Application U/S 133 against TMA for cleanliness

       IN THE COURT OF CIVIL JUDGE/JM  K.N SHAH

                                                        Crl. Misc Appl No      2016

                    

Akhtar Ali  son of Haji Rasheed  , adult, Muslim, Arain by caste, Resident of ward No 1 Lakhair muhalla sita Road Taluka K.N Shah District Dadu…………………….……… Applicant.

                          

                                  Versus

1.   Khalid Memon Town Officer (TMA) Sita Road.

2.   Mohammad Hassan Panhwar Clerk.

3.   Fateh Mohammad Inspector.

4.   Noor Hussain Inspector.

5.   Manthar Solangi.Motor operator.

6.   Manzoor Chandio Motor operator.

Resident of Town office Sita Road, Taluka K.N Shah District Dadu.……………………………….…………….….. Opponents.

                     APPLICATON UNDER SECTION 133 CRPC

              It is prayed that this Honourable Court may kindly be pleased to pass conditional order against the above named opponents wherein directing the opponents to supply the water to the inhabitants of the community,to remove the sewage water through the sucker machine, clean the street, remove the hindrances  which is in shape of sewage water in common street of ward: 1 Lakhair muhalla  sita road which has  created public nuisance and depriving the facility of water supply and by stopping the passage of the general public on the consideration of the facts and the grounds mentioned bellow:-

              FACTS AND GROUNDS

1.     That there is common street in sita road ward no:1 lakhair  Muhalla, where the applicant and others are residing and so also there are more than 100 house which are situated in the said street.

2.     That the applicant used to reside at above address, there is no proper drainage system, and there is difficulty of water supply on time, therefore the applicant and other resides of the locality are facing great trouble in this modern age.

3.     That the applicant along with other resident of above colony time and again approached to the opponent for cleaning the street and drainage by taking the water through the sucker machine, but the opponents are not paying any head to it, due to that the street of the colony/ muhalla is under water and giving scene like lake.

4.     That the act of the opponent is against the law for which this Honourable Court may kindly called the opponents and passed such order through which the opponent may be directed to clean the street, resolve the water problem for which the opponents are not entitled to do so under the law.

5.     That the applicant and other inhabitants repeatedly approached to the opponent for taking water but the opponent refused to do so, and due to that there is apprehension of spreading different kinds of syndrome in the colony/muhalla .

6.     That the applicants and others are facing great trouble due to storage of water and opponent is not taking water from street.

7.     That now the applicant has filed the instant application for justice before this Honourable Court.

Dated:                                                     Advocate

                                                          For Applicant