CHANGE DATE OF BIRTH IN NADRA CNIC

 

IN THE COURT OF SENIOR CIVIL KARACHI CENTRAL

 

                                                CIVIL SUIT NO:         /20

A                                                                                                         …Plaintiff

 

Versus

 

NADRA,  through its Manager/ Incharge                                             …Defendant

 

SUIT FOR DECLARATION TO CHANGE DATE OF BIRTH IN NADRA CNIC

Respectfully Sheweth,

 

1.      That the plaintiff was born on 08-08-1982 and later on the plaintiff passed his Primary Examination from Shaheen Public Shool  in the year of 2005.

 

2.      That the plaintiff applied for the National Identity Card from NADRA office but inadvertently the date of birth of the plaintiff was mentioned as 16-10-1987 instead of 08-08-1982.

 

3.      That the plaintiff contacted the defendant for the necessary correction in his NIC Card. The defendant earlier asked for submission of duly attested Affidavit from the plaintiff, which was provided accordingly but the defendant refused to take the application of plaintiff on the plea that the plaintiff first should obtain the declaration from the competent court of law.

 

4.      That despite all efforts the defendant is not ready to correct the date of birth of the plaintiff on his ID Card, hence this case.

 

5.      That cause of action finally accrued a few days ago when the defendant refused to entertain the application of the plaintiff which is still continuing.

 

 

6.      That the office of the defendant  is within the territorial limits P/S……… this Honourable Court got the jurisdiction to entertain the matter in hand.

 

7.      That the value of the suit for the purpose of jurisdiction is fixed as Rupees 2000/-, which is exempted from court fee.

 

PRAYER

 

In view of above, it is therefore, most humbly prayed that the suit of the plaintiff may kindly be decreed in favour of the plaintiff

 

a.       Direct the  defendant  to change Date of Birth of the plaintiff as 08-08-1982 instead of 16-10-1987 and after the necessary changing the new I.D Card of the plaintiff may kindly be issued, in the interest of justice.

 

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

 

 

PLAINTIFF

Karachi:

Dated:              /20                                                                   ADVOCATE FOR PLAINTIFF