Suit for Correction of Date of Birth in Domicile Certificate

Suit for Correction of Date of Birth in Domicile Certificate 

 

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

 

IN THE COURT OF SENIOR CIVIL JUDGE, RAWALPINDI

 

Zabeeb Ahmed Khan Jan son of Nabeel Jani R/O Mera Bukhsh, Jahndi Mor, Rawalpindi

 

…Plaintiff

Versus

 

Deputy Commissioner, Rawalpindi

…Defendant

 

SUIT FOR DECLARATION AND MANDATORY INJUNCTION

 

Respectfully Sheweth,

 

 

1.            That the plaintiff was born in the on 06-06-2003. On attaining the age of majority, the Identity Card of plaintiff was applied for, which was issued to him bearing CNIC No. 37405-5555555555-7.

 

2.            That in the year 2020, the plaintiff appeared in  Secondary School Certificate Examination 2020 from Federal Board of Intermediate and Secondary Education, Islamabad, which  he successfully passed and he was issued Secondary School Certificate on 24-07-2020.

 

3.            That the plaintiff also applied for Domicile Certificate, which was issued to him on 23-08-2019 bearing Domicile No. RWP-8-2019-129. In the said Domicile Certificate, the date of birth was wrongly mentioned as 06-06-2000.  In fact, the correct date of birth of plaintiff is 06-06-2003  which is reflecting in his CNIC and Secondary School Certificate. (copies of Domicile Certificate along with CNIC and SSC are annexed herewith for your kind perusal)  

 

4.            That the efforts were made by the plaintiff for correction of his date of birth in Domicile Certificate by way of approaching the office of defendant, but all his efforts went in vain, hence this suit.  

 

5.            That cause of action firstly accrued on 23-08-2019, when plaintiff was issued Domicile Certificate with incorrect date of birth and lastly when plaintiff’s efforts for correction of  his date of birth were went in vain, which is still continuing.

 

6.            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.

 

7.            That the prescribed Court fee has been affixed on the plaint.

 

PRAYER:

 

In view of above, it is therefore, most humbly prayed that  a decree for the following:

 

1.                                Declaration to the affect that the correct the date of birth of plaintiff is “06-06-2003” as reflecting in his CNIC and Secondary School Certificate.

 

 

2.                                Mandatory injunction, directing the defendant to correct the date of birth of plaintiff in his record and after making necessary correction issue fresh domicile Certificate to plaintiff.

 

may kindly be passed in favour of  plaintiff and against the defendant.

 

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 September 2022 the contents of the para  1 to 4  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