IN THE COURT
OF SENIOR CIVIL JUDGE,
1. MUHAMMAD MUSHTAQ son of Muhammad Shafi,
2. Mst. Firdous Begum
3. Mst. Misbah Parveen
Daughters of Muhammad Shafi (deceased).
4. Mst. Musarat Bibi Widow of Muhammad Ashraf son of Muhammad Shafi
5. Muhammad Imran Ashraf
6. Muhammad Irfan Ashraf
7. Muhammad Kamran Ashraf
Plaintiffs No. 5 to 7 sons of Muhammad Ashraf (deceased).
8. Mst. Nafeesa Nadeem D/o Muhammad Ashraf W/o Muhammad Nadeem
9. Mst. Chand Bibi Wd/o Liaqat Ali son of Muhammad Shafi
10. Waqas Ahmad
11. Asad Liaqat
12. Mst. Faiza Ishfaq W/o Muhammad Ishfaq
Plaintiffs No. 10 to 12 sons and daughter of Liaqat Ali (deceased).
13. Mst. Nasreen Wd./o Muhammad Aslam son of Muhammad Shafi (deceased)
14. Adnan Aslam
15. Farhan Aslam
Plaintiffs No. 14 & 15 sons of Muhammad Aslam (deceased).
16. Mst. Zoobia Ismail
17. Mst Ayesha Maqbool
18. Mst. Rubi Aslam
Plaintiffs No.16 to 18 daughter of Muhammad Aslam (deceased).
19. Mst. Musarrat Razzaq Wd./o Abdul Razzaq son of Muhammad Shafi (deceased)
20. Muhammad Umar son of Abdul Razzaq
21. Mst. Sumaira Razzaq
22. Mst. Memoona Irfan
Plaintiffs No. 21 & 22 daughters of Abdul Razzaq (deceased).
All r/o House No.8 Street No.38 Shah Alam Street, Near Masid Arain, Ichhra,
1. Public at Large
and Taxation Department,
SUIT FOR DECLARATION WITH CONSEQUENTIAL RELIEF.
1. That the predecessor-in-interest of the plaintiffs has six sons and two daughters namely Muhammad Mushtaq (plaintiff No.1), Mst. Firdous Begum, Mst. Misbah Parveen (daughters/plaintiffs No.2 & 3), Muhammad Ashraf (deceased) husband of plaintiff No.4 and father of plaintiffs No.5 to 8, Liaqat Ali (deceased son) husband of plaintiff No.9 and father of plaintiffs No.10 to 12, Muhammad Aslam (deceased son) husband of plaintiff No.13 and father of plaintiffs No.14 to 18, Abdul Razzaq (deceased son) husband of plaintiff No.19 and father of plaintiffs No.20 to 22. It is pertinent to mention here that one son namely Gulzar has also died issueless.
the said Muhammad Shafi died on
the predecessor-in-interest of plaintiffs left behind the property No.SXVIII-43-S-8-A,
Circle-I, Zone-IV, Region-A situated at
4. That pedigree table of legal heirs of deceased Muhammad Shafi is on next page.
5. That after the death of Muhammad Shafi, the predecessor-in-interest of plaintiffs, plaintiffs inherited his property mention in para No.3 of the plaint, being his legal heirs according to their legal shares respectively.
6. That the plaintiffs approached the defendant No.2 for transferring the suit property in their names but he refused to do so. The defendant No.2 is legally bound to transfer the said property in the name of plaintiffs according to Sharia Law but the defendant No.2 without any legal justification refused to transfer the said property in the name of the plaintiffs. The defendant No.2 also demanded the decree of court as declaration of legal heirs of deceased, hence this suit.
7. That the cause of action firstly accrued in favour of plaintiffs against the defendant No.2 on 17-08-1992 after the death of predecessor-in-interest of plaintiffs and lastly when the defendant No.2 refused to transfer the suit property in the name of plaintiffs which is still continuing.
the parties reside in
9. That the value of the suit for the purposes of court fees and jurisdiction is fixed at Rs.200/- which is exempt from affixation of court fees.
In view of the above submissions, it is therefore, most humbly prayed that a decree for declaration may very graciously be passed in favour of plaintiffs as legal heirs of deceased Muhammad Shafi in supreme interest of justice, equity and fair play.
It is further prayed that the defendant No.2 may very kindly be directed to transfer the suit property in the name of the plaintiffs in the relevant Departmental Record.
Any other relief which this honourable court deems fit and appropriate in favour of the plaintiffs may also be awarded.
Muhammad Nisar Malik
Advocate High Court
on oath at