IN
THE COURT OF SENIOR CIVIL JUDGE, LAHORE
Civil
Suit No.________________/ 2015
Name of Plaintiff or
Plaintiffs son of ………… resident of ……………………
…PLAINTIFFS
Versus
Public at Large
…DEFENDANT
SUIT
FOR DECLARATION TO DECLARE PLAINTIFFS AS LEGAL HEIRS OF LATE …………………………..
Respectfully Sheweth:-
- That the addresses of the parties have been given correctly for the purpose of service of notices / summons etc.
- That the husband of plaintiffs No. 1 and 2 and real father of plaintiffs No. 3 to 8 namely ………………….. died on 23-03-2007. Copy of death certificate is annexed as Annex-A.
- That the plaintiffs required the declaration to the effect that the plaintiffs are lawful legal heirs of deceased and no other person is legal heir of deceased except them and if they are not declared as legal heirs of the deceased named above they shall suffer an irreparable loss.
- That the cause of action accrued when husband of plaintiffs No. 1 and 2 and real father of plaintiffs No. 3 to 8 died which is still continuing.
- That the parties reside, cause of action accrued and deceased died in Lahore, hence, this Honourable Court has jurisdiction to entertain and adjudicate upon the matter.
- That the subject matter of the suit for the purposes of court fees and jurisdiction is fixed at Rs. 400/- which is exempted for the payment of court fee.
PRAYER
In
view of above submissions, it is most humbly prayed that judgment may very
kindly be passed in favour of the plaintiffs and against the defendant declaring
the plaintiffs No. 1 to 8 the only legal heirs of the deceased ………………… in the
larger interest of justice
Any
other relief which this Honourable Court may deems fit may also be granted to
the plaintiffs.
Plaintiffs
Through
Advocate
VERIFICATION:
Verified on Oath at Lahore on 17th
day of December 2014 that the contents of the plaint from Paras No. 1 to 3 are
correct as per my knowledge and belief, rest of the paras are also correct as
per my information.
PLAINTIFFS
No comments:
Post a Comment