Date of Birth correction in BISE (Plaint)

 

Date of Birth correction in BISE (Plaint)
Date of Birth correction in BISE (Plaint) 

In the name of ALLAH, the most beneficent, the most merciful

 

Draft of Suit for correction of date of birth in BISE record

 

If  you find that your date of birth is incorrectly written in your educational documents (Educational Board record), and request the concerned Educational Board / BISE / Board of Intermediate and Secondary Education but the board does not correct your date of birth in its record, you may file  a suit for correction of date of birth against BISE. The draft of suit is as under:-

 

 

IN THE COURT OF SENIOR CIVIL JUDGE, RAWALPINDI

 

 

Jameel ur Rehman son of Alif Ahmed Malik resident of Jand, P.O Khas, Tehsil and District Chakwal

 

…Plaintiff

Versus

 

Board of Intermediate and Secondary Education, Rawalpindi through its Chairman.  

…Defendant

 

SUIT FOR DECLARATION AND MANDATORY INJUNCTION

 

Respectfully Sheweth,

 

 

1.               That the plaintiff was born on 11-02-1998. His birth certificate was also got issued with the same date of birth i.e 11-02-1998. (copy of birth certificate is annexed herewith).

2.               That this date of birth of plaintiff  was also got incorporated in his Form-B, issued by NADRA. (copy of Form-B is annexed herewith).

3.               That on attaining the  age of majority, the plaintiff applied for obtaining the Identity Card from NADRA, which was issued to him accordingly.  In the Identity Card his date of birth is also written correctly as “11-02-1998”.

4.               That the plaintiff appeared in SSC examination from the Board of  Intermediate and Secondary Education Rawalpindi under roll No. 832517 year 2016 and successfully passed the same.  In this regard, his matriculation Mark Sheet was issued  to plaintiff accordingly.  (Copy of mark sheet is annexed herewith).

5.               That the plaintiff shocked to see that his date of birth was incorrectly written as “15-09-2001” in his above said matriculation mark sheet. In fact, his  correct date of birth is 11-02-1998, which  is as per his all other documents like Birth Certificate, Form-B, Identify Card, Domicile Certificate etc.

6.               That the plaintiff moved an application in the office of defendant, with the request to correct his date of birth in matriculation mark sheet/certificate but the application was rejected the office of defendant, vide letter No. 2961-ASA dated 20-09-2017.

7.               That the act of defendant is illegal and unlawful, against the fact as well law.

8.               That cause of action firstly accrued when the matriculation mark sheet/ certificate of plaintiff was issued,   lastly when his application for correctness of date of birth was rejected by the office of defendant, which is still continuing.

9.               That the office of the defendant is situated within the territorial jurisdiction of this Honourable Court and the plaintiff is also residing at Rawalpindi, hence this Honourable Court got the jurisdiction to entertain the matter in hand.

10.         That the proper court fee has been affixed on the plaint.

PRAYER:

In view of above, it is therefore, most humbly prayed that  following decrees may kindly be passed in favour of plaintiff and against the defendant.

 

1.                                          Declaration to the affect that the correct date of birth of plaintiff’ is “11-02-1998” instead of  15-09-2001.

2.                                          Mandatory injunction, directing  the defendants to correct the date of birth of plaintiff in his matriculation mark sheet/ certificate as “11-02-1998 and after making necessary correction in the record, issue the same to the plaintiff.  

 

Any other relief, which this Honourable Court deems fit and proper may also be granted to the plaintiff.

Plaintiff

Through

 

Counsel

Advocate High Court

VERIFICATION:-

Verified on Oath at Rawalpindi on this ___Day of April, 2018 , the contents of the para  1 to 7  of the suit the suit are true and correct to the best of my knowledge and rest of the paras are believed to be true and correct as per information received.

 

Plaintiff



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