Draft: SUIT FOR DECLARATION TO CHANGE (DATE OF BIRTH) IN NADRA CNIC

 IN THE COURT OF SENIOR CIVIL JUDGE, RAWALPINDI

In the matter of:

U.S___ son of_____Presently resident of H. No. __, _____ Colony, Rawalpindi.

...…Plaintiff

Versus

NADRA, Saddar Branch, Rawalpindi through its Manager/ Incharge.

..…Defendant

SUIT FOR DECLARATION TO CHANGE DATE OF BIRTH IN NADRA CNIC

Respectfully Sheweth,

That the plaintiff was born on 08-08-1980 and later on the plaintiff passed his Primary Examination at Bhalwal School, Sargodha in the year of 2005.

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.

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.

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.

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.

That the office of the NADRA, Rawalpindi is within the territorial limits of this Honourable Court and the plaintiff is temporarily resident at Rawalpindi, so this Honourable Court got the jurisdiction to entertain the matter in hand.

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 and the defendant may kindly be directed 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.

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

Plaintiff

Through

Advocate

Verification:-

Verified on Oath at Rawalpindi on this _____Day of July 2018, the contents of the para 1 to 5 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

*___________________*

Draft: AFFIDAVIT (SUIT FOR DECLARATION TO CHANGE DATE OF BIRTH IN NADRA CNIC)

IN THE COURT OF SENIOR CIVIL JUDGE, RAWALPINDI.

In the matter of:

U.S.M____ son of ___, Presently resident of H. No. __, _____ Colony, Rawalpindi.

.....…Plaintiff

Versus

NADRA, Saddar Branch, Rawalpindi through its Manager/ Incharge.

...…Defendant

SUIT FOR DECLARATION TO CHANGE DATE OF BIRTH IN NADRA CNIC

Affidavit

That I,Abbas khan Sangeen Advocate son of ——Presently resident of H. No. ____, _____ Colony, Rawalpindi.

DO HEREBY SOLEMNLY DECLARE AS UNDER

That the contents of the suit are true and correct to the best of my knowledge and belief and nothing has been concealed therein.

Deponent

Verified on Oath at Rawalpindi On this Day of July 2018. That the above deposition is true and correct to the best of my Knowledge and belief.

Deponent