IN
THE COURT OF SENIOR CIVIL JUDGE, LAHORE
CIVIL
SUIT NO: ________________________/2015
1. ___________ widow of deceased
2. ___________ son of deceased
3. ________ daughter of deceased
All
residents of House No. ______, Lahore.
……PLAINTIFFS
V E
R S U S
1. PUBLIC AT LARGE
2. LAHORE DEVELOPMENT AUTHORITY, THROUGH ITS
DIRECTOR GENERAL,
……DEFENDANTS
SUIT
FOR DECLARATION WITH MANDATORY INJUNCTION
Respectfully Sheweth:
1. That the addresses of the parties for the purpose of service by this Learned Court have correctly been given above.
2. That succinctly stated, facts giving rise to the filing of instant suit are that the plaintiffs are the only legal heirs of Late ______ deceased. Plaintiff No. 1 is his widow, Plaintiffs No. 2 & 3 are his son & daughter respectively. There are no legal heirs of ____ deceased except the plaintiffs.
3. That Late _____ was owner of House No. ___, situated at ___, Lahore (hereinafter referred to as “the suit property”). Late ____ became owner of the suit property vide transfer letter bearing No._____ dated ____ issued by LDA/Defendant No. 2. ( or sale deed if any with details)
4. That unfortunately, _____deceased died on ____, thereafter, the plaintiffs approached the office of LDA/Defendant No. 2 for transfer of suit property in their name, however, officials of LDA flately refused to do the same and directed the plaintiffs to get a declaratory decree from civil court.
5. That the plaintiffs, after death of _____deceased, have stepped into his shoes as they are his only legal heirs and defendants No. 2 is duty bound to transfer the suit property in the name of the plaintiffs.
6. That the cause of action arose firstly on _____ when ____deceased died and for the second time when the plaintiffs approached officials of Defendant No. 2 & they refused to consider the plaintiffs as legal heirs of _____deceased; the cause of action still continues.
7. That the suit property is situated at Lahore, therefore, this Honourable Court has got jurisdiction to adjudicate upon the matter.
8. That value of the suit for the purpose of jurisdiction and court fee is fixed at Rs. 200/-; required court fee has been affixed on the plaint.
1. That the addresses of the parties for the purpose of service by this Learned Court have correctly been given above.
2. That succinctly stated, facts giving rise to the filing of instant suit are that the plaintiffs are the only legal heirs of Late ______ deceased. Plaintiff No. 1 is his widow, Plaintiffs No. 2 & 3 are his son & daughter respectively. There are no legal heirs of ____ deceased except the plaintiffs.
3. That Late _____ was owner of House No. ___, situated at ___, Lahore (hereinafter referred to as “the suit property”). Late ____ became owner of the suit property vide transfer letter bearing No._____ dated ____ issued by LDA/Defendant No. 2. ( or sale deed if any with details)
4. That unfortunately, _____deceased died on ____, thereafter, the plaintiffs approached the office of LDA/Defendant No. 2 for transfer of suit property in their name, however, officials of LDA flately refused to do the same and directed the plaintiffs to get a declaratory decree from civil court.
5. That the plaintiffs, after death of _____deceased, have stepped into his shoes as they are his only legal heirs and defendants No. 2 is duty bound to transfer the suit property in the name of the plaintiffs.
6. That the cause of action arose firstly on _____ when ____deceased died and for the second time when the plaintiffs approached officials of Defendant No. 2 & they refused to consider the plaintiffs as legal heirs of _____deceased; the cause of action still continues.
7. That the suit property is situated at Lahore, therefore, this Honourable Court has got jurisdiction to adjudicate upon the matter.
8. That value of the suit for the purpose of jurisdiction and court fee is fixed at Rs. 200/-; required court fee has been affixed on the plaint.
PRAYER
In
aforementioned circumstances, it is humbly prayed that the instant suit for
declaration and mandatory injunction may kindly be decreed in favour of the
plaintiffs as mentioned below:
(i)
That the plaintiffs may kindly be declared as only legal heirs of Late ____
&
(ii)
That defendant No. 2 may kindly be directed to transfer the suit property in
the name of the plaintiffs.
Any
other relief which this Honourable Court deems fit and proper and which has not
been prayed for inadvertently may kindly also be granted.
PLAINTIFFS
Through
Advocate High Court
VERIFICATION:
Verified on Oath at Lahore on this ____ day of ____2015
that the contents of Paras No. 1 to 5 are correct to the best of our knowledge
and those of paras No. 6 to 8 are correct to the best of our belief.
PLAINTIFFS
