IN THE HONARABLE COURT OF DISTRICT JUDGE

EAST AT KARACHI

I..D COMPLAINT NO. /2025

Shahid Iqbal S/o Dawood Sharif

Muslim, Adult R/o House No.B.51,

Block E, North Nazimabad, Karachi …………… Complainant

Versus

1. Arslan Ali Abbas S/o Unknown……. proposed Accused

2. SHO P.S Gulistan e Johar…………………… Respondent

APPLICATION UNDER SECTION 3 /4 ILLEGAL

DISPOSSESION ACT 2005.

The above named Complainant respectfully submitt.

1. That the Complainant is peace loving and Law abiding citizen of

Republic of Pakistan as such fundamental rights are guaranteed by
the Constitution of Pakistan 1973.

2. That the complainant is the lawful owner and possessor of Plot

No. LS-05, Block 15, Gulistan-e-Johar, Karachi. The
complainant bought the said plot on 14-10-2020, and since then
has been using all legal rights over the property. The complainant
lives on the first floor of the building and was also in peaceful and
legal possession of the shop on the ground floor.

(Photo stat copy of documents of the said shop filed & marked
annexure (A) )

3. That the accused has filed a civil suit for declaration, which is
Suit No. 2408 of 2024, currently pending before the Court of the
XI Senior Civil Judge, Karachi East. In his written reply to that
suit, the complainant requested the court to appoint a Nazir (court
officer) to visit the property and submit a report about who is in
 possession. The case is still pending, and no final decision has
been given yet.

4. That while the case is still pending in court, the accused, without
waiting for any legal decision, broke the locks of the shop and
forcefully entered it.

5. That the accused, by doing this, violated the law and disrespected
the authority of the court. He illegally removed the complainant
from the shop and allowed an unknown person to settle in it
without any court order or legal right.

6. That the accused is known for such illegal acts and had bad
intentions toward the complainant’s shop. Taking advantage of
the complainant’s absence, he broke the locks and forcefully
entered the shop.

7. That the accused has no legal ownership, right, or title over the
shop. He had no authority to use force or take over the
complainant’s property. His actions are illegal and against the law.

8. That the complainant approached at police station Gulistan e

Johar but no appropriate action against above named accused.
(photo stat copy of Application10-04-2025 is filed and
marked annexure “B”)

9. That the accused have individually and collectively, being land

grabbers, committed and offence punishable under Illegal
Dispossession Act 2005, as they have illegally occupied the house
of complainant and complainant has been deprived of his valuable
property.

10. That there is no other adequate, efficacious and speedy remedy

available for getting justice.

11. That it is therefore humbly prayed that this Honorable court may
be pleased to pass the order as under.
 PRAYER.

It is respectfully prayed that this Honorable Court may kindly

pleased to;

a. Take cognizance of the offence under section 3 of the Illegal

Dispossession Act 2005.

b. Order of restoration of possession to the complainant.

c. Order the registration of an FIR and initiation of criminal

proceedings against the accused for illegal trespass and
dispossession

d. Take cognize against the respondents/ accused, impose the

fine upon the accused of Rs 1,000,000/- or aas the court deems
fit.

e. Any other relif (s) which this Honorable court may deem fit
and proper under the circumstances of the case may be granted
to the complainant in the interest of justice.

Karachi,
Dated: / / 2025 ADVOCATE FOR THE
APPLICANT/ PETITONER.
 IN THE HONARABLE COURT OF DISTRICT JUDGE

EAST AT KARACHI

I..D COMPLAINT NO. /2025

Shahid Iqbal S/o Dawood Sharif

Muslim, Adult R/o House No.B.51,

Block E, North Nazimabad,

Karachi ………………………………..…………… Complainant

Versus

Arslan Ali Abbas S/o Unknown & others……………. Respondent

AFFIDAVIT

I, Shahid Iqbal S/o Dawood Sharif, Muslim, Adult

R/o House No.B.51, Block E, North Nazimabad, Karachi do here
by stat on Oath as under.

1. That the contents of complaint under section 3 / 4 of Illegal

dispossecssion Act 2005, may be treated as part and parcel
of this affidavit.

2. That accused persons have illegally occupied in my shop

and I have been deprived of my valuable property.

3. That whatever stated above is true and correct to the best of

my knowledge and belief.
Karachi
Dated : /07/2025 DEPONENT

IN THE HONARABLE COURT OF DISTRICT

JUDGE WEST AT KARACHI
 COMPLAINT NO. /2021

Muhammad Imran S/o

Muhammad Shakir ………………………… Complainant

Versus

1. Abid Ali S/o Abbas Ali & others…………. Accused.

APPLICATION UNDER SEACTION 7 OF THE ILLEGAL

DISPOSSESSION ACT OF 2005.

The complainant respectfully showth:

On the facts and grounds submitted in accompanying affidavit it

is respectfully prayed on behalf of the complainant above named
that the Hon’ble court may pleased be to pass an order restoring
the physical possession of said House i.e House No. 315, Sector
D-3, Street 13, Baldia Town, Karachi, as it has been establish
from the facts and circumstances of the case the respondents have
illegally, forcibly occupied / possessed the said property without
due course of law and complainant is entitled for interim relief of
restoration of physical possession over the said property till the
final decision of this case as such it is in the interest of justice the
prayer of this application may kindly be allowed.

Prayer is made in broader interest of justice.

Karachi

Datated /01/2021 Advocate for complainant

IN THE HONARABLE COURT OF DISTRICT JUDGE

WEST AT KARACHI
 COMPLAINT NO. /2021

Muhammad Imran S/o

Muhammad Shakir ………………………… Complainant

Versus

1. Abid Ali S/o Abbas Ali & others…………. Accused.

AFFIDAVIT IN SUPPORT OF APPLICATION

I, Muhammad Imran S/o Muhammad Shakir, Muslim,

adult R/o House No. 315, Street No.13, Sector No. D-3, Baldia

Town, Karachi do here by stat on Oath as under.

1. That I say that I am the the complainant in this case and I

am well conversant with the facts of the case, the

accompanying application under section 7, of Illegal

Dispossession Act -2005, has been drafted and filed on my

own instructions and on my behalf contents of said

application as well as main complaint U/S 3 & 4, of the

Illegal Dispossession Act-2005 may be treated as part of

this affidavit for the sake of brevity the contents thereof are

true and correct to the best of my knowledge and belief.

2. That I say that I was in physical possession of the said

property being original and absolute owner and as such I am

 entitled for prime facie case and hence convenience is in my

favor.

3. Unless the application under section 7 of Illegal

dispossession seriously prejudiced.

Whatever stated above is ture and correct to the best of my

knowledge and belief.

Karachi.

Dated / 01/2021 DEPONENT

CNIC

CELL No.

IN THE HONARABLE COURT OF DISTRICT JUDGE

WEST AT KARACHI
 COMPLAINT NO. /2021

Muhammad Imran S/o

Muhammad Shakir ……………………… COMPLAINANT

Versus

1. Abid Ali S/o Abbas Ali& others…………. RESPONDENT

APPLICATION FOR APPOINTMENT OF ENQUIRY

COMMISSION.

It is most respectfully prayed on behalf of the complainant

that this Honerable Court may kindly be appoint Judicial

Magistrate are revenue officer has enquire office to unearth the

factual possession of the House ie House No. 315, Street No.13,

Sector No. D-3, Baldia Town, Karachi.

Whereas SHO Madina Colony is party in complaint and the

respondent have grabbed the house with the collusion of SHO,

hence complainant has serious apprehension that SHO will not

submit the proper report this Hon’ble Court.

Prayer is made to secure the ends of justice.

Karachi

Dated: /01/2021 Advocate for Complainant

IN THE HONARABLE COURT OF DISTRICT JUDGE

WEST AT KARACHI
 COMPLAINT NO. /2021

Muhammad Imran S/o

Muhammad Shakir ……………………… COMPLAINANT

Versus

Abid Ali S/o Abbas Ali & others…………. RESPONDENT

SUPPORTING AFFIDAVIT OF APPLICATION

I, Muhammad Imran S/o Muhammad Shakir, Muslim, adult R/o

House No. 315, Street No.13, Sector No. D-3, Baldia Town,

Karachi do here by stat on Oath as under.

1. That I am deponent of this affidavit as well as such am fully

conversant with the facts stat here in.

2. That I say the accompanying application has been draft and

filed under my instruction, contents whereof are true and

correct to the best of my knowledge and belief and some

may be treated has part and parcel of this affidavit.

3. That this Hon’ble Court may kindly be appoint Judicial

Magistrate or revenue officer as a enquiry officer in above

said complainant.

Whatever stated above is true and correct to the best of

knowledge and belief.

Karachi

Dated: / 01/2021 DEPONENT