Summary: Not always but invariably the limitation is found to be mixed question of law and fact.

Summary: ----First Sched., Art. 164---Civil Procedure Code (V of 1908), O. IX-- -Setting aside ex-parte decree---Limitation---Once a person appears, participates in proceedings, submits written statement and later on absents himself from proceedings, which results into ex-parte decree, application for setting aside of such ex-parte decree will have to be submitted within a period of thirty days as provided in Art. 164 of the Limitation Act, 1908. Shahid Pervez alias Shahid Hameed v. Muhammad Ahmad Ameen 2006 SCMR 631 ref. (b) Civil Procedure Code (V of 1908)--- ----S. 12(2) & O. IX, R. 13---Dismissal of suit in default---Application for recalling of dismissal order---Dismissal of said application for non-prosecution---Subsequent application under S. 12(2) of C.P.C.---Maintainability---When the remedy under O. IX, R. 13, C.P.C. was availed and the application was dismissed for non-prosecution, the petitioner was required to submit the application for restoration of the application which was dismissed for non-prosecution, but he filed the application and had sought setting aside ex-parte decree through revival of the suit by filing an application under S. l2(2), C.P.C.---Application under S. 12(2), C.P.C. and revival of suit in consonance with sub-clause (2) of S. 12 is for an aggrieved person but on the ground of fraud, mis-representation and want of jurisdiction---Application under S. l2(2), C.P.C was not a substitute for the application for setting aside decree under O. IX, R. 13, C.P.C., rather grounds of the application under S. 12(2) C.P.C., were different to the application, which could be seen and adjudged within the four corners provided by the legislature---No doubt, suit of the respondent/plaintiff had been decreed against the petitioner ex-parte but due to lethargic attitude of the petitioner/defendant---Record also reflected that the suit of the plaintiff for recovery of a specific amount was also dismissed for non-prosecution---No doubt, in appropriate cases, application filed under S. l2(2), C.P.C., required submission of written reply, framing of issues and recording of evidence but not in each case, as it depended upon facts and circumstances of each case---Revision was dismissed with costs accordingly. Amina Bibi through General Attorney v. Nasrullah and others 2000 SCMR 296; Mrs. Anis Haider v. S. Amir Haider and others 2008 SCMR 236 and Ghulam Muhammad v. Ahmed Khan 1993 SCMR 662 ref. (c) Civil Procedure Code (V of 1908)--- ----S. 12(2)---Dismissal of suit in default---Application for recalling of the dismissal order---Dismissal of said application for non-prosecution- --Subsequent application under S. 12(2) of C.P.C.---Application under S. 12(2) of C.P.C was concurrently rejected---Pendency of revision petition before the High Court for a long time due to conduct of revision petitioner---Effect---Costs, imposition of---High Court observed that frivolous litigations are initiated by parties without any locus standi---Present case was one of the classic examples where present application remained pending before this (High) Court for the last six years where on each date, the petitioner requested adjournment---On one hand, frivolous litigation may cause and increase the backlog and on the other hand, it creates hurdle in smooth administration of justice and for such like matters it was held time again by the Superior Courts that incompetent petition requires its burial from its inception---Petitioner had availed remedy under O. IX, R. 13 and lastly, he filed application under S. 12(2), C.P.C. which was not maintainable---Hence, it was rightly dismissed by the lower Court---In wake of the conduct of the petitioner for the last six years, costs of Rs. 50 000/- was imposed on him, to be recovered by the Executing Court along with decreetal amount---Revision was dismissed with costs accordingly. Nemo for Petitioner Ms. Neelam A. Khan for Respondents. Date of hearing: 1st August, 2024.

Summary: ----Quote: a. Period of limitation for filing an application for setting aside exparte decree would be governed by Article 164 of Schedule-II of Limitation Act. In both the cases where a defendant does not turn up in response to a summon or he is proceeded exparte after appearing in the court. The maximum period in such cases shall be treated as 30 days. b. Where a party to litigation makes abuse of the process of court and deliberately withheld appearance in court then imposition of the penal clauses imposed against him under CPC, Should not be lightly lifted or same should be done with levy of reasonable and substantial cost, sufficient for compensating the opposite party for the wastage of money and time spent on such litigation as well as for the inconveniences caused to him by tactics employed by the defaulting party deliberately. ----Background: The respondents filed a suit for possession through partition, seeking their share in a jointly owned house. The house was originally owned by the respondents' predecessor, and upon her death, the property devolved to her legal heirs. The petitioners, who were also co-owners, contested the suit by claiming that the house had been gifted to them and that the respondent had sold her share to one of the petitioners through an unregistered sale deed. The petitioners, however, were subsequently absent from the court proceedings, leading to an ex-parte decree in favor of the respondents. The petitioners' subsequent application to set aside the ex-parte decree was dismissed by the trial court and the appellate court, leading to the current civil revision. ----Issues: 1- Whether the application to set aside the ex-parte decree was barred by the law of limitation. 2- Whether the ex-parte decree was void due to the petitioners' claims of purchase and lack of discussion in the final order. ----Holding/Reasoning/Outcome: The court dismissed the civil revision, affirming the decisions of the lower courts. The court held that: The application to set aside the ex-parte decree was indeed barred by the law of limitation. The relevant limitation period was 30 days as per Article 164 of the Limitation Act, 1908. The petitioners filed their application nearly two years after the ex-parte decree, far beyond the prescribed period. The court also rejected the argument that the ex-parte decree was void. It was established that the petitioners had knowledge of the proceedings but chose to remain absent. The decree was based on sufficient evidence, including the registered deed in favor of the respondents' predecessor, while the petitioners failed to substantiate their claims with evidence. The court emphasized that leniency in setting aside ex-parte orders should be exercised cautiously to prevent abuse of the legal process. The court also highlighted the importance of imposing reasonable costs to deter delaying tactics in litigation. ----Citations/Precedents: Syed Arshad Ali vs. Said Ali (2018 YLR 779) Shah Qaimoos Khan and 4 others vs. Faizullah Khan and another (2020 CLC 111) Messrs Rehman Weaving Factory (Regd) Bahawalnagar vs. Industrial Development Bank of Pakistan (PLD 1981 SC 21) Honda Atlas Cars (Pakistan) Ltd vs. Honda Sarhad (Pvt) Ltd and others (2005 SCMR 609) Shahid Pervaiz alias Shahid Hameed vs. Muhammad Ahmad Ameen (2006 SCMR 631) Kiramat Khan vs. IG, Frontier Corps and others (2023 SCMR 866) Chief Executive Officer NPGL, GENCO-III, TPS, Muzafargarrah vs. Khalid Umar Tariq Imran & others (2024 SCMR 518)

Summary: ----Quote: Limitation Act had not been earlier extended to erstwhile FATA and cannot be applied before the date of merger i.e. 31.05.2018; but same would have its application thereafter. the Act be given a retrospective effect, however, the law will have its effect from the date of its deemed application after 31. 05.2018 ----Background: A land dispute arose between the parties in Tehsil Pindiali. The respondent claimed ownership of the land, stating that it was purchased 15 years ago, while the petitioners contested this claim. The dispute was initially brought before the Assistant Political Agent (APA), where a jirga (council of elders) was formed to resolve the matter. The jirga ruled in favor of the respondent, a decision that was subsequently upheld by the APA, the Commissioner FCR, and the FATA Tribunal. The petitioners' appeals and review petitions were dismissed at each stage, leading to the current civil revision after the merger of FATA with Khyber Pakhtunkhwa. ----Issues: 1- Whether the execution petition filed by the respondent was time-barred under the Limitation Act of 1908. 2- Whether the judgment and decree were executable without proper identification and description of the disputed property. ----Holding/Reasoning/Outcome: The court dismissed the civil revision, affirming the decisions of the lower courts. The court held that: The limitation period began with the merger of FATA into Khyber Pakhtunkhwa, making the execution petition timely. The identification of the property by the jirga, which included a representative nominated by the petitioners, was sufficient and unchallenged. The court noted that the procedures followed under the Frontier Crime Regulation (FCR) were different from regular civil procedures, and the lack of detailed property descriptions did not invalidate the execution. The petitioners were provided ample opportunity to contest the identification of the property, and their failure to produce additional evidence at the appropriate time did not warrant the reversal of the lower court's decision. ----Citations/Precedents: National Commission on Status of Women through Chairperson vs. Government of Pakistan (PLD 2019 S.C 218) 25th Constitutional Amendment to the Constitution of Islamic Republic of Pakistan, 1973

Summary: Background: The Respondent initiated a suit for recovery amounting to PKR 32,285,308/- before the Civil Judge 1st Class, Rawalpindi, on September 16, 1991. The claim was based on a contract (No. CEA-125/87) for the provision and installation of POL Cylindrical Steel Tanks at Quetta, agreed with the Appellants through the DW&CE (Army) Branch, Rawalpindi, in December 1986. The contract valued at PKR 14,296,501/- was to be completed within 12 months from the issuance of the first written work order dated January 17, 1987. The work commenced after delays in site handover and provision of layout plans, leading to substantial losses for the Respondent. Despite several changes and delays attributed to both parties, the project was completed on May 19, 1991, and the Respondent sought recovery due to delays and additional costs. ----Issues: 1- Whether the suit for recovery was barred by the limitation period. 2- Whether the delays in completing the contract were attributable to the Appellants or the Respondent. 3- Whether the Respondent was entitled to recover the claimed amount due to the delays and changes in the contract terms. ----Holding/Reasoning/Outcome: The trial court decreed the suit in favor of the Respondent for PKR 99,35,373/- with costs and interest at 10% per annum until the realization of the decree, provided a three-month grace period for satisfaction of the decree. The Appellants challenged this decision before the Lahore High Court, which dismissed their appeal, affirming that the delays were primarily due to the Appellants' failure to provide necessary materials and drawings in time. The present appeal before the Supreme Court resulted in a reversal of the High Court's decision. The Supreme Court found concurrent delays attributable to both parties and emphasized the principle of "concurrent delays," where each party contributed to the delays. The Court also found the Respondent’s recovery proceedings to be a retaliatory measure to avoid refunding an overpayment identified in a post-payment audit. Thus, the appeal was allowed, and the decrees of the lower courts were set aside, with each party bearing its own costs. ----Citations/Precedents: Henry Boot Construction (UK) Limited v. Malmaison Hotel (Manchester) Limited (1999) 70 Con LR 32 Adyard Abu Dhabi v. SD Marine Services [2011] EWHC 848 (Comm) United Bank Limited v. Jamil Ahmed (2024 SCMR 164) Nazim-ud-Din v. Sheikh Zia-ul-Qamar (2016 SCMR 24) A. Rahim Foods v. K&N’s Foods (2023 CLD 1001) Society of Construction Law Delay and Disruption Protocol, 2nd Edition

Summary: (a) Constitution of Pakistan: ---Arts. 17(2), 51(6)(d) & (e), 63, 65, 106(3)(c), 184(3), 185(3), 224(6); Elections Act, 2017, Ss. 66, 67, 104 & Election Rules, 2017 Allocation of reserved seats for women and non-Muslims—Scope—Constitutional validity of Election Commission of Pakistan’s (ECP) Order dated 01.03.2024 and its notifications declaring returned candidates on reserved seats—Maintainability—Sunni Ittehad Council (SIC), not having contested the General Elections 2024 or submitted any priority list for reserved seats, claimed entitlement to such seats based on independent candidates joining it post-election—Held, SIC did not fulfil constitutional or legal prerequisites to claim allocation of reserved seats under proportional representation system; did not contest elections or secure any general seat—ECP’s order and relevant notifications, insofar as they excluded PTI-affiliated candidates from the seat count, were declared ultra vires the Constitution and set aside—Supreme Court by majority held that PTI remained a political party under the law, and candidates declaring PTI affiliation in their nomination forms and supported by party certificates were to be treated as PTI members for purposes of seat allocation—Denial of election symbol did not affect right of a political party to field candidates or participate in elections—PTI held entitled to proportionate allocation of reserved seats based on its actual electoral success—Constitutional obligation imposed on ECP to recalculate and notify reserved seats for PTI accordingly—Petitions of SIC dismissed. Cited Cases: • Workers' Party Pakistan v. Federation of Pakistan PLD 2012 SC 681 • Benazir Bhutto v. Federation of Pakistan PLD 1988 SC 416 (b) Constitutional Law: ----Arts. 51(6)(d) & (e), 106(3)(c), 63-A, 226 Interpretation of proportional representation—Returned candidates declared independent by ECP despite nomination as PTI members—Held, candidates who submitted nomination papers declaring PTI affiliation and did not contradict said declaration prior to withdrawal deadline must be treated as PTI members—Declaration by ECP that such candidates were independent held without lawful authority—Court declared that under constitutional provisions, party-list based allocation of reserved seats must reflect the true will of electorate and should not be frustrated by technicalities—Failure of ECP to recognize valid PTI candidatures undermined representational justice and electoral integrity. (c) Representation and Electoral Rights: ----Elections Act, 2017, Ss. 66, 67, 104; Election Rules, 2017 Submission of party lists and affidavits—ECP required to apply statutory provisions in a manner giving full effect to constitutional rights—Court directed ECP to issue notice to 41 other returned candidates (who were declared independent but declared PTI affiliation in part) to file notarized statements confirming party affiliation, with PTI granted opportunity to confirm such claims—Held, such mechanism would determine true number of general seats secured by PTI, entitling it to reserved seats accordingly—Court ordered timely publication of list and compliance report by ECP—Reserved seats not to remain vacant under Article 224(6), and must be filled to preserve parliamentary representativeness. (d) Constitutional Jurisdiction and Limitation: ----Arts. 184(3), 185(3), 175 Scope of Supreme Court’s power in electoral matters—PTI was not a party to the original proceedings before the ECP or High Court—Minority view emphasized that majority judgment extended beyond Court’s constitutional jurisdiction under Art. 185(3)—Concerns raised that judicial relief was granted to a non-party, creating enforceable rights in absence of lis—Joined candidates were not heard, and allocation affected without affording audi alteram partem—Held (minority), that such judicial overreach may result in constitutional violations and consequences for oath-bound office holders—Majority nevertheless exercised jurisdiction under Art. 184(3) to enforce fundamental representational rights.

Summary: Background: Faysal Bank Limited (FBL) filed a suit (No. 78/2012) before the Banking Court No.II, Karachi under the Financial Institutions (Recovery of Finances) Ordinance, 2001 (FIO, 2001) for recovery of finances extended to the appellants. The Banking Court granted unconditional leave and framed five issues, eventually passing a judgment on 06.09.2023 followed by a decree on 26.09.2023. ----Issues: 1- Whether the appeal against the judgment of the Banking Court is barred by time. 2- Whether the appeal should be filed against the judgment alone without waiting for the decree. 3- Whether the appeal filed against both the judgment and decree is within the limitation period. ----Holding/Reasoning/Outcome: The primary objection by the respondent's counsel was that the appeal is barred by time, as it was filed after the judgment and not immediately upon the issuance of the judgment. The respondent's counsel relied on the case of First Pakistan Security Limited, arguing that the appeal should have been filed within 30 days of the judgment. The court examined the Financial Institutions (Recovery of Finances) Ordinance, 2001, and the interpretation of Section 22(1) regarding the timing of filing an appeal. The court found that the scheme of the 2001 Ordinance requires the decree to be part of the appeal process in civil matters, and waiting for the decree does not render the appeal time-barred. The court, assisted by the amicus curiae, concluded that an appeal must be filed against both the judgment and the decree. The time consumed in obtaining the decree should be excluded from the limitation period, ensuring the appeal is within the permissible timeframe. On the merits of the case, the court addressed the issues framed by the Banking Court: The appellants failed to prove that they did not utilize the Term Finance Facility. The statement of accounts fulfilled the requirements of the Bankers’ Books Evidence Act, 1891. The appellants had admitted to availing of two financial facilities, and the partial denial was immaterial. The evidence supported that the appellants had availed and utilized the finance facilities as claimed by Faysal Bank. The appeal was found to be filed within the limitation period and was maintainable. However, on the merits, the appeal was dismissed. The court upheld the Banking Court's judgment and decree, confirming the recovery of finances extended to the appellants by Faysal Bank. ----Citations/Precedents: First Pakistan Security Limited v. Bank Alfalah Limited (2020 CLD 269) Directorate of Small Industries, Govt. of Baluchistan v. Civil Aviation Authority (1993 MLD 1836) Multiline Associates v. Ardeshir Cowasjee and others (1995 SCMR 362) Chaudhary Pervez Elahi v. Deputy Speaker, Provincial Assembly of Punjab, Lahore and others (PLD 2023 SC 539) Yousaf Garments v. Grindlays Bank (1988 CLC 1214) Bank of America v. Alam & Bros and 6 others (1984 CLC 3393) Sevak Jeranchod Bhogilal and others v. The Dakore Temple Committee and others (AIR 1925 Privy Council 155) H. H. S Feldman v. Province of East Bengal (PLD 1970 Karachi 295) Pakistan Television Corporation Limited v. Commissioner Inland Revenue (Legal), LTU Islamabad and others (2017 PTD 1372) Micro Innovations and Technologies (Pvt.) Ltd. v. Federation of Pakistan and 4 others (2023 PTD 742) Messrs Master Foam (Pvt.) Ltd. and 7 others v. Government of Pakistan through Secretary, Ministry of Finance and others (PLD 2005 SC 373) Cooperative Insurance Society of Pakistan Limited, Karachi and others v. State Life Insurance Corporation of Pakistan, Karachi and 12 others (1999 SCMR 2799)

Summary: Amanat Ullah Khan, the appellant, contested the judgment and decree dated 14.03.2019 passed by the Civil Judge, Islamabad. The appellant's suit, filed on 11.09.2004, sought a declaration of ownership of Plot No.1, Street No.47, Sector F-8/1, Islamabad, and the cancellation of transfer letters dated 18.06.1977 and 07.05.1987 by the Capital Development Authority (CDA), which transferred ownership of the property to respondent No.1 and subsequently to Javed Akhtar, predecessor of respondents No.2-a to 2-e. ----Issues: 1. Whether the transfer of half share in the suit property from the appellant, a minor at the time, to respondent No.1 was valid. 2. Whether the appellant's suit was time-barred. 3. Whether the transactions in question were fraudulent. 4. Whether the appellant had a cause of action or locus standi to file the suit. ----Holding/Reasoning/Outcome: Holding: The court held that the transfer of half share in the suit property from the appellant to respondent No.1 was valid, as it was done by the appellant's father, his natural guardian. The suit was also found to be time-barred. Reasoning: The court reasoned that the appellant's father had the authority to act on behalf of the minor appellant, and no fraud was established in the transfer. The appellant failed to provide evidence of fraud or explain the delay in challenging the transfer. The court also noted that the appellant's failure to produce his father as a witness was detrimental to his case. Outcome: The appeal was dismissed with costs. The appellant was ordered to pay Rs. 5,15,000 to respondents No.2-a to 2-e for litigation costs and an additional Rs. 10,00,000 under Section 35(1)(iii) of the Code of Civil Procedure, 1908. ----Citations/Precedents: Ghulam Nabi Vs. Faisal Naveed (2003 SCMR 1794) Abdul Ghani Vs. Yasmeen Khan (2011 SCMR 837) Sultan Vs. Muhammad Hussain (2006 MLD 659) Muhammad Umar Khan Vs. Aziz Begum (2001 MLD 448) Aamir Masood Vs. Khurshid Begum (2001 MLD 159) Muhammad Adil Vs. Muhammad Amir (2023 SCMR 1032) Muhammad Haneef Vs. Abdul Samad (PLD 2009 SC 751) Manzoor Hussain Vs. Muhammad Nawaz (2010 SCMR 1042) Allah Bukhsh Vs. Bakhtawar (2018 CLC 1070)

Summary: Background: M/s. Sui Northern Gas Pipelines Limited (appellant) filed a Regular First Appeal (RFA) seeking condonation of delay in filing an appeal against the consolidated judgment and decree dated 17.03.2022 passed by the Additional District Judge, Faisalabad. The appellant's suit for recovery of Rs.12,19,57,918/- was dismissed, while the respondent's (M/s. Bhatti Fabrics) suit for declaration, mandatory, and permanent injunction was decreed. The appeal was filed after the prescribed period, and the appellant sought condonation of the delay under Section 5 of the Limitation Act, 1908. ----Issues: 1- Whether the delay in filing the appeal should be condoned under Section 5 of the Limitation Act, 1908. 2- Whether the provisions of the Limitation Act, 1908 apply to a case governed by the Gas (Theft Control and Recovery) Act, 2016. 3- Whether the appeal was filed within the prescribed period of limitation. ----Holding/Reasoning/Outcome: ---Condonation of Delay: The court noted that the appeal was initially filed on 07.05.2022, within the limitation period. However, the office raised objections, and the appeal was re-filed on 08.06.2024, after a delay of over two years. The appellant's reason for the delay was that the case file was misplaced and mixed up with other files. The court found this explanation insufficient and unconvincing. ---Applicability of the Limitation Act, 1908: The court held that the Gas (Theft Control and Recovery) Act, 2016, which is a special law, provides a limitation period of 30 days for filing an appeal. Therefore, the provisions of the Limitation Act, 1908, a general law, do not apply. The court emphasized that special laws take precedence over general laws. ---Limitation Period: The court found that the appeal was filed after a substantial delay, and the appellant failed to remove the office objections within the stipulated time. The court ruled that the statutory remedy of appeal cannot be left open indefinitely, and the delay in re-filing the appeal was not justified. The court dismissed the application for condonation of delay and the appeal itself as time-barred. The court also expressed concern over the negligent conduct of the appellant's officers and officials, which led to the delay and potential monetary loss to the company. The Managing Director of Sui Northern Gas Pipelines Limited was directed to conduct a thorough inquiry and take action against the responsible officers and officials. ----Citations/Precedents: Gulistan Textile Mills Ltd. and another Vs. Soneri Bank Ltd. and another (2018 CLD 203) Messrs MCB Bank Ltd. Vs. Commissioner Inland Revenue (2014 PTD 1874) Asad Ali and 9 others Vs. The Bank of Punjab and others (PLD 2020 SC 736) Lahore Development Authority v. Muhammad Rashid (1997 SCMR 1224) Zulfiqar Ahmad Vs Malik Sarfraz (deceased) through his L.Rs., etc. [C.P.No.1334-L/2021] Ainuddin and others Vs. Abdullah and another (2019 SCMR 880) Shahid Pervaiz alias Shahid Hameed v. Muhammad Ahmad Ameen (2006 SCMR 631) Messrs Blue Star Spinning Mills Ltd. VS Collector of Sales Tax and others (2013 SCMR 587) Ghulam Hussain Ramzan Ali VS Collector of Customs (Preventive), Karachi” (2014 SCMR 1594) Ashiq Hussain Sabri Vs Secretary Health, Government of the Punjab & 8 Others (PLD 2011 Lahore 490 (D.B)) Muhammad Din Vs Abdul Ghani & Another (2012 SCMR 1004) ----Quote: Appeal under Section 13 of the Gas (Theft Control and Recovery) Act, 2016--- Period of filing such appeal is 30 days. Applicability of Section 5 of the Limitation Act, 1908--- Appeal initially filed within time--- Office raised certain objections granting 3 days' time to remove said objection---Appeal re-filed after 749 days with application under Section 5 of the Limitation Act? Held that Section 5 of the Limitation Act is not applicable to proceedings under special enactment, wherein a specific period of limitation is provided--- Special Law always takes preference over the general law. Appeal dismissed being barred by limitation? Court ordered for holding of inquiry and recovery of the amount of claim in the suit from the delinquent officials of the appellant company.

Summary: (a) Limitation Act, 1908: ----Art. 120—Limitation—Declaratory relief—Correction of date of birth—Accrual of cause of action—Scope—Petitioner sought correction of her date of birth from 05.03.1987 to 05.03.1997 in her CNIC, SSC, HSSC, and Detailed Marks Certificate—Trial Court and Appellate Court dismissed suit as barred by limitation, holding limitation commenced from date of issuance of SSC certificate—Held, limitation under Art. 120 begins from when right to sue accrues—In such cases, right to sue accrues either upon knowledge of incorrect entry or upon refusal by competent authority to correct it—Petitioner produced Form No. 3 and verified school documents indicating true date of birth, which remained undisputed—Limitation thus computed from refusal by respondent, not issuance of certificate—Suit filed within six years from such refusal—Precedents from PLD 1988 Lahore 658 and 2019 YLR 2354 followed—Suit not time-barred. (b) Civil Procedure Code (V of 1908): ----S. 96—Appeal—Findings based on misapplication of limitation law—Scope of interference—Where lower courts erroneously interpret commencement of limitation period and ignore undisputed documentary evidence, interference by revisional court is warranted—Findings set aside, and declaratory relief granted in favour of petitioner. (c) Evidence Act (Qanun-e-Shahadat Order, 1984): ----Admission—Undisputed documents—Legal effect—Where respondent authorities did not challenge documentary evidence (e.g., school admission register showing date of birth), such documents deemed admitted—Petitioner’s evidence sufficiently established her correct date of birth as 05.03.1997. Revision allowed.