt of this legal
notice otherwise my client has also given me instructions to
 initiate legal proceedings against you before the competent
court of law at your risk and cost.

Sardar Tariq Mehmood

Advocate High Court
Rawalpindi
Note:-
One copy of this legal notice is retained in my office for record and necessary
proceeding.
 SYED WAQAS HAMDANI
Advocate High Court Rawalpindi
Office # 37-G, Madina Block, District Courts Rawalpindi.
Phone # : 0344-8868563

Ref: ___________ Dated: __________

To,
Syed Muhammad Abid s/o Syed Ali Mushafi
R/o House No. H-823, Street No.7, Sector I-9/1,
Islamabad.

Subject: LEGAL NOTICE

On instructions of my client Syed Ali Mushafi, resident of House

No. H-823, Street No.7, Sector I-9/1, Islamabad, I hereby served you
the following legal notice:-

1. That you are younger son of my client, who provided you

education, shelter, food and other necessities of life and brought
up you in a respectful manner and able you to stand on your on
feet and become an active member of the society. My client also
arranged your marriage and also provided a separate portion in
his house for your living.

2. That from the last two years, your behavior has become rude,
non-cooperative, disobedient and misbehaving with my client
and other family members. You many times quarreled,
misbehaved and disrespect my client regardless his status and
relationship. Your said behavior is not only against moral values
but also against the teachings of Islam.

3. That my client tried his level best to tolerate the same but you
have crossed all the limits and now your attitude is intolerable
and my client did not want to keep any contact or relation with
you.
4. That my client is exclusive owner of the above said house where
you are living along with your family without paying any rent/
compensation.

In view of above, you are hereby advised to vacate the house of

my client within 10 days of the receipt of this legal notice,
otherwise my client will initiate legal proceedings against you at
your risk and cost.

SYED WAQAS HAMDANI

Advocate High Court
Rawalpindi

Notes
A copy of this legal notice is retained in my office for record and further
proceedings.

Advocate
To:
Hadayat Khan son of Muhamamd Din Khan, resident of Nalian, Tehsil Palandri,
District Sadhnoti.

Subject: FINAL LEGAL NOTICE

On instructions of my client Ch. Gulzar Ahmed son of Ch. Muhammad Hussain, resident of
Street No. 4, Quaid-e-Azam Colony, Dhamial Camp, Rawalpindi, I hereby served you the following
legal notice:-

7. That you entered into an agreement to sell dated 27-03-2013 with my client for purchase of
Triple Storey House measuring 5 Marlas bearing Khasra No. 1253, situated at Mouza Lakhan
Dehati, Tehsil and District Rawalpindi against total sale consideration of Rs. 57,00,000/- and
you paid earnest money of Rs. 10,00,000/- in presence of witnesses.

8. That it was agreed between you and my client that you were supposed to pay the second
installment of Rs. 10,00,000/- on 05-05-2013 but instead of paying the second installment you
along with 4/5 persons came to my client and tried to harass and pressurize him for handing
over the possession of aforesaid house to you. Your said act was illegal, unlawful and against
the terms and conditions of the agreement. You have also failed to perform your obligations as
per terms and conditions of the aforesaid agreement and have committed breach of agreement.
Therefore a legal notice dated 11-06-2013 was sent to you but you even did not bother to reply
the same which clearly shows your irresponsible attitude and malafide intention.

9. That as per terms and conditions of the agreement, my client is no more bound to deal with
you but keeping a sympathetic heart wants to give you a final chance to fulfill your part of
contractual obligations.

10. That during the said period, the value of property is also increased and we expect you to keep
this point in view because the delay was caused due to your negligence and irresponsible
attitude due to which my client loss may good offers regarding the property and also suffered
financial loss and mental torture. You are also threatening my client for handing over the
possession of the house against the terms and condition of the agreement which act is also
illegal and unlawful.

11. In view of above you are finally given 14 days before 5-10-2013 to perform your complete
part of contractual obligations and pay the total outstanding amount, otherwise your earnest
money would be confiscated as per the terms and conditions of the agreement and the
agreement stands cancel and further you will also responsible for any legal proceedings in
case of non reply of this legal notice.

Nadia Latif Khokhar

Advocate Rawalpindi.
Note:-
A copy of this legal notice is retained in my office for record and necessary proceeding.
Advocate
To:
Mr. Ghulam Mustafa S/o Dost Muhammad, R/o
Street No. 21, Dhoke Banaras, Millatabad near Qadria Mosque, Rawalpindi
Cantt.

Subject: LEGAL NOTICE

On instructions of my client Mr. Sajjad Khan son of Muhammad Rafiq Khan, resident
of 280/D-1, Mohallah Afshan Colony, Rawalpindi, I hereby served you the following legal
notice:-

12. That you entered into an agreement to sell dated 27-12-2011 with my client for
purchase of Plot measuring 2¾ Marlas bearing Khewat No. 37, Khatooni No. 52,
Khasra No. 383, situated at Mouza Misrial, Rawalpindi Cantt against total sale
consideration of Rs. 7,10,000/- and you paid earnest money of Rs. 1,00,000/- in
presence of witnesses.

13. That my client holds special power of attorney in respect of above said plot and has
sole and absolute right to sale the above said plot.

14. That it was agreed between you and my client that you will pay the remaining sale
consideration of Rs. 6,10,000/- on 1st February 2012 and my client will transfer the
above mentioned plot in your name and in case of failure to pay the remaining sale
consideration, your earnest money will be confiscated.

15. That on the agreed date you did not pay the remaining sale consideration to my client,
hence through this legal notice you are hereby informed that your earnest money of
Rs. 1,00,000/- is liable to be confiscated as you have badly failed to perform your

contractual obligations within stipulated time.

BASIT CHAUDHRY
Advocate High Court
LLM (UK)
Cell #: 0333-5102575

Note:-
A copy of this legal notice is retained in my office for record and necessary
proceeding.
Advocate
SYED ZULFIQAR ABBAS NAQVI
Advocate Supreme Court of Pakistan
Office # 24-B1, Back Side Flashmen Hotel, Haider Road,
Saddar, Rawalpindi.
Phone # : 0300-8540881