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| Reply to Contempt Petition format |
In the name of ALLAH, the most beneficent, the most
merciful
IN THE COURT OF MUHAMMAD SAIM SHAHZAD ,
LEARNED CIVIL JUDGE
Saleem
Butt Gujar
Versus
Naqash
Gujar Malik etc
CONTEMPT
APPLICATION U/O 39 RULE 2(3) READ WITH SECTION 151 CPC
WRITTEN
REPLY ON BEHALF OF RESPONDENTS
Respectfully Sheweth:-
PRELIMINARY
OBJECTIONS:-
1.
That the contempt application
is not maintainable not proceedable. The story narrated in the contempt application
is false and frivolous. In fact, respondents are not making any sort of construction
over the suit property in any manner.
2.
That House No. 5454541 bearing
Khasra No. 7744 situated at Street No. 652, Peoples Colony, Tench Bhatta is
already a constructed house, which is now in possession of father of parties.
3.
That the respondent No.1 himself
owner of plot 06 Marlas in same Khasra No. 7744 Peoples Colony, Tench Bhatta
Rawalpindi
4.
That the parities to the
contempt petition are step-brothers inter-se.
5.
That the suit properties were
fraudulently transferred by the applicant/ plaintiff in his own name which was later
on challenged by the father of the parties before competent court of law and
same is pending before the court of Mr. Rao Ejaz, Civil Judge Rawalpindi.
6.
That the instant applicant
has been filed just to pressurize, blackmail and harras the answering respondents
and their father.
ON
1.
Para No. 1 is admitted.
2.
Para No. 2 is denied. The
suit properties were fraudulently transferred by the applicant/ plaintiff in
his own name which was later on challenged by the father of the parties before
competent court of law and same is pending before the court of Mr. Rao Ejaz,
Civil Judge Rawalpindi.
3.
Para No. 3 calls for no
reply.
4.
Para No. 4 cannot be replied for
want of knowledge.
5.
Para No.5 is denied. The
respondent No. 1 is residing in
6.
Para No.6 is denied.
7.
Para No.7 is denied.
8.
Para No.8 is denied.
9.
Para No.9 is denied. All the constructions were made
over the suit property by the father of the parties. Later on, the suit properties
were fraudulently transferred by the applicant/ plaintiff in his own name which
was later challenged by the father of the parties before competent court of law
and same is pending before the court of Mr. Rao Ejaz, Civil Judge Rawalpindi.
10.
Para No. 10 is denied.
11.
Para No. 11 is denied.
12.
In reply to para No. 12, it
is stated that the court should punish those who attempt contempt of court but
in the instant case, the respondents have not committed any contempt of court.
13.
In reply to para No. 13, it
is stated that the court should punish those who attempt contempt of court but
in the instant case, the respondents have not committed any contempt of court.
It is, therefore,
prayed that the contempt application may
be dismissed with costs..
Respondents
Through
Counsel
Advocate High Court