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IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

      Civil Suit No.___________/2012

1. MUHAMMAD MUSHTAQ son of Muhammad Shafi,
2. Firdous Begum
3. Misbah Parveen

Daughters of Muhammad Shafi (deceased).

4. 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. Nafeesa Nadeem D/o Muhammad Ashraf W/o Muhammad Nadeem
9. Chand Bibi Wd/o Liaqat Ali son of Muhammad Shafi
10. Waqas Ahmad
11. Asad Liaqat
12. Faiza Ishfaq W/o Muhammad Ishfaq

Plaintiffs No. 10 to 12 sons & daughter of Liaqat Ali (deceased).

3. Nasreen Wd./o Muhammad Aslam son of Muhammad Shafi (deceased)
4. Adnan Aslam
5. Farhan Aslam

Plaintiffs No. 14 & 15 sons of Muhammad Aslam (deceased).

6. Zoobia Ismail
7. Mst Ayesha Maqbool
8. Rubi Aslam

Plaintiffs No.16 to 18 daughter of Muhammad Aslam (deceased).

9. Musarrat Razzaq Wd./o Abdul Razzaq son of Muhammad Shafi (deceased)
10. Muhammad Umar son of Abdul Razzaq
11. Sumaira Razzaq
12. 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, Lahore.

Plaintiffs

VERSUS

1. Public at Large
2. Excise & Taxation Department, Ichhra Circle-I, Zone No.4, Region-(A), Ihsaan Building 2/A, Freed Kot Road, Lahore.

Defendants

SUIT FOR DECLARATION WITH CONSEQUENTIAL RELIEF.

Respectfully Sheweth:-

1. That the predecessor-in-interest of the plaintiffs has six sons & 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 & father of plaintiffs No.5 to 8, Liaqat Ali (deceased son) husband of plaintiff No.9 & father of plaintiffs No.10 to 12, Muhammad Aslam (deceased son) husband of plaintiff No.13 & father of plaintiffs No.14 to 18, Abdul Razzaq (deceased son) husband of plaintiff No.19 & father of plaintiffs No.20 to 22. It is pertinent to mention here that one son namely Gulzar has moreover died issueless.
2. That the said Muhammad Shafi died on 17-08-1992 & leaving behind plaintiffs as his legal heirs. It is pertinent to mention here that after the death of said Muhammad Shafi/ predecessor-in-interest of plaintiffs, his five sons have moreover died.
3. That the predecessor-in-interest of plaintiffs left behind the property No.SXVIII-43-S-8-A, Circle-I, Zone-IV, Region-A located at 38 Shah Alam Street Ichhra, Lahore. Copy of registered sale deed attached here with.
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 yet 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 yet the defendant No.2 without any legal justification refused to transfer the said property in the name of the plaintiffs. The defendant No.2 moreover 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 & lastly when the defendant No.2 refused to transfer the suit property in the name of plaintiffs which is still continuing.
8. That the parties reside in Lahore & cause of action has moreover arisen here, therefore this learned court has received jurisdiction to try & adjudicate upon this matter.
9. That the value of the suit for the purposes of court fees & jurisdiction is fixed at Rs.200/- which is exempt from affixation of court fees.

PRAYER:

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 & 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 & appropriate in favour of the plaintiffs may moreover be awarded.

Plaintiffs

Through:-

Muhammad Nisar Malik
Advocate High Court

VERIFICATION:

Verified on oath at Lahore on this 24^th day of February 2012 that the contents of the Suit are true & correct to the best of my knowledge, information & belief & nothing has been concealed so far.

Plaintiff

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