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| Correction of the name |
Purpose: to get a correct name in the result card/certificate through a court of competent jurisdiction.
Forum: Senior
Civil Judge.
(Name along with parentage and address of the
plaintiff) …Plaintiff
Versus
(To implead
concerned board/university) …Defendants
SUIT FOR
DECLARATION AND MANDATORY-INJUNCTION
Respectfully Sheweth,
That the plaintiff is an educated
lady, who changed her name from Husna Mushtaq to Husna Khan by filling all the
legal and codal fatalities and now according to the National Computerized
Identity Card bearing No. 37407-6862259-9 the name of the plaintiff is Husna Khan d/o Muhammad Riaz. A copy of CNIC is
attached herewith.
That the plaintiff passed the
matriculation and intermediate examinations from defendant No.1’s educational
board vide Roll No. 11111111 in the year 2011 and Roll No. 2222222 in the year
2018 respectively, whereas, the plaintiff also completed her graduation exam under
the supervision of defendant No. 2 vide Roll No. 111112 in the year 2018.
Copies of educational certificates/degrees are attached herewith.
That as the name of the plaintiff
has been changed from Husna Mushtaq to Husna Khan, therefore, the plaintiff wants to change
her name in the educational certificate issued by the defendants, and in this
regard, the plaintiff a number of times approached to the office of the
defendants but they are not ready to change the name of the plaintiff on her
educational certificate without a decree of this Hon’ble court. The plaintiff
already filed a suit for the same purpose, which the same was conditionally
withdrawn by the plaintiff, hence this suit.
That despite all efforts the
defendants are not ready to incorporate the necessary mentioned above
correction on the result card/mark sheets of the plaintiff, hence this case.
That cause of action firstly accrued
to the plaintiff when the plaintiff changed her name and lastly when the
defendants finally refused to entertain the application of the plaintiff for
correction of the name in the educational certificates/degree, which is still
continuing.
That the plaintiff is residing at
Rawalpindi and cause of action accrued at Rawalpindi, hence this Hon’ble court
has jurisdiction to entertain the suit.
That the value of the suit for
the purpose of jurisdiction is fixed as Rupees 2000/-, which is exempted from the
court fee.
PRAYER
In view of the
above, it is, therefore, most humbly prayed that a decree for a declaration to
the effect that the actual and correct name of the plaintiff is “Husna Khan”, and a decree for mandatory
injunction be directed the defendants to correct the name of the plaintiff on
the result intimation cards/degree accordingly and issue fresh result card/degree
to the plaintiff with the correct name of plaintiff i.e. Husna Khan, may kindly be passed in favor of the
plaintiff and against the defendants, in the interest of justice.
Any other
relief which this Hon’ble court deems fit and proper may also be granted to the
plaintiff.
Plaintiff Through counsel
Verification:-
Verified on
Oath at city on this day of month, year, the contents of para 1 to 4 of the plaint are true and correct to
the best of my knowledge, and rest of the paras No.5 to 7 are also believed to
be true and correct.
Plaintiff
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