Succession Application

IN THE COURT OF 1st ADDITIONAL DISTRICT AND SESSION JUDGE,
SHAHEED BENAZIR ABAD
Succession Application No. of 2012.
Akhtar Hussain. …..………………Applicant.
VERSUS
Asghar Ali and others …………………Opponents.
STATEMENT
I humbly submitted on behalf of the opponents the defence
Savings certificates of the minors as under:-
Name of Minor Registration No Certificate No Amount
1.
Amir Ali 18355 HF 264363 10000
Amir Ali 18355 FC 882145 1000
Amir Ali 18355 FC 882146 1000
Amir Ali 18355 FC 882147 1000
Amir Ali 18355 EA 145184 500
=13,500/=
2.
Imran Ali 18354 HF 264362 10000
Imran Ali 18354 FC 882142 1000
Imran Ali 18354 FC 882143 1000
Imran Ali 18354 FC 882144 1000
Imran Ali 18354 EA 145183 500
=13,500/=
3.
Mst. Fozia 18359 GB 763523 5000
Mst. Fozia 18359 FC 882154 1000
Mst. Fozia 18359 FC 882155 1000
=7,000/=
4.
Mst. Nazia 18358 GB 763522 5000
Mst. Nazia 18358 FC 882152 1000
Mst. Nazia 18358 FC 882153 1000
=7,000/=
5.
Mst. Shakeela 18360 GB 763524 5000
Mst. Fozia 18360 FC 882156 1000
Mst. Fozia 18360 FC 882157 1000
=7,000/=
6.
Mst. Iqra 18356 GB 763520 5000
Mst. Iqra 18356 FC 882148 1000
Mst. Iqra 18356 FC 882149 1000
=7,000/=
7.
Mst. Fiza 18357 GB 763521 5000
Mst. Fiza 18357 FC 882150 1000
Mst. Fiza 18357 FC 882151 1000
=7,000/=
Dated: Advocate for opponents.

IN THE COURT OF THE DISTRICT JUDGE,
Letter of Administration No. of 2013.
Muhammad Basheer S/O Allah Dad, Awan,

adult, Muslim, R/o Village Allah Dad, Awan,
Deh 34, Dad Taluka Nawabshah,
District Shaheed Benazir Abad ………………Applicant.
VERSUS
1. Mst. Arshan Wd/o Allah Dad, Awan.

2. Abdul Majeed,
3. Mst. Ayesha,
4. Mst. Siddiqaan,
5. Mst. Yeshnan,
6. Mst. Saleema,
Opponents No. 2 to 6, all, son and daughters of

Late Allah Dad Awan, Muslims, Adults, R/O Village Allah Dad, Awan,
Deh 34 Dad, Taluka Nawabshah, District Shaheed Benazir Abad.
7. Public at large ………………………………………………………

Opponents.
APPLICATION U/S 218

SUCCESSION ACT,1925.
The applicant named above humbly submits as under:-
1). That Late Muhammad Nazeer son of Late Allah Dad, Awan, was
permanent resident of Village Allah Dad Awan, Deh 34 Dad, Taluka
Nawabshah, District Shaheed Benazir Abad and was died on 05-01-2013, for
which death certificate is submitted herewith as annexure “A”.
2). That said deceased at the time of his death left the applicant and
opponents No. 01 to 06 as his sole legal heirs. Applicant is brother, while
opponents No. 1 is mother and 2 to 6 are brother and sisters of the said
deceased respectively.
3). That said deceased was Suni Muslim and so are his legal heirs.
4). That said deceased namely Hafiz Muhammad Nazeer, Awan,
had obtained loan from National Bank of Pakistan Ltd, main branch
Nawabshah, amounting to Rs. 62,000/- and deposited/ given gold as surety
against such loan/ amount at the time of his such amount was outstanding
against him and the
P/…2
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same was deposited by his legal heirs on this account the bank has issued
clearance certificate photocopy of such certificate issued by the concerned
bank is submitted herewith as annexure “B”.
6). That after getting clearance certificate, the concerned bank is
not ready to redeem/ release the gold without providing letter of administration
of the Honorable court. Hence this application.
7). The said deceased died intestate and due and diligent search
has been made for a Will but none is found out.
8). That no application has been made to any Court so for and no
grant has been made of any certificate, probate or letter of administration in
respect of the documents and estates of the said deceased and there is no
any impediment under the provisions of Succession Act, 1925 or any other
enactment for the time being in force to the grant of the letter of administration
or the validity thereof if it were granted.
9). That the applicant has fully set forth the amount of loan from
National Bank of Pakistan Ltd, main branch Nawabshah, in Para No.04 above,
in respect of which letter of administration is applied for.
PRAYER
The applicant, therefore, prays that the Honourable court may be
pleased to issue a Letter of Administration in his favour authorizing/
empowering him to get/ receive the aforesaid gold from concerned authorities.
Applicant
Advocate for Applicant.
P/…3
P/…3
VERIFICATION.
I, Muhammad Basheer S/O Late Allah Dad, Awan, adult, Muslim, r/o:
Village Allah Dad, Awan, Deh 34 Dad, Taluka, Nawabshah, District Shaheed
Benazir Abad, do hereby verify on oath on this ------ day of September 2013 at
Nawabshah, that whatever stated above is true and correct to the best of my
knowledge and belief.
Deponent
I know the deponent
Advocate
Documents filed
As Annexure "A" & "B".
Documents Relied upon.

1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant herself
2. Abdul Sattar S/o Haji Muhammad Suleman, Awan,

3. Muhammad Yaseen S/o Ghulam Rasool,
both R/o Village Allah Dad Awan, Taluka Nawabshah,
District Shaheed Benazir Abad.
Drafted by me in my office at Nawabshah, under the instructions of the

applicant.
Addresses of the parties are same as shown in the cause title of the
application
Dated:- (ASIF HAMAYUN MUGHAL)
Muhammad Basheer ------------------------------Applicant
VERSUS
Mst. Arshan & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Muhammad Yaseen son of Ghulam Rasool, Awan, adult,

Muslim, r/o: village Allah Dad, Awan, Deh 34 Dad, Taluka, Nawabshah, District
Shaheed Benazir Abad, do hereby state on oath as under:-
1. That I know the applicant as well as opponents No. 1 to 6, who are

legal heirs of deceased Hafiz Muhammad Nazeer Awan, son of Late Allah
Dad, Awan, who died on 05.01.2013.
2. That deceased Hafiz Muhammad Nazeer, Awan, at the time of his

death left some gold which was mortgaged in National Bank of Pakstan Ltd,
main branch Nawabshah.
3. That applicant and opponents No. 1 to 6 are sole legal heirs of

deceased Hafiz Muhammad Nazeer, Awan, and prior to this no application in
this respect has either been applied for or granted in favour of legal heirs of
deceased.
Whatever stated above is true and correct to the best of my knowledge

and belief.
Deponent.
I know the deponent.
Advocate.
SHAHEED BENAZIR ABAD.
Succession Application No. 21 of 2013.
Muhammad Khan.
------------------------------Applicant
VERSUS
Manthar & Others

------------------------------ Opponents.
STATEMENT.
Share of legal heirs are as under:-
1. Muhammad Khan. Son Rs. 14,285.71/-

2. Manthar Son Rs. 14,285.71/-
2. Ahmed Khan. Son Rs. 14,285.71/-
3. Didar Ali. Son Rs. 14,285.71/-
3. Khair Muhammad. Son Rs. 14,285.71/-
5. Nizam Din. Son Rs. 14,285.71/-
6. Mst Mehran. Daughter Rs. 7,142.87/-
7. Mst. Hajani. Daughter Rs. 7,142.87/-
______________
Total= 1, 00,000/-
______________
Advocate for Applicant

Muhammad Khan.
------------------------------Applicant
VERSUS
Manthar & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Mst. Hajani D/O Late Muhammad Yateem, Khoso, W/O Munawar Ali,
Khoso, adult, Muslim, r/o: Deh 38 Dad Village Khair Muhammad Khoso,
Taluka Nawabshah, District Shaheed Benazir Abad, do hereby state on oath
as under:-
1. That I have received amount Rs. 7142.87 (Seven Thousand One

Hundred Fourty Two Rupees & Eighty Seven paisa Only) being opponent
No. 7, from applicant Muhammad Khan S/O Yateem Khan Khoso, being my
share in the amount left by my late father in Succession Application No. 21 of
2013.
2. That I have no objection if the surety papers return to the surety.

and belief.
Deponent.
(Mst. Hajani, Khoso)
Advocate.
IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD
Succession Application No. Of 2012.
Mst. Rafiqan alias Rubina

--------------------------Applicant.
Versus.
Shakeel Ahmed & Others

-----------------------Opponents.
STATEMENT
I produce Defense Saving Certificate (Original) in the name of

following minor:-
Baby Maha Khan

D/O Late Muhammad Yaseen Khan. Rs. 12960.83/-
Nawabshah
Dated:- Advocate for
Applicant.
Mst. Rubina ------------------------------Applicant
VERSUS
Farzand & Others

------------------------------ Opponents.
APPLICATION U/O 32 RULE 3 CPC

It is prayed that this Honourable Court may be pleased to
appoint opponent No.2, as guardian ad-litim for minors opponent No.5 to 9, for
the purpose of obtaining Letter of Administration on the consideration of the
grounds mentioned in the accompanying affidavit.
ADVOCATE FOR APPLICANT

NAWABSHAH.
DATED:

VERSUS
Farzand & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Rubina Wd/O Buxal, Bughio, adult, Muslim, r/o: Shahbaz Colony,
Near Town Committee Kandiaro, District Naushehrofaroze. House No. 104
Deh 50 Dad Azeem Colony Nawabshah, do hereby state on oath as under:-
1. That I am applicant and hence fully conversant with the facts of the
present application.
2. That accompanying application U/O 32 Rule 3 CPC has been filed by

me, the contents where of are true and may be read as part of this affidavit.
3. That opponent No.2, is real brother minors, and the minors are under
the care and custody of opponent No.2, and she has no interest in the matter
in controversy in the application adverse that of minors and that she is a fit
person to be so appointed.
4. That Justice requires that my accompanying application may be

allowed.
5. That I shall suffer serious loss if the accompanying application is not

allowed.

and belief.
Deponent.
Advocate.

Mst. Rubina Wd/O Bakhshal Bughio,

adult, Muslim, at present R/o Shahbaz Colony,
Near Town Committee Kandiaro, District Naushehrofaroze.
House No. 104 Deh 50 Dad Azeem Colony Nawabshah………………
Applicant.
VERSUS
6. Farzand Ali S/o. Bakhshal Bughio,

7. Javed Ali S/o. Bakhshal Bughio,
8. Parvez Ali S/o. Bakhshal Bughio,
9. Naved Ali S/o. Bakhshal Bughio,
10. Sajida D/o. Bakhshal Bughio,
Aged about 16 years.
11. Reena D/o. Bakhshal Bughio,
12. Faraz S/o. Bakhshal Bughio,
13. Tanveer S/o. Bakhshal Bughio,
14. Tasveer S/o. Bakhshal Bughio,
All, Muslims, Adults except minors No. 05 to 09,

through their real brother and ad-litim opponent No. 02 Javed Ali,
R/o Shahbaz Colony, Near Town Committee Kandiaro,
District Naushehrofaroze.
Permanent Address House No. 104 Deh 50 Dad
Azeem Colony Nawabshah.
15. Public at large ………………………………………………………

Opponents.
APPLICATION U/S 218

1). That late Bakhshal S/O Imam Bux Bughio, r/o: House No. 104, Deh 50
Dad, Azeem Colony, Nawabshah , District Shaheed Benazir Abad, died on
10.11.1999, for which death certificate is submitted herewith as annexure “A”.
opponents No. 01 to 09 as his sole legal heirs. Applicant is widow, while
opponents No.1 to 09 are sons and daughters of the said deceased.
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4). That said deceased namely Bakhshal had obtained loan from
House Building Finance Corporation Rs. 1,00,000/-, in 1986. On the house
viz. house No. 104 Deh 50 Dad, Azeem Colony, Nawabshah , District
Shaheed Benazir Abad.
5). That the said loan has been paid in installments, some
installments had been paid in the life of the deceased and after his death the
remaining amount has been paid by his heirs. Thereafter there is no any
outstanding amount against the said house and House Building Finance
Corporation issued clearance certificate in this regard. Photocopy of the same
is attached herewith as annexure “B”.
6). That after getting clearance certificate, House Building Finance
Corporation is not ready to redeem the documents of the said house without
providing letter of administration of the Honorable court. Hence this
application.
7). The said deceased died intestate and due and diligent search
8). That to maintain and look after the same house and redeem the
documents from House Building Finance Corporation, a letter of
administration is required by the applicant and opponents No. 01 to 09, hence
this application.
9). That no application has been made to any Court so for and no
grant has been made of any certificate, probate or letter of administration in
respect of the documents and estates of the said deceased and there is no
any impediment under the provisions of Succession Act, 1925 or any other

10). That the applicant has fully set forth the amount of loan from
House Building Finance Corporation, in Para No.05 above, in respect of which
letter of administration is applied for.
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P/..3
PRAYER
The applicant, therefore, prays that the Honourable court may be

pleased to issue a Letter of Administration in her favour authorizing/
empowering her to get/ receive the aforesaid documents from concerned
authorities.
Applicant
VERIFICATION.
I, Rubina Wd/O Bakhshal Bughio, adult, Muslim, r/o: House No. 104,
Deh 50 Dad, Azeem Colony, Nawabshah, District Shaheed Benazir Abad and
Permanent Address R/o Shahbaz Colony, Near Town Committee Kandiaro,
District Naushehrofaroze. do hereby verify on oath on this ------ day of July
2013 at Nawabshah, that whatever stated above is true and correct to the
best of my knowledge and belief.
Deponent
I know the deponent
Advocate
Documents filed

1. Same as above
LIST OF WITNESSES:
2. Sher Muhammad S/o. Muhammad Khan Khaskheli,

R/o. Village Fakir Muhammad Deenari,
Near Doctors Colony Nawabshah.
3. Mashooque Ali S/o. Dargahi Kambrani,
R/o. Afzal Shah Town Nawabshah.
Drafted by me in my office at Nawabshah, under the instructions of the

applicant.
application.

IN THE COURT OF IST ADDITIONAL DISTRICT JUDGE,
Mst. Dildar Akhtar ………. Applicant.
Versus
Shakeel Ahmed & Others ………. Opponents.
-: R E C I P T :-
I have received an amount of Rs. 1,40,259.42/-, being

opponent No. 5, from applicant Mst. Dildar Akhtar, being my share in the
amount left by my father in Succession Application No. 137 of 2012.
(Mst. Shumaila)
(S/O Late Muhammad Afzal Khan.)
IN THE COURT OF IST ADDITIONAL DISTRICT JUDGE,

Mst. Dildar Akhtar ………. Applicant.
Versus
Shakeel Ahmed & Others ………. Opponents.
-: R E C I P T :-
I have received an amount of Rs.1,40,259.42/-, being

opponent No. 6, from applicant Mst. Dildar Akhtar, being my share in the
amount left by my father in Succession Application No. 137 of 2012.
(Mst. Shaheen Bibi.)
(S/O Late Muhammad Afzal Khan.)


Mst. Rafiqan alias Rubina Wd/O Muhammad
Yaseen Khan, adult, Muslim, r/o Habib
Sugar Mills, Colony, Road Nawabshah,
--------------------------Applicant.
Versus.
2. Shakeel Ahmed .
3. Shahid Khan,
4. Zahid Khan,
5. Mst. Shagufta Shaheen,
6. Mst. Shaista Shaheen,
7. Mst. Shabana Khan,
8. Mst. Zahida Parveen,
All adult Muslims,
8. Mst. Maham Khan, Minor aged about 15 years.
All sons and daughters of late Muhammad Yaseen Khan,
R/o: Habib Sugar Mills, Colony Nawabshah. Nawabshah,
No. 8
9. Public at large
-----------------------Opponents.
APPLICATION U/S 218

1). That late Buxal S/O Imam Bux Bughio, r/o: House No. 104, Deh 50
Dad, Azeem Colony, Nawabshah , District Shaheed Benazir Abad, died on
10.11.1999, for which death certificate is submitted herewith as annexure
“A”.
opponents No.1 to 4 are sons of the said deceased.
P/2…
P/..2
4). That said deceased namely Buxal had obtained loan from House
Building Finance Corporation Rs. 1,00,000/-, in 1986. On the house viz house
No. 104 Deh 50 Dad, Azeem Colony, Nawabshah , District Shaheed Benazir
Abad.
5). That the said loan has been paid in installments, some installments had
been paid in the life of the deceased and after his death the remaining amount
has been paid by his heirs. Thereafter there is no any outstanding amount
against the said house and House Building Finance Corporation issued
clearance certificate in this regard. Photocopy of the same is attached
herewith as annexure “B”.
6). That after getting clearance certificate, House Building Finance

Corporation is not ready to redeem the documents of the said house without
providing letter of administration of the Honurable court. Hence this
application.
7). The said deceased died intestate and due and diligent search has been
made for a Will but none is found out.
8). That to withdraw the documents aforesaid from House Building

Finance Corporation, a letter of administration is required by the applicant and
opponents No. 1 to 4, hence this application.
9). That no application has been made to any Court so for and no grant
has been made of any certificate, probate or letter of administration in respect
of the documents and estates of the said deceased and there is no any
impediment under the provisions of Succession Act, 1925 or any other
10). That the applicant has fully set forth the amount of loan from House
Building Finance Corporation, in Para No.4 above, in respect of which letter of
administration is applied for.
P/..3
P/..3
PRAYER
The applicant, therefore, prays that the Honourable court may

be pleased to issue a Letter of Administration in her favour
authorizing/ empowering her to get/ receive the aforesaid
documents from concerned authorities.
Applicant
VERIFICATION.
I, Rubina Wd/O Buxal, Bughio, adult, Muslim, r/o: House No.

104, Deh 50 Dad, Azeem Colony, Nawabshah, District Shaheed Benazir Abad,
do hereby verify on oath on this ------ day of January, 2013 at Nawabshah, that
whatever stated above is true and correct to the best of my knowledge and
belief.
Deponent
I know the deponent
Advocate
Documents filed

1. Same as above
LIST OF WITNESSES:
2. Loung Khan S/O Dhani Parto Unar.
3. Lakhadino S/O Muhammad Ismail Unar
Both r/o: Village Pir Nazar Muhammad Shah,
Taluka Kazi Ahmed , District Shaheed Benazir Abad.
Drafted by me in my office at Nawabshah, under the instructions

of the applicant.
Addresses of the parties are same as shown in the cause title
of the application.

VERSUS
Farzand & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Rubina Wd/O Buxal, Bughio, adult, Muslim, r/o: House No.

do hereby state on oath as under:-
2. That my husband late Buxal S/O Imam Bux, Bughio died on 10-11-
1999. I produce death certificate as Annexure “A”.
3. That said deceased Late Buxal, Bughio was permanent r/o House No.
and was a Sunni Muslim.
4. That said deceased left me and opponents Nos. 1 to 4 as his sole legal
heirs. I am widow, while opponent No.1 to 9 are sons and daughters of
deceased Buxal Bughio.
5. That said deceased left the house No. 104, deh 50 dad Azeem Colony
Nawabshah which was mortgaged against an amount of Rs.1,00,000 /-, with
House Building Finance Corporation, the same loan now has been cleared
and the photo copy of clearance certificate is attached with the application as
annexure “B”.
6. That said deceased died intestate and due and diligent search has
been made for a will but none is found out.
8. That to withdraw the documents aforesaid from the concerned
authorities a Letter of administration certificate is required by us.
P/2…
P/2…
9. That no application has been made to any court so far and no grant has
been made of any certificate, probate or letter of administration in respect of
said documents and estate of the said deceased and there is no any
impediment under the provision of Succession Act, 1925 or any other

enactment for the time being enforce to grant the letter of administration or the
validity thereof if it were granted.
10. That I therefore, pray that letter of administration may pleased be
granted in my favour authorizing / empowering me to get / receive the
documents aforesaid.

and belief.
Deponent.
Advocate

VERSUS
Farzand & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Sher Muahmmad son of Muhammad Khan, Khaskheli , adult,

Muslim, r/o: village Faqeer Muhammad Deenari, Near Doctors Colony,
Nawabshah, District Shaheed Benazir Abad, do hereby state on oath as
under:-
1. That I know the applicant as well as opponents No. 1 to 4, who

are legal heirs of deceased Buxal, son of Imam Bux, Bughio, who died
on 10.11.1999.
2. That deceased Buxal, at the time of his death left a house which
was mortgaged in House Building Finance Corporation.

deceased Buxal, Bughio and prior to this no application in this respect
has either been applied for or granted in favour of legal heirs of
deceased.
Whatever stated above is true and correct to the best of my

Deponent.
Advocate.
VERSUS
Farzand & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Mashooque Ali son of Dargaahi, Qambrani, adult, Muslim,

r/o: Afzaal Shah Town, Sanghar Road, Nawabshah, , do hereby state on
oath as under:-

on 10.11.1999.

deceased.

Deponent.
Advocate.

VERSUS
Farzand & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Sher Muhammad son of Muhammad Khan, Khaskheli, adult,

Muslim, r/o: Village Faqeer Muhammad Deenari, near Doctors Colony,
Nawabshah, do hereby state on oath as under:-

on 10.11.1999.

deceased.

Deponent.
Advocate.
IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.
Succession Application No. OF 2012.
Mst. Rafiqan @ Rubina

-------------------------------Applicant
VERSUS
Shakeel Ahmed & another

------------------------------ Opponents.
A F F I D A V I T.
I, Zahida Parveen D/O Late Muhammad Yaseen Khan, adult, muslim, r/o:
H.No. 513/28,29 Mohalla I.C Nawabshah, Municipal Committee Nawabshah District
1. That I am Opponent No.7 in the above matter and hence fully conversant with
the facts of the present application.
2. That my father late Muhammad Yaseen Khan S/O Nanny Khan, died on 13-
04-2012.
3. That said deceased Muhammad Yaseen Khan was permanent r/o: Habib
Sugar Mills (Pvt) Ltd. Colony Nawabshah, District Shaheed Benazir Abad, and was a
Sunni Muslim.
4. That said deceased left applicant, and us Opponents Nos. 1 and 8 his sole
legal heirs.
5. That said deceased left an amount of Rs. 65821/- with National Bank of
Pakistan University branch, Nawabshah, for releasing thereof, for which Succession
Certificate is required.
6. That said deceased died intestate and due and diligent search has been
made for a will but none is found out.
7. That to withdraw the amount aforesaid from the concerned branch, a

succession certificate is required to applicant.
8. That I have no objection if the Honourable court may be pleased to grant

Succession Certificate in favour of applicant, authorizing/ empowering her to get /
withdraw / receive the amount aforesaid with interest to be accrued up to the date of
withdrawal from concerned branch for disbursement thereof amongst all the legal
heirs according to our legal share, in accordance with law.
Whatever stated above is true and correct to the best of my knowledge and
belief.
Deponent.
Advocate
Mst. Sanobar
-------------------------------Applicant
VERSUS
Haji Shahdad Khan & another

------------------------------ Opponents.
A F F I D A V I T.
I, Mst. Sehar Bano W/O Haji Shahdad Khan, Channar, adult, muslim, r/o:
Mehran Colony, Sakrand Road Nawabshah, District Shaheed Benazir Abad, do
hereby state on oath as under:-
1. That I am Opponent No.2 in the above matter and hence fully conversant with
the facts of the present application.
2. That my son late Niaz Hussain Channar, died on 19-08-2012.
3. That said deceased Niaz Hussain Channar was permanent r/o: Mehran
Colony, Sakrand Road Nawabshah, District Shaheed Benazir Abad, and was a Sunni
Muslim.
4. That said deceased left applicant, minors 2 to 5 and us Opponents Nos. 1 and
2 his sole legal heirs.
5. That said deceased left an amount of Rs. 65821/- with National Bank of
Pakistan University branch, Nawabshah, for releasing thereof, for which Succession
Certificate is required.
6. That said deceased died intestate and due and diligent search has been
made for a will but none is found out.
7. That to withdraw the amount aforesaid from the concerned branch, a

succession certificate is required to applicant.
8. That I have no objection if the Honourable court may be pleased to grant

Succession Certificate in favour of applicant, authorizing/ empowering her to get /
withdraw / receive the amount aforesaid with interest to be accrued up to the date of
withdrawal from concerned branch for disbursement thereof amongst all the legal
heirs according to our legal share, in accordance with law.
Whatever stated above is true and correct to the best of my knowledge and
belief.
Deponent.
Advocate

VERSUS
Farzand & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Sher Muahmmad son of Muhammad Khan, Khaskheli , adult,

Muslim, r/o: village Faqeer Muhammad Deenari, Near Doctors Colony,
Nawabshah, District Shaheed Benazir Abad, do hereby state on oath as
under:-

are legal heirs of late Buxal, son of Imam Bux, Bughio, who died on
10.11.1999.

deceased.

Deponent.
Advocate.
VERSUS
Farzand & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Zulekhan Wd/O Muhammad Laique Unar, adult, Muslim,

r/o: village Saleh Shah, Taluka Kazi Ahmed, District Shaheed Benazir Abad,
1. That I am applicant and hence fully conversant with the facts of

the present application.
2. That my husband late Muhammad Laique S/O Punhoon Khan

Unar died on 05-05-2011. I produce death certificate as Ex:__________.
3. That said deceased Late Muhammad Laique was permanent r/o

village Saleh Shah, Taluka Kazi Ahmed, District Shaheed Benazir
Abad and was a Sunni Muslim.
4. That said deceased left me and opponents Nos. 1 to 4 as his sole

legal heirs. I am widow, while opponent No.1 mother, opponent No.2,
daughter and opponents No. 3 and 4, are brothers of deceased
Muhammad Laique.
5. That said deceased left an amount of Rs.03,08.192/-, with

United Bank Limited Kazi Ahmed Branch, at the time of his death. I
produce Bank Balance Certificate as Ex. _____________.
6. That said deceased died intestate and due and diligent search
has been made for a will but none is found out.
P/2…
P/2…
7. That such heir ship certificate issued by the Mukhtiarkar
(Revenue), Nawabshah is submitted as Ex._________________.
8. That to withdraw the amount aforesaid from the concerned
Bank a succession certificate is required by us.
9. That no application has been made to any court so far and no
grant has been made of any certificate, probate or letter of
administration in respect of debts, securities and estate of the said
deceased and there is no any impediment under the provision of
Succession Act, 1925 or any other enactment for the time being
inforce to grant the succession certificate or the validity thereof if it
were granted.
10. That I therefore, pray that Succession Certificate may pleased be
granted in my favour authorizing / empowering me to get / withdraw
/ receive the amount aforesaid with interest to be accrued up to the
date of withdrawal from bank etc for disbursement thereof amongst all
the legal heirs according to our legal share, in accordance with law.

Deponent.
Advocate
S.A. NO. 2011
Mst. Zulekhan
-------------------------------Applicant
VERSUS
Mst. Sahiba Khatoon & Others

------------------------------ Opponents.
appoint opponent No.1, as guardian ad litem for minor opponent No.2,
for the purpose of obtaining Succession Certificate on the
consideration of the grounds mentioned in the accompanying affidavit.
ADVOCATE FOR APPLICANT

NAWABSHAH.
DATED:
S.A. NO. 2011

Mst. Zulekhan
-------------------------------Applicant
VERSUS
Mst. Sahiba Khatoon & Others

------------------------------ Opponents.
A F F I D A V I T.


2. That accompanying application U/O 32 Rule 3 CPC has been

filed by me, the contents where of are true and may be read as part of
this affidavit.
3. That opponent No.1, is real grand mother of minor, and the

minor is under the care and custody of opponent No.1, and she has
no interest in the matter in controversy in the application adverse that
of minors and that she is a fit person to be so appointed.

allowed.
5. That I shall suffer serious loss if the accompanying application

is not allowed.

Deponent.
Advocate.
Mst. Zulekhan Wd/O Mhammad Laique

Unar, adult, Muslim, r/o: Village Saleh
Shah, Taluka Kazi Ahmed, District Shaheed
Benazir Abad.
--------------------------Applicant.
Versus.
10. Sahiba Khatoon Wd/O Punhoon Khan .

11. Baby Hakeeman D/O Late Muhammad Laique ,
aged about 11 years,
12. Muhammad Ismail S/O Late Punhoon Khan.
13. Haji Chutto S/O Late Punhoon Khan.
All adults, Muslims, r/o: Village Saleh Shah,

Taluka Kazi Ahmed, District Shaheed
Benazir Abad.
14. Public at large
-----------------------Opponents.
APPLICATION U/S 370 & 372

1). That late Muhammad Laique S/O Punhoon Khan Unar , r/o: Village
Saleh Shah, Taluka Kazi Ahmed, District Shaheed Benazir Abad, died on
05.052011, for which death certificate is submitted herewith as annexure “A”.
opponent No.1, is mother, opponents No.2, is daughters and opponents No.3
and 4 are brothers of the said deceased.
P/2…
P/2…
3). That said deceased was Suni muslim and so are his legal heirs.
4). That said deceased at the time of his death left an amount of
Rs.3,08,192/- with United Bank Limited Kazi Ahmed Branch, Such certificate
issued by Manger, is submitted herewith as annexure “B”.
5). That said deceased died intestate and due and diligent search has been
6). That to withdraw the amount aforesaid from Bank, a succession

certificate is required by the applicant and opponents No. 1 to 4, hence this
application.
7). That no application has been made to any Court so for and no grant has
the debts, securities and estates of the said deceased and there is no any
enactment for the time being in force to the grant of the succession certificate
8). That the applicant has fully set forth the securities/amount/debts in
Para No.4 above, in respect of which succession certificate is applied for.
PRAYER
be pleased to issue a Succession Certificate in her favour
authorizing/ empowering her to get/ with draw/ receive the
amount aforesaid with interest to be accrued up to the date of
withdrawal from concerned Bank, for disbursement thereof
amongst all the legal heirs, according to their legal shares.
Applicant
P/3…
P/3…
VERIFICATION.

do hereby verify on oath on this ------ day of November, 2011 at Nawabshah,
that whatever stated above is true and correct to the best of my knowledge
and belief.
Deponent
I know the deponent
Advocate
Documents filed

1. Same as above
LIST OF WITNESSES:
4. Loung Khan S/O Dhani Parto Unar.

5. Lakhadino S/O Muhammad Ismail Unar
Both r/o: Village Pir Nazar Muhammad Shah,

Taluka Kazi Ahmed , District Shaheed Benazir Abad.
Drafted by me in my office at Nawabshah, under the
instructions of the applicant.
Addresses of the parties are same as shown in the cause title of
the application.
(AMEER ALI
MAHESSAR)
Nawabshah.
Dated:
IN THE COURT OF IIND ADDITIONAL DISTRICT JUDGE, SHAHEED
BENAZIR ABAD.
Letter of Administration NO. of 2011
Aamir Khan Magsi

-------------------------------Applicant
VERSUS
Mst. Shahjah & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Pathani W/O Ali Hassan Magsi, adult, muslim, r/o: Village

Buxo Magsi, Taluka Sakrand, District Shaheed Benazir Abad, do
1. That I am Opponent No.3 in the above matter and my son Dost

Muhammad Magsi, died on 10.04.2010 and at the time of death
of he was permanent r/o: Village Buxo Magsi, Taluka Sakrand,
District Shaheed Benazir Abad, and was a Sunni Muslim.
2. That said deceased left gold, mortgaged in National Bank of

Pakistan, Mohni Bazar Branch, Nawabshah, weighing 82.700
grams as gross weight which became 53-00 grams as net weight
of the gold amounting to Rs.74,000/- for which he obtained loan,
which are to be deposited such certificate / letter dated
01.12.2010, issued by NBP, Mohni Bazar Branch, Nawabshah,
for which Letter of administration is required.
5. That I have no objection if the Honourable court may be pleased

to grant Letter of administration in favour of applicant,
authorizing/ empowering him to get/ withdraw/ receive the gold
aforesaid from concerned bank for disbursement thereof amongst
all the legal heirs according to our legal share, in accordance with law.

Deponent.
I know the Deponent.
Advocate.
BENAZIR ABAD.
Aamir Khan Magsi

-------------------------------Applicant
VERSUS

------------------------------ Opponents.
A F F I D A V I T.
I, Shahjah Wd/O Dost Muhammad Magsi, adult, muslim, r/o:

Village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir Abad,
1. That I am Opponent No.1 in the above matter and I am natural

guardian and real mother of opponent No.4, and my husband
Dost Muhammad Magsi, died on 10.04.2010 and at the time of
death of he was permanent r/o: Village Buxo Magsi, Taluka
Sakrand, District Shaheed Benazir Abad, and was a Sunni
Muslim.
2. That said deceased left gold, mortgaged in National Bank of

Pakistan, Mohni Bazar Branch, Nawabshah, weighing 82.700
grams as gross weight which became 53-00 grams as net weight
of the gold amounting to Rs.74,000/- for which he obtained loan,
which are to be deposited such certificate / letter dated
01.12.2010, issued by NBP, Mohni Bazar Branch, Nawabshah,
for which Letter of administration is required.

to grant Letter of administration in favour of applicant,
authorizing/ empowering him to get / withdraw / receive the gold
aforesaid from concerned bank for disbursement thereof amongst
all the legal heirs according to our legal share, in accordance
with law.

Deponent.
Advocate.
IN THE COURT OF THE DISTRICT JUDGE, SHAHEED
BENAZIR ABAD
Miss. Mehar Afshan & others

……..…………….Applicants
Versus
Public at Large
……….…………. Opponents
: - STATEMENT - :
In compliance of order dated: 08.01.2011, of the Honourable

Court, I hereby submit Photostat copy of residence certificate showing
the name of Baby Iqra along with his father’s name as Abdul Jabbar
Memon, and present address of both is as under:
Address:
H # A-35, Govt. Employees Co-operative Housing Society,
Nawabshah.
Advocate for Applicants

Nawabshah.
Dated:08.03.2011
BENAZIR ABAD.
Aamir Khan Magsi

-------------------------------Applicant
VERSUS

------------------------------ Opponents.
A F F I D A V I T.
I, Shahid Latif son of Noor Muhammad Magsi, adult, muslim,

r/o: Village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir
Abad, do hereby state on oath as under:-

are legal heirs of late Dost Muhammad son of Ali Hassan Magsi, who
died on 10.04.2010.
2. That deceased Dost Muhammad at the time of his death left

gold mortaged in National Bank of Pakistan Mohni Bazar Nawabshah,
weighing 82.700 grams as gross weight which become 53.000 grams
as net weight of the gold against the loan of Rs.74,000/-, which are to
be deposited by his legal heirs.

deceased Dost Muhammad and prior to this no application in this
respect has either been applied for or granted in favour of legal heirs of
deceased.

Deponent.
Advocate.
BENAZIR ABAD.
Aamir Khan Magsi

-------------------------------Applicant
VERSUS

------------------------------ Opponents.
A F F I D A V I T.
I, Ghulam Murtaza son of Ali Nawaz Magsi, adult, muslim, r/o:

Village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir Abad,

are legal heirs of late Dost Muhammad son of Ali Hassan Magsi, who
died on 10.04.2010.
2. That deceased Dost Muhammad at the time of his death left

gold mortaged in National Bank of Pakistan Mohni Bazar Nawabshah,
weighing 82.700 grams as gross weight which become 53.000 grams
as net weight of the gold against the loan of Rs.74,000/-, which are to
be deposited by his legal heirs.

deceased Dost Muhammad and prior to this no application in this
deceased.

Deponent.
Advocate.
Muhammad Waseem
-------------------------------Applicant
VERSUS
Azeem Shahzore & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Zaheer Ahmed son of Bashir Ahmed, Memon, adult, Muslim,

r/o: Mohni Bazar Nawabshah, do hereby state on oath as under:-

are legal heirs of late Muhammad Saleem son of Abdul Rasheed,
Rajput, who died on 22-10-2009.
2. That deceased Muhammad Saleem at the time of his death left a

vehicle bearing registration No. ANR -093, Cultus VXR, Model 2007,
which was obtained by him from UBL, Gul Centre, Hyderabad on
lease. After his death the said vehicle was under the possession of the
legal heirs of deceased Muhammad Saleem, who were paying the lease
money regularly. The bank concerned mistakenly took over the
possession of the vehicle on the issue of non payment, but when the
receipts were shown to Bank authority, they demanded Succession
Certificate/ Letter of Administration from the applicant.

deceased Muhammad Saleem and prior to this no application in this
deceased.

Deponent.
Advocate.
Muhammad Waseem son of Muhammad

Saleem, adult, Muslim, Rajput by caste, r/o:
Shahbaz Plaza, Liaquat Market Nawabshah.
--------------------------Applicant.
Versus.
15. Azeem Shahzore son of M. Saleem Rajput.

16. Mst. Muqadas D/O Muhammad Saleem.
17. Mst. Nazia Wd/O Muhammad Saleem,
All r/o: Shahbaz Plaza Liaquat Market Nawabshah,
18. Public at Large
---------------------------- opponents
APPLICATION U/S 218 OF

1). That late Muhammad son of Abdul Rasheed Rajput, r/o:

Shahbaz Plaza, Liaquat Market , Nawabshah, died on 22.10.2009, for which
death certificate is submitted herewith as annexure “A”.
opponents No. 1 to 3 as his sole legal heirs. Applicant is son, while opponents
No. 1 and 2 are son and daughter respectively while opponent No.3, is
widow, of the said deceased.
3). That said deceased was Suni muslim and so are his legal heirs, the
applicant and opponents No.1 to 3.
4). That said deceased at the time of his death left a vehicle bearing
registration No. ANR-093, Cultus VXR, Model 2007, which was obtained by
him by way of lease from United Bank Limited, Gul Center, Hyderabad. Said
deceased was regularly depositing the lease money till his death viz.
22.10.2009,
P/2…
P/2…
and there after his son the applicant , hence till January, 2011, there was no
any outstanding of United Bank Limited, Gul Center, Hyderabad against the
leased vehicle, but there after mistakenly said United Bank Limited took over
the possession on the pretext of non payment, but when the receipts were
shown to them, they asked that Muhammad Saleem may appear before them
on which it was disclosed to them about the death of Muhammad Saleem,
therefore, they refused to hand over the vehicle, until and unless succession
certificate / letter of administration may be handed over to them, hence the
present application has been filed. (Photostat copies of documents of vehicle
are submitted herewith as annexure “B”
6). That to take the possession of the vehicle aforementioned back form
M/S United Bank Limited , Gul Center, Hyderabad, a Letter of
administration is required by the applicant and opponents No. 1 to 3, hence
this application.
enactment for the time being in force to the grant of the Letter of
Administration or the validity thereof if it were granted.
Para No.4 above, in respect of which Letter of administration is applied for.
PRAYER
The applicant, therefore, prays that the Honourable Court may
be pleased to issue a Letter of administration in his favour
authorizing/ empowering him to get/ with draw/ receive the
vehicle bearing registration No. ANR-093, Cultus, VXR, Model
2007, from M/S United Bank Limited , Gul Center, Hyderabad.
Applicant
P/3…
P/3…
VERIFICATION.
I, Muhammad Waseem son of Muhammad Saleem Rajput, adult,

Muslim, r/o: Shahbaz Plaza, Liaquat Market Nawabshah, do hereby verify on
oath on this _________ day of February, 2011 at Nawabshah, that whatever
stated above is true and correct to the best of my knowledge and belief.
Deponent
I know the deponent
Advocate
Documents filed
As Annexure "A" & “B”

1. Same as above
LIST OF WITNESSES:
1. Applicant himself
2.
3.
the application.
(AMEER ALI
MAHESSAR)
Nawabshah.
Dated :
IN THE COURT OF IIND. ADDITIONAL DISTRICT JUDGE, SHAHEED
BENAZIR ABAD.
Ameer
-------------------------------Applicant
VERSUS
Mst. Zuhraan & Others

------------------------------ Opponents.
APPLICATION U/S 376 SUCCESSION ACT,1925.
It is prayed that this Honourable court may be pleased to
issue extended Succession Certificate in favour of applicant
authorizing/ empowering him to get/ receive the amount of
Rs.6,03,560/- from Sui Southern Gas Company Limited, requiring
Succession Certificate, vide letter No.REF:IR/HO/1.1-D/1656, dated:
30th December, 2010, left by deceased Punhoon son of Bux Ali and
for disbursement thereof amongst all the legal heirs viz. applicant and
opponents No.1 to 3, according to their legal share on the
consideration of the following facts and grounds.
F A C T S.
Facts leading to the present application are that the
Honourable Court was pleased to issue Succession Certificate in
respect of amount of Rs.24,322.49, to be withdrawn from Habib Bank
Limited Sakrand Branch. However, the applicant was enquiring other
amounts left by the deceased and have come to know about the
aforesaid assets/ amount / articles of deceased Punhoon and enquired
from the concerned, on which they required Succession Certificate,

hence this application for extended Succession Certificate, in favour of
the applicant on the following grounds :-
P/2…
G R O U N D S.
1. That all the legal formalities were complied with while issuing
succession Certificate dated: 31.05.2010, by this Honourable court
with regard to the legal heirs of late Punhoo son of Buxal Viz.
publication in newspaper, report from Mukhtiarkar and evidence of the
witnesses.
2. That letter bearing No.REF:IR/HO/1.1-D/1656, dated: 30 th
December, 2010, issued by SSCG , requiring Succession Certificate in
respect of amount of Rs.4,03,560/-, as three installments of
compensation and Rs.2,00,000/- as Group insurance, in total
Rs.6,03,560/- is submitted herewith.
3. That Photostat copy of Succession Certificate dated: 31.05.2010
is submitted herewith as the original was obtained by concerned
authorities after it was issued.
Applicant
V E R I F I C A T I O N.
I, Amir Channa son of Bux Ali Channa, adult, Muslim, r/o: village
Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad, do hereby verify on oath on this _______ day of February,
2011 at Nawabshah, that whatever stated above is true and correct to
the best of my knowledge and belief.
Deponent.

Advocate.
S.A. NO. 2010
Muhammad Yakoob @ Fahad Memon

-------------------------------Applicant
VERSUS
Mst. Husana Begum & Others

------------------------------ Opponents.
appoint opponent No.1, as guardian ad litem for minors opponents
No.2 to 4, for the purpose of obtaining Succession Certificate on the
APPLICANT.
NAWABSHAH.
DATED:
S.A. NO. 2010
Muhammad Yakoob @ Fahad Memon

-------------------------------Applicant
VERSUS
Mst. Husana Begum & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Muhammad Yakoob Alias Fahad son of Muhammad Maroof

Memon, adult, Muslim, r/o: House No. 67, Sarfraz Colony, near Excise
Office, Nawabshah, do hereby state on oath as under:-

2. That accompanying application U/O 32 Rule 3 CPC has been

filed by me, the contents where of are true and may be read as part of
this affidavit.
3. That opponent No.1, is real mother of minors, and the minors

are under the care and custody of opponent No.1, and she has no
interest in the matter in controversy in the application adverse that of
minors and that she is a fit person to be so appointed.

allowed.

is not allowed.

Deponent.
Advocate.
Letter of Administration No. of 2011
Aamir Khan Magsi

-------------------------------Applicant
VERSUS
Mst. Shahjahan & Others

------------------------------ Opponents.
It is prayed on behalf of the applicant that this
Honourable Court may be pleased to appoint opponent No.1, as
guardian ad litem for minor Opponent No.4, for the purpose of
obtaining Letter of Administration on the consideration of the grounds
mentioned in the accompanying affidavit.
ADVOCATE FOR APPLICANT.

NAWABSHAH.
DATED:
Letter of Administration No. of 2011
Aamir Khan Magsi

-------------------------------Applicant
VERSUS
Mst. Shahjahan & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Aamir Khan son of Dost Muhammad Magsi, adult, Muslim,

r/o: Village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir
Abad, Nawabshah, do hereby state on oath as under:-

2. That accompanying application U/O 32 Rule 3 CP C has been

filed on my instructions, the contents where of are true and may be
read as part of this affidavit.
3. That Opponent No.1, is real mother of minor, and the minor is

under the care and custody of opponent No.1, and she has no interest
in the matter in controversy in the application adverse that of minor
and that he is a fit person to be so appointed.

allowed.

is not allowed.

Deponent.
Advocate.
Letter of Administration Application No. of 2011.
Aamir Khan son of Dost Muhammad Magsi,

muslim, adult, r/o: village Buxo Magsi,
Taluka Sakrand, District Shaheed Benazir
Abad.
--------------------------Applicant.
Versus.
19. Mst. Shahjah Wd/O Dost Muhammad Magsi.

20. Aftab Ahmed so of Dost Muhammad Magsi.
21. Mst. Sindu D/O Dost Muhammad Magsi
22. Baby Sadaf D/O Dost Muhammad Magsi,

minor aged about 15 year, through her mother
and natural guardian, Mst. Shahjahan, the
opponent No.1,
23. Mst. Pathani W/O Ali Hassan Magsi
all r/o: village Buxo Magsi, Taluka Sakrand,

24. Public at large

-----------------------Opponents.


1). That late Dost Muhammad S/O Ali Hassan Magsi, r/o: village Buxo
Magsi, Taluka Sakrand, District Shaheed Benazir Abad, died on 10.04.2010, for
which death certificate is submitted herewith as annexure “A”.
P/2…
P/2…
opponents No. 1 to 5 as his sole legal heirs. Applicant is son, while opponents
No. 1 is widow, the opponents No.2 son, 3 and 4 are daughters, opponent
No.5, is mother of the said deceased.
4). That said deceased at the time of his death left gold, mortgaged in
National Bank of Pakistan, Mohni Bazar Branch, Nawabshah, weighing 82.700
grams as gross weight which became 53-000 grams as net weight of the gold,
amounting to Rs.74,000/- for which he obtained loan, which are to be
deposited, such certificate / letter bearing No. MOHNI/HRN/10/, dated:
01.12.2010, issued by NBP, Mohni Bazar Brnach, Nawabshah is submitted
herewith as annexure “B.
6). That to withdraw the gold aforesaid from the National Bank of
Pakistan, Mohni Bazar Nawabshah, a Letter of administration is required by
the applicant and opponents No. 1 to 5, hence this application.
enactment for the time being in force to the grant of the Letter of
Administration or the validity thereof if it were granted.
PRAYER
gold aforesaid, from concerned Bank, for disbursement thereof
amongst all the legal heirs, according to their legal shares, after
deducting the amount to be deposited against the loan of the
gold.
Applicant
P/3…
VERIFICATION.
I, Aamir Khan son of Dost Muhammad Magsi, adult, Muslim,

r/o: village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir Abad, do
hereby verify on oath on this _________ day of January, 2011 at Nawabshah,
and belief.
Deponent
I know the deponent
Advocate
Documents filed

1. Same as above
LIST OF WITNESSES:
4. Ghulam Murtaza son of Ali Nawaz Magsi.

5. Shahid Latif son of Noor Muhammad Magsi
Village Buxo Magsi, Taluka Sakrand,


the application.
(AMEER ALI
MAHESSAR)
Nawabshah.
Dated :
IN THE COURT OF THE DISTRICT
JUDGE, SHAHEED BENAZIR ABAD
Succession Application No.

of 2011.
IN THE COURT OF 2ND

ADDITIONAL DISTRICT JUDGE,
Succession Application No.

OF 2010.
Gul Jahan
-------------------------------
Applicant.
VERSUS
Gul Rehman &

Others
------------------------------
Opponents.
STATEMENT.
I, with draw the above said
succession application as the same
was filed due to bonafide mistake
and I am to file application for
letter of administration, therefore
the documents attached may be
returned.
Nawabshah
Dated: 10-03-2010

Versus
Public at Large
: - STATEMENT - :
I, hereby produced Photostat copy of NIC of Abdul
Hameed father of deceased Mehar Afroze , as required by the NADRA.

Nawabshah.
Dated:
-: R E C I P T :-
I have received an amount of Rs.52,839-00, being opponent

No.5, from applicant Mst. Yasmeen being my share in the amount left
by my father in Succession Application No. 1 of 2010.
(Ahsan Raza S/O Syed Hassan Raza)

-: R E C I P T :-
I have received an amount of Rs.52,839-00, being opponent

No.4, from applicant Mst. Yasmeen being my share in the amount left
by my father in Succession Application No. 1 of 2010.
(Shabbar Raza S/O Syed Hassan Raza)

IN THE COURT OF IIND ADDITONAL DISTRICT JUDGE,
Succession Application No. 20 OF 2009.
Mst. Rehana & another

-------------------------------Applicants.
VERSUS
Baby Amna & Others

------------------------------ Opponents.
: - STATEMENT - :
It is jointly prayed by both the parties by admitting the claim of
each other that the Honorable Court may be pleased to issue two separate
Succession Certificate , one in favour of the applicants authorizing /
empowering applicant NO.1, to withdraw the amount the banks concerned of
her as well as applicant No.2, for their respective share viz. ___________, and
an other Succession Certificate in favour of opponents empowering /
authorizing the attorney of the opponents in respect of the share of the
opponents viz. ________________,
Applicant No.1 for Attorney of the

opponents.
herself and on behalf of
her minor daughter.
Advocate for applicants Advocate for Opponents.

IN THE COURT OF IIND. ADDITIONAL DISTRICT JUDGE, SHAHEED BENAZIR
ABAD.
Ameer ----------- Versus ------------------- Mst. Zuhraan & Others

-
A F F I D A V I T.
I, Suleh W/O Bux Ali Channa, adult, muslim, r/o: village Haji Allah
Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed Benazir Abad,
1. That I am Opponent No.2 in the above matter and my son late

Punhoon Died on 10.02.2010 and at the time of death he was permanent
r/o: Village Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District
Shaheed Benazir Abad, and was a Sunni Muslim.
2. That said deceased left an amount of Rs. 24322.49/- with Habib

Bank, Sakrand Branch, for which Succession Certificate dated
31.05.2010, however, later on enquiry it has come to know that
further amount of Rs.6,03,560/- is lying with SSGC Limited, who
required Succession Certificate for releasing thereof, for which
Succession Certificate is required.

department, a succession certificate is required by us.

to grant Succession Certificate in favour of applicant, authorizing/
empowering him to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from concerned
department for disbursement thereof amongst all the legal heirs
according to our legal share, in accordance with law.

Deponent.
Advocate.
Ameer
-------------------------------Applicant
VERSUS
Mst. Zhurran & Others

------------------------------ Opponents.
STATEMENT
Share of legal heirs are as under :
1. Mst. Zuhraan Widow 25% Rs.6080.62

2. Ameer Brother . 39% Rs.9458.75
3. Mst. Suleh Mother 16.5% Rs.4053.74
4. Mst. Haseena Daughter 19.5% Rs.4729.37
_____________________________
TOTAL Rs.24322.49
---------------------------------------------

Nawabshah.
Dated:05.04.2010
Ameer
-------------------------------Applicant
VERSUS

------------------------------ Opponents.
A F F I D A V I T.
I, Haseena D/O Bux Ali Channa, adult, muslim, r/o: village

Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District
1. That I am Opponent No.3 in the above matter and hence fully

conversant with the facts of the present application.
2. That my brother late Punhoon S/O Bux Ali Channa, died on

10-02-2010.
3. That said deceased Punhoon was permanent r/o: Village Haji

Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad, and was a Sunni Muslim.
4. That said deceased left applicant and us Opponents Nos. 1 to 3

his sole legal heirs.


department , a succession certificate is required by us.


Deponent.
Advocate
Ameer
-------------------------------Applicant
VERSUS

------------------------------ Opponents.
A F F I D A V I T.
I, Zuhraan Wd/O Punhoon Channa, adult, muslim, r/o: village


2. That my husband late Punhoon S/O Bux Ali Channa, died on

10-02-2010.
3. That said deceased Punhoon was permanent r/o: Village Haji

Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad, and was a Sunni Muslim.



department , a succession certificate is required by us.


Deponent.
Advocate
Ameer
-------------------------------Applicant
VERSUS

------------------------------ Opponents.
A F F I D A V I T.
I, Ameer Channa son of Bux Ali Channa, adult, muslim, r/o:

village Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District

2. That my brother late Punhoon S/O Bux Ali Channa died on 10-
02-2010. I produce death certificate as Ex:__________.
3. That said deceased Late Punhoon was permanent r/o village

Shaheed Benazir Abad and was a Sunni Muslim.

legal heirs. I am brother, while opponents Nos.1 to 3, Widow, mother
and sister respectively of deceased Punhoon.
5. That said deceased left an amount of Rs.24,322.49, with Habib
Bank Limited Sakrand Branch, at the time of his death. I produce
Bank Balance Certificate as Ex. _____________.
P/2…
P/2…
7. That such heir ship certificate issued by the Mukhtiarkar
(Revenue), Nawabshah is submitted as Ex._________________.
were granted.
Deponent.
Advocate
Ameer
-------------------------------Applicant
VERSUS

------------------------------ Opponents.
APPLICATION FOR VERIFICATION OF

THE LEGAL HEIRS OF DECEASED PUNHOON S/O BUX ALI CHANNA
It is submitted that Punhoon S/O Bux Ali Channa, r/o: Village Haji
Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed Benazir
Abad, died on 10-02-2010, leaving behind the following legal heirs;
5. Ameer Brother.
6. Mst. Zuhrran Widow.
7. Mst. Suleh Mother
8. Mst. Haseena Sister
All muslims, adults, r/o: Village Bux Ali Channa,

Deh 39 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad.
It is therefore, prayed that Mukhtiarkar (Revenue) Taluka

Nawabshah, may be directed to verify the legal heirs of deceased PUnhoon
S/O Bux Ali Channa, r/o: Village Haji Allah Dad Mari, Deh 39 Dad, Taluka
Nawabshah, District Shaheed Benazir Abad.

Nawabshah.
Dated:05.04.2010
Ameer
-------------------------------Applicant
VERSUS

------------------------------ Opponents.
A F F I D A V I T.
I, Nazeer Ahmed son of Khan Muhammad, adult, muslim, r/o:

Village Imam Bux Mari, Taluka Nawabshah, District Shaheed Benazir
Abad, Nawabshah, do hereby state on oath as under:-
1. That I know applicant and opponents Nos. 1 to 3.
2). That deceased Punhoon S/O Bux Ali Channa was my relative
died on 10.02.2010, and left behind him his sole legal heirs the
applicant and Opponents No. 1 to 3.
3). That said deceased Punhoon Channa was permanent resident of

Village Imam Bux Mari, Taluka Nawabshah, at the time of his death.
4). That applicant is brother of the said deceased while Opponents

No. 1 to 3 are widow, mother and sister respectively.
5). That said deceased at the time of his death left behind him an
amount of Rs.24322.49/- with Habib Bank Limited Sakrand Branch, for
which succession certificate is required to the applicant and
Opponents Nos. 1 to 3.

and belief.
Deponent.
Advocate
Ameer Channa S/O Bux Ali Channa, adult,

muslim, r/o: Village Haji Allah Dad Mari,
Deh 39 Dad, Taluka Nawabshah, District
--------------------------Applicant.
Versus.
25. Mst. Zuhraan Wd/O Punhoon Channa.

26. Mst. Suleh W/O Bux Ali Channa.
27. Mst. Hassena D/O Bux Ali Channa
All adults, muslims, r/o: Village Haji Allah

Dad Mari, Deh 39 Dad, Taluka Nawabshah,
28. Public at large

-----------------------Opponents.

1). That late Punhoon S/O Bux Ali Channa, r/o: Village Haji Allah
Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed Benazir Abad,
died on 10.02.2010, for which death certificates is submitted herewith as
annexure “A”.
opponents No. 1 to 3 as his sole legal heirs. Applicant is brother, while
opponents No. 1 to 3 , is widow, mother and Sister respectively of the said
deceased.
P/2…
P/2…
applicant and opponents No.1 to 3, such Heir ship Certificate issued by the
Mukhtiarkar (Revenue) Nawabshah is submitted as annexure “B”.
4). That said deceased at the time of his death left an amount of
Rs.24322.49/- with Habib Bank Limited Sakrand Branch, Such certificate
issued by Manger, is submitted herewith as annexure “C”.
6). That to withdraw the amount aforesaid from Bank, a succession

certificate is required by the applicant and opponents No. 1 to 3, hence this
application.
PRAYER

be pleased to issue a Succession Certificate in his favour
Applicant
P/3…
P/3…
VERIFICATION.
I, Ameer S/O Bux Ali Channa, adult, muslim, r/o: Village Imam
Bux Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed Benazir Abad,
do hereby verify on oath on this 05th day of April, 2010 at Nawabshah, that
whatever stated above is true and correct to the best of my knowledge and
belief.
Deponent
I know the deponent
Advocate
Documents filed
As Annexure "A" to "C".

1. Same as above
LIST OF WITNESSES:
2. Mukhtiar Ali son of Rano Khan Channa.

3. Nazeer Ahmed S/O Khan Muhammad
Both r/o: Village Allah Dad Mari, Deh 39 Dad,

Taluka Nawabshah, District Shaheed Benazir Abad.

the application.
(AMEER ALI
MAHESSAR)
Nawabshah.
Dated: 05.04.2010
IN THE COURT OF 2ND ADDITIONAL DISTRICT JUDGE, SHAHEED
BENAZIR ABAD.
Gul Jahan
-------------------------------Applicant.
VERSUS
Gul Rehman & Others

------------------------------ Opponents.
STATEMENT.
I, with draw the above said succession application as the same was
filed due to bonafide mistake and I am to file application for letter of
administration, therefore the documents attached may be returned.
Nawabshah Advocate for
Applicant
Dated: 10-03-2010
Letter of Administration Application No. OF 2010.
Gul Jahan
-------------------------------Applicant.
VERSUS
Gul Rehman & Others

------------------------------ Opponents.

THE LEGAL HEIRSOF DECEASED MANZOOR HUSSAIN S/O GHULAM
MUHAMMAD MAGSI.
It is submitted that Manzoor Hussain S/O Ghulam Muhammad

Magsi, r/o: village Ghulam Ali Magsi, Deh 29 Dad, Taluka Nawabshah,
District Shaheed Benazir Abad, died on 20-01-2008, leaving behind the
following legal heirs;
9. Gul Jahan son.

10. Gul Rehman son.
11. Mst. Rasheeda Widow
All muslims, adults, r/o: Village Ghulam Ali

Magsi, Deh 29 Dad, Taluka Nawabshah, District
Nawabshah, may be directed to verify the legal heirs of deceased Manzoor
Hussain S/O Ghulam Muhammad Magsi, r/o: village Ghulam Ali Magsi,
Deh 29 Dad, Taluka Nawabshah, District Shaheed Benazir Abad.

Nawabshah.
Dated:10.03.2010
Letter of Administration Application No. OF 2010.
Gul Jahan
-------------------------------Applicant.
VERSUS
Gul Rehman & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Tarique Hussain son of Ghulam Muhammad Magsi, adult,

muslim, r/o: village Ghulam Alli Magsi, Deh 29 Dad, Taluka
Nawabshah , District Shaheed Benazir Abad, do hereby state on oath
as under:-
1. That I know applicant and opponents No. 1 and 2.
2). That deceased Manzoor Hussain Magsi was my close relative,

died on 20.01.2008, and left behind him his sole legal heirs the
applicant and opponent No.1 and 2.
3). That said deceased Manzoor Hussain Magsi was permanent

resident of Village Ghulam Muhammad Magsi, Deh 29 Dad, Taluka
Nawabshah, District Shaheed Benazir Abad.
4). That applicant is son of the said deceased while opponents NO.1
and 2 are son and widow respectively .
5). That said deceased at the time of his death left behind him gold
ornaments in National Bank of Pakistan Mohni Bazaar Branch,
Nawabshah, for which Letter of Administration is required to the
applicant and opponents No.1 and 2.
6). That prior to this no any application on the part of the applicant
and opponents No. 1 and 2 have been moved before any court or
authority , competent to issue or grant.
Deponent.
Advocate
Letter of Administration Application No. of 2010.
Gul Jahan S/O Manzoor Hussain , adult,

muslim, r/o: Village Ghulam Ali Magsi, Deh
29 Dad, Taluka Nawabshah, District
--------------------------Applicant.
Versus.
29. Gul Rehman S/O Manzoor Hussain.

30. Mst. Rasheedan Wd/O Manzoor Hussain.
Both adults, muslims, r/o: Village Ghulam Ali Magsi,
Deh 29 Dad, Taluka Nawabshah,
31. Public at Large.

-----------------------Opponents.

1). That late Manzoor Hussain son of Ghulam Muhammad Magsi,

died on 20.01.2008, for which death certificate is submitted herewith as
annexure “A”.
2). That said deceased Manzoor Hussain was permanent resident of

Village Ghulam Ali Magsi, Deh 29 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad.
opponents No. 1 & 2 as his sole legal heirs. Applicant and opponent No.1, are
sons and opponent No.2 is widow of said deceased.
4). That said deceased was Sunni muslim and so are his legal heirs, the
applicant and opponents No.1 & 2.
P/2…
P/2…
5). That said deceased at the time of his death left gold, mortgage in
National Bank of Pakistan, Mohni Bazar Branch, Nawabshah, weighing 173
grams as gross weight which became 100 grams as net weight of the gold,
amounting to Rs.70,000/- for which he obtained loan, which has been
deposited and such clearance certificate issued by Manger, NBP, Mohni Bazar,
Nawabshah, is submitted herewith as annexure “B & C”.
7). That to withdraw the gold aforesaid from the National Bank of
Pakistan, Limited Mohni Bazar Nawabshah, a Letter of administration is
required by the applicant and opponents No. 1 & 2, hence this application.
PRAYER
gold aforesaid, from concerned Bank, for disbursement thereof

Applicant
P/3…
P/3…
VERIFICATION.
I, Gul Jahan S/O Manzoor Hussain Magsi, adult, muslim, r/o:

village Ghulam Muhammad Magsi, Taluka Nawabshah, District Shaheed
Benazir Abad, do hereby verify on oath on this 10th day of March, 2010 at
Deponent
I know the deponent
Advocate
Documents filed

1. Same as above
LIST OF WITNESSES:
6. Tarique Hussain S/O Ghulam Muhammad Magsi.

7. Fakir Muhammad S/O Haji Mir Muhammad Magsi
adults, muslims, r/o: Village Ghulam Muhammad,

Deh 29 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad.
the application.
(AMEER ALI
MAHESSAR)
Nawabshah.
Dated : 10.03.2010
IN THE COURT OF IIND ADDITONAL DISTRICT JUDGE,

-------------------------------Applicants.
VERSUS
Baby Amna & Others

------------------------------ Opponents.
REPLECATION TO OBJECTIONS FILED

ON BEHALF OF OPPONENTS No.3 ,6 to 11 .
I, Rehana Arshad Wd/O Late Arshad Mehmood Awan, adult,

muslim, r/o: Peela Camp No.1, Line-par, UC No.08, Nawabshah town, do
hereby state on oath as under :-
1). That I am applicant No.1, in the above matter and hence fully
conversant with the facts of the same.
2). That I entered into marriage with late Arshad Mehmood on 25.07.2000,
copy of Nikahnama is submitted herewith as annexure "A".
3). That from this wedlock I gave birth to a Baby namely Mah Noor D/O
Arshad Mehmood on 10.11.2001, such certificate issued by Nazim Union
Council No.8, Nawabshah is submitted herewith as annexure "B".
4). That after the death of my late husband, I applied for special leave for
observing Iddat from Executive District Officer, Education , District Shaheed
Benazir Abad, such order granting 130 days leave is submitted herewith as
annexure "C".
5). That my baby Mah Noor D/O Late Arshad Mehmood has been
receiving education in Govt. Girls Model Primary School Line Par,
Nawabshah, such certificate issued by Head Mistress is submitted herewith as
annexure "D".
P/2…
P/2…
6). That Form "B" obtained from NADRA , showing Baby Mah Noor D/O
Late Arshad Mehmood Awan is submitted herewith as annexure "E".
7). That at the time of death of late Arshad Mehmood opponent No.1 Baby
Amna, who was studying in 08th class was residing with me but after death of
late Arshad Mehmood Awan, opponent No.3 took her with him.
8). That neither my late husband pronounced divorce to me nor issued

any "Talaq Nama" as alleged dated: 04.01.2006, on behalf opponents No. 3, 6
to 11, which is creative of mind of the opponents in collusion with Fida-ur-
Rehman nothing but to usurp the valuable rights of me and my daughter
Baby Mah Noor with malafide intention and for ulterior motive and in this
regard they had also illegally occupied the property of my late husband and
the documents in respect of that property. The witnesses shown by the
respondents to be the alleged witnesses of the Talaq Nama are set-up persons
of the opponents to defraud me and my daughter to deprive of our valuable
rights. It is further submitted that neither Haq Mahar in the life time of my
late husband was given to me nor any divorce was taken place. It is strange
that the alleged Talaq Nama which is other wise false is dated: 04.01.2006 and
the date of birth of my daughter Baby Mah Noor is 10.11.2001 and the
Nikahnama is dated: 25.07.2000, therefore, the contention on behalf of the
opponents is itself contradictory form which the malafide intention on their
part is reflecting. It is also submitted that I and my daughter baby Mah Noor
are very much entitled to obtain our legal rights by inheriting whatever the
property left by my late husband according to our legal share, but opponent
No.3 and Fida-ur-Rehman , who are very cunning and shrewd persons have
been trying to deprive us from our valuable rights and have even made a lot
of fraud in respect of property of my late husband. It is further submitted that
the cheque and receipt of Courier service has also been managed as neither I
had been given the cheque nor it was enchased at all.
9). That my husband was business man having movable and immoveable
properties in his name in Nawabshah and other cities and he also to get his
brother in law namely Fida-ur-Rehman, employed in Askari Bank limited
Nawabshah, deposited Rs.65/70 Lacks , in his account, but said Fida –ur-
Rehman in collusion and connivance of respondent No.3 by playing fraud did
not show the amount of the deceased to usurp the same.
P/3…
P/3…
10). That after the death of my late husband I went into shock and taking the
undue advantage of the same opponents No. 3 to 11 in collusion with Fida-ur-
Rehman took all the documents of the property and record of bank deposit
and other valuables with them and also driven me out from the house, that
was a reason why, I performed my Iddat in the house of my parents.
11). That I also got notices issued to the Manager / M/S National Bank of
Pakistan Mohni Bazaar Branch Nawabshah and M/S Bank Al-Flah in which
my late husband was running the accounts, but they refused to provide such
information subject to orders from the Court of law, because of influence of
Fida-ur-Rehman.
12). That the malafide on the part of that Fida-ur-Rehman to whom my late
husband got employed in Bank Askari can be judged that he got himself
appointed the attorney of other opponents and has filed the objections on his
part which is nothing but creative of mind of him to usurp the valuable rights
of the original legal heirs of the deceased.
13). That I along with my daughter being the legally wedded wife and
daughter of late Arshad Mehmood Awan respectively are entitled to get our
due share in accordance with law from the properties of deceased left by him
at the time of his death.
Deponent.
Advocate.
Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.
STATEMENT.
I have no objection if the Honourable Court may be pleased to
appoint me as guardian ad litim for the opponent No.6, in the above matter,
as I am ready for the same.
Opponent No.1.
Advocate for Opponents No.1 to 6.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Ahsan Raza S/O Late Hassan Raza, muslim, adult, r/o:

House # 5, Officers Colony, Habib Sugar Mills Limited Nawabshah, do

2. That my father late Hassan Raza Son of Ghulam Imam died on

11-10-2009.
3. That said deceased Late Hassan Raza was permanent r/o:

House # 5, Officers Colony, Habib Sugar Mills Limited Nawabshah and
was a Shia Muslim.

5. That said deceased left an amount of Rs.7775/- with Bank Al

Habib Limited Nawabshah Branch and an amount of Rs.3,54, 749
with Habib Sugar Mills Limited Nawabshah at the time of his death.

Bank and Habib Sugar Mills Limited Nawabshah, a succession
certificate is required by us.

empowering her to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from bank and
Habib Sugar Mills Limited Nawabshah etc for disbursement thereof
amongst all the legal heirs according to our legal share, in accordance
with law.

Deponent.
Advocate
Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Ali Asghar son of Hassan Imam, adult, muslim, r/o: Camp

No.2, Nawabshah, do hereby state on oath as under:-
1. That I know applicant and opponents Nos. 1 to 6.
2). That deceased Syed Hassan Raza was my relative died on

11.10.2009, at left behind him his sole legal heirs the applicant and
Opponents No. 1 to 6.
3). That said deceased Syed Hassan Raza was permanent resident
of Officers Colony, Habib Sugar Mills Limited Nawabshah, & was
serving as Senior Electrician , in Habib Sugar Mills Limited
Nawabshah, at the time of his death.
4). That applicant is widow of the said deceased while Opponents

No. 1 to 6 are sons of said deceased.
amount of Rs.7775/- with Bank Al Habib Limited Nawabshah Branch
and an amount of Rs.3,54,749/- with Habib Sugar Mills Limited
Nawabshah, for which succession certificate is required to the
applicant and Opponents Nos. 1 to 6.

and belief.
Deponent.
Advocate
Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.
STATEMENT
Share of legal heirs are as under :
12. Mst. Yasmeen Raza Widow Rs.45,290-00

13. Aamir Raza son. Rs.52839-00
14. Farukh Raza son Rs.52839-00
15. Mubashar Raza son Rs.52839-00
16. Shabbar Raza son Rs.52839-00
17. Ahsan Raza son Rs.52839-00
18. Ali Raza son ( Minor) Rs.52839-00
_____________________________
TOTAL Rs.3,62,324-00
---------------------------------------------

Nawabshah.
Dated:01.01.2010
Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.
APPLICATION U/R 14 OF
SINDH CIVIL COURT RULES.
It is prayed on behalf of the applicant that this Honourable court
may be pleased to treat the above matter as urgent one and take the same
up for the purpose of admission as the same requires urgency on the
Advocate for applicant.

Nawabshah.
Dated: 01.01.2010
Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.
A F F I D A V I T.
I, Yasmeen Raza Wd/O Hassan Raza Syed, adult, muslim, r/o:

House No. 5, Officer Colony, Habib Sugar Mills Limited, Nawabshah,
2. That accompanying application U/R 14 of Sindh Civil Court Rules has

been drafted under my instruction and the contents whereof to avoid
repetition be treated true and correct.
3). That to withdraw the amount mentioned in para No.5 of Successions

Application and to approach Sindh Worker Welfare Board, for the dues of the
said deceased a Succession Certificate is required in limited time, hence this
application.
4). That I shall suffer serious loss and injury if my accompanying

application is not allowed.
and belief.
Deponent.
Advocate.
Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.

THE LEGAL HEIRSOF DECEASED HASSAN RAZA SON OF
GHULAM IMAM SYED
It is submitted that Hassan Raza son of Ghulam Imam, Syed r/o:

House No.5, Officers colony, Habib Sugar Mills, Limited Nawabshah, died on
11-10-2009, leaving behind the following legal heirs;
19. Mst. Yasmeen Raza Widow

20. Aamir Raza son.
21. Farukh Raza son
22. Mubashar Raza son
23. Shabbar Raza son
24. Ahsan Raza son
25. Ali Raza son ( Minor)
All muslims, adults, except No.8, who is minor

aged about 13 years, R/O: H # 5, Officers Colony,
Habib Sugar Mills Limited, Nawabshah.

Nawabshah, may be directed to verify the legal heirs of deceased Hassan Raza
son of Ghulam Imam Syed, r/o: House NO.5, Officers Colony, Habib Sugar
Mills Limited Nawabshah.

Nawabshah.
Dated:01.01.2010
Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.
It is prayed on behalf of the applicant that this
Honourable Court may be pleased to appoint opponent No.1, as
guardian ad litem for minor Opponent No.6, for the purpose of
obtaining Succession Certificate on the consideration of the grounds
mentioned in the accompanying affidavit.
ADVOCATE FOR APPLICANT.

NAWABSHAH.
DATED: 01-01-2010
Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.
A F F I D A V I T.

House No. 5, Officer Colony, Habib Sugar Mills Limited, Nawabshah,

2. That accompanying application U/O 32 Rule 3 CP C has been

filed on my instructions, the contents where of are true and may be
read as part of this affidavit.
3. That I am real mother of minor, and proposed guardian is real

brother of opponent NO.6, who under the care and custody of
opponent No.1, and he has no interest in the matter in controversy in
the application adverse that of minor and that he is a fit person to be
so appointed.

allowed.

is not allowed.

Deponent.
Advocate.
Mst. Yasmeen Raza Wd/O Hassan Raza

Syed, adult, muslim, r/o: House # F-5,
Officer Colony, Habib Sugar Mills Colony,
Nawabshah.
--------------------------Applicants.
Versus.
32. Aamir Raza son of Hassan Raza, adult, muslim.

33. Farukh Raza son of Hassan Raza, adult, muslim.
34. Mubashar Raza Son of Hassan Raza adult, muslim.
35. Shabbar Raza son of Hassan Raza , adult, muslim.
36. Ahsan Raza son of Hassan Raza, adult, muslim.
37. Ali Raza son of Hassan Raza, minor, aged
about 13 years, through his next friend and
real brother Aamir Raza, Opponent No.1, all
r/o: House # F-5, Officer Colony, Habib
Sugar Mills Limited, Nawabshah.
38. Public at large

-----------------------Opponents.

1). That late Hassan Raza son of Ghulam Imam, Syed died on
2). That said deceased Syed Hassan Raza was permanent resident
of House No.F-5, Mohalla Habib Sugar Mills Officers, Colony, Nawabshah,
Taluka Nawabshah, District Shaheed Benazir Abad and was serving as Senior
Electrician in Habib Sugar Mills Limited Nawabshah.
P/2…
P/2…
opponents No. 1 to 6 are sons of the said deceased.
4). That said deceased was Shia muslim and so are his legal heirs, the
5). That said deceased at the time of his death left an amount of Rs.7,775/-
with Bank Al Habib Limited Nawabshah Branch, Such certificate issued by
Manger, is submitted herewith as annexure “B”, and an amount of Rs.3,54,
749-00 with Habib Sugar Mills Limited Nawabshah, such Certificate
dated: 30.12.2009, issued by (General Manger),Finance and Accounts
Nawabshah, is submitted herewith as annexure "C".
7). That to withdraw the amount aforesaid from the Bank Al Habib
Limited Nawabshah Branch and from Habib Sugar Mills Limited
Nawabshah, a succession certificate is required by the applicant and
opponents No. 1 to 6, hence this application.
PRAYER
be pleased to issue a Succession Certificate in her favour
authorizing/ empowering her to get/ with draw/ receive the
withdrawal from concerned Bank and institution, for
disbursement thereof amongst all the legal heirs, according to
their legal shares.
Applicant
P/3…
VERIFICATION.

House # 5, Officer Colony, Habib Sugar Mills Limited, Nawabshah, do
hereby verify on oath on this ________day of January, 2010 at Nawabshah,
and belief.
Deponent
I know the deponent
Advocate
Documents filed

1. Same as above
LIST OF WITNESSES:
2. Ali Asghar son of Hassan Imam

3. Hussain Ali son of Ali Asghar
Both adults, muslim, r/o: Habib Sugar Mills Colony,

Nawabshah.

the application.
(AMEER ALI
MAHESSAR)

-------------------------------Applicants.
VERSUS
Baby Amna & Others

------------------------------ Opponents.
STATEMENT
I, hereby produced second address of Mst. Alam Ara, as
provided by applicant No.1, as under:-
House No.H-29, near Aqab Central Jail,

Pir Illahi Bux Colony & Ghosia Masjid,
Karachi No.5, District
Advocate for applicant

Nawabshah.
Dated:
Mst. Abida
-------------------------------Applicant
VERSUS
Ghafoor & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Sharifan W/O Ghafoor Sial, muslim, adult, r/o: village

Salahuddin Dahri, Taluka Sakrand, District Shaheed Benazir Abad,

2. That my son late Shahbaz Khan son of Ghafoor Sial died on 04-
03-2009.
3. That said deceased Late Shahbaz was permanent r/o village

Salahuddin Dahri, Taluka Sakrand, District Shaheed Benazir Abad

5. That said deceased left an amount of Rs.1,00,000 and profit

there on Rs.30,630-14, Fixed Deposit of MPDC No.001977 and /- at
the time of his death.


to grant Succession Certificate in favour of applicant, authorizing /
interest to be accrued up to the date of withdrawal from bank etc for
disbursement thereof amongst all the legal heirs according to our legal
share, in accordance with law.

Deponent.
Advocate
Mst. Abida
-------------------------------Applicant
VERSUS
Ghafoor & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Ghafoor son of Ismail Sial, muslim, adult, r/o: village

1. That I am Opponent No.1 in the above matter and proposed

Guardian of Opponents No. 3 to 6 and also hence fully conversant
with the facts of the present application.
2. That my son late Shahbaz Khan son of Ghafoor Sial died on 04-
03-2009.





to grant Succession Certificate in favour of applicant, authorizing /
interest to be accrued up to the date of withdrawal from bank etc for
share, in accordance with law.

Deponent.
Advocate
Mst. Abida
-------------------------------Applicant
VERSUS
Ghafoor & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Abida Wd/O Shahbaz Khan Sial, muslim, adult, r/o: village


2. That my husband late Shahbaz Khan son of Ghafoor Sial died

on 04-03-2009. I produce death certificate as Ex:__________.


legal heirs. I am widow, while opponent No.2 is father and Opponent
No.3 is mother of deceased Shahbaz; Opponents Nos. 3, 5 and 7 are
sons and opponent No.4 daughter of deceased Shahbaz.

the time of his death. I produce Bank Balance Certificate as Ex.
_____________.
P/2…
P/2…
were granted.

Deponent.
Advocate
Imam Zadi & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
A F F I D A V I T.
I, Abdul Jabbar son of Waryam Khan Pahi, adult, muslim, r/o:

Village Malook Khan Pahi, Taluka Sakrand, District Shaheed Benazir
Abad, do hereby state on oath as under:-
1. That I know applicants.
2). That deceased Muhammad Rahim was my cousin died on

14.01.2009, at left behind him his sole legal heirs the applicants No. 1
to 6.
3). That said deceased Muhammad Rahim was permanent resident

of Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad & was serving as dispenser, in Health Department, at
4). That applicant No.1 is widow of the said deceased while

applicant No. 2 is mother and applicants No.3 to 6 are son and
daughters respectively.
amount of Rs.8500/- in National Bank of Pakistan, Engineering
University Branch Nawabshah, for which succession certificate is
required to the applicants.
6). That prior to this no any application on the part of the

applicants have been moved before any court or authority , competent
to issue or grant.

Deponent.
Advocate
Imam Zadi & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
A F F I D A V I T.
I, Abdul Sattar son of Muhammad Malook Pahi, adult, muslim,

r/o: Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad, do hereby state on oath as under:-
1. That I know applicants.
2). That deceased Muhammad Rahim was my maternal nephew

died on 14.01.2009, at left behind him his sole legal heirs the
applicants No. 1 to 6.

of Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad & was serving as dispenser, in Health Department, at

applicant No. 2 is mother and applicants No.3 to 6 are son and
daughters respectively.
amount of Rs.8500/- in National Bank of Pakistan, Engineering
University Branch Nawabshah, for which succession certificate is
required to the applicants.

to issue or grant.

Deponent.
Advocate
Imam Zadi & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
APPLICATION U/O 32 RULE 3 (2) CPC
It is prayed on behalf of the applicant No.1, that this
Honourable Court may be pleased to appoint her as guardian ad litem
for minors applicants (1) Abdul Rehman, (2) Mst. Shumaila, (3) Mst.
Aneela and (4) Mst. Fiza for the purpose of obtaining Succession
Certificate on the consideration of the grounds mentioned in the
accompanying affidavit.
ADVOCATE FOR APPLICANTS.

NAWABSHAH.
DATED: -07-2009
Imam Zadi & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
A F F I D A V I T.
I, Imam Zadi Wd/O Muhammad Rahim Pahi, adult, muslim,

r/o: Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad, do hereby state on oath as under:-

2. That accompanying application U/O 32 Rule 3 (2) CP C has

been filed on my instructions, the contents where of are true and may
be read as part of this affidavit.
3. That I am real mother of minors, applicants Nos. 3 to 6 I

have no any interest in the matters in controversy in the
application adverse that of minors and that I am a fit person to
be so appointed.

allowed.

is not allowed.

Deponent.
Advocate.
1. Mst. Imam Zadi Wd/O Muhammad

Rahim Pahi.
2. Mst. Sami W/O Abdul Hakeem ,

mother of late Muhammad Rahim
Pahi.
3. Abdul Rehman son of Late

Muhammad Rahim Pahi, aged about
09 years.
4. Mst. Shumaila D/O Late Muhammad

Rahim Pahi, aged about 11 years.
5. Mst. Aneela D/O Late Muhammad

Rahim Pahi, aged about 06 years.
6. Mst. Fiza D/O Late Muhammad

Rhaim Pahi, aged about 03 years.
No. 1 and 2 , adults, muslims,

applicants No. 3 to 6 , minors through
their mother and next friend /
guardian ad litm application No.1, all
r/o: Village Malook Pahi, Taluka
Sakrand, District Shaheed Benazir
Abad.
--------------------------Applicants.
Versus.
Public at large
-----------------------Opponents.

The applicants named above humbly submit as under:-
1). That late Muhammad Rahim son of Abdul Hakeem Pahi died on
P/2…
P/2…
of Village Malook Pahi, Taluka Sakrand, District Shaheed Benazir Abad and
was serving as Dispenser in Health Department, therefore, heir ship certificate
was required to be produced there at hence the same was applied before
Mukhtiarkar (Revenue) Sakrand and ultimately same was issued on
12.02.2009, Photostat copy of which is hereby submitted as annexure “B”.
3). That said deceased at the time of his death left the applicants as his sole
legal heirs. Applicant No.1 is widow, application No.2 is mother while
applicant No.3 to 6 are son and daughters respectively of the said deceased.
4). That said deceased was Sunni muslim and so are his legal heirs, the
applicants.
5). That said deceased at the time of his death left an amount of Rs.8,500/-
with National Bank of Pakistan, Engineering University Branch (293),
Nawabshah. Such certificate issued by Manger dated: 28.07.2009, is submitted
herewith as annexure “C”.
7). That to withdraw the amount aforesaid from the concerned Bank, a
succession certificate is required by the applicants, hence this application.
8). That no application has been made to any court so for and no grant has
enactment for the time being in force to grant of the succession certificate or
the validity thereof if it were granted.
9). That the applicants have fully set forth the securities/amount/debts in
PRAYER
The applicants, therefore, pray that the Honourable court may
be pleased to issue a Succession Certificate in their favour
authorizing/ empowering applicant No.1, Mst. Imam Zadi
Wd/O late Muhammad Rahim Pahi to get/ with draw/ receive
the
P/3…
P/3…
amongst all the applicants according to their legal shares.
Applicant No.2. applicant No.1

for herself and for minors,
the applicants No. 3 to 6.
VERIFICATION.
I, Imam Zadi Wd/O Late Muhammad Rahim Pahi, adult,

muslim, r/o: Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad, do hereby verify on oath on this ________day of July, 2009 at
Deponent
I know the deponent
Advocate
Documents filed

1. Same as above
LIST OF WITNESSES:
1. Applicant themselves.
2. Abdul Sattar son of Muhammad Malook Pahi
3. Abdul Jabbar son of Waryam Khan Pahi
All adults, muslim, r/o: Village Malook Khan Pahi,

Taluka Sakrand, District Shaheed Benazir Abad.

instructions of the applicants No.1 & 2.
the application.
(AMEER ALI
MAHESSAR)
Advocate for Applicants.
Sohni & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
A F F I D A V I T.
I, Rahim Dad son of Saleem Zardari, adult, muslim, r/o: Village

Muhammad Laique Zardari, UC-Chanessar-II, Taluka Nawabshah,
District Shaheed Benazir Abad, do hereby state on oath as under:-
1. That I know applicant Mst. Sohni as well as her children

applicants Nos. 2 to 4 .
2). That deceased Muhammad Laique Zardari was my cousin died
on 08.04.2009, at left behind him his sole legal heirs the applicants
No. 1 to 4.
3). That said deceased Muhammad Laique Zardari was permanent

resident of Village Muhammad Laique Zardari, UC Chanessar-II,
Taluka Nawabshah, was serving as Senior Executive Officer, Logistic
Department, Pakistan State Oil company limited at the time of his
death.

applicants No. 2 and 3 are daughters and applicant No.4 is son.
amount of Rs.51,56,214/- being his provident fund , gratuity and
insurance etc, while in his life time he purchased a flat and obtained
loan of Rs.34,92,156/- and repaid only Rs.7,23,738/- while there is
outstanding of Rs.27,68,418/- of National Bank of Pakistan Awami
Markaz Branch, Karachi in respect of said loan.
P/2…
P/2…
6). That to withdraw the amount aforesaid from the concerned

department a Succession Certificate is required to the applicant. The
applicants are Sunni muslims, so also the said deceased

to issue or grant.

Deponent.
Advocate
Sohni & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
A F F I D A V I T.
I, Ghazi Bux son of Ali Bux Khan Zardari, adult, muslim, r/o:
Village Muhammad Laique Zardari, UC-Chanessar-II, Taluka
Nawabshah, District Shaheed Benazir Abad, do hereby state on oath
as under:-
1. That I know applicant Mst. Sohni as well as her children

applicants Nos. 2 to 4 .
2). That deceased Muhammad Laique Zardari was my brother died

on 08.04.2009, at left behind him his sole legal heirs the applicants
No. 1 to 4.

resident of Village Muhammad Laique Zardari, UC Chanessar-II,
Taluka Nawabshah, was serving as Senior Executive Officer, Logistic
Department, Pakistan State Oil company limited at the time of his
death.

applicants No. 2 and 3 are daughters and applicant No.4 is son.
amount of Rs.51,56,214/- being his provident fund , gratuity and
insurance etc, while in his life time he purchased a flat and obtained
loan of Rs.34,92,156/- and repaid only Rs.7,23,738/- while there is
outstanding of Rs.27,68,418/- of National Bank of Pakistan Awami
Markaz Branch, Karachi in respect of said loan.
P/2…
P/2…

department a Succession Certificate is required to the applicant. The
applicants are Sunni muslims, so also the said deceased

to issue or grant.

Deponent.
Advocate
Sohni & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
A F F I D A V I T.
I, Sohni Wd/O Late Muhammad Laique Zardari, adult, Muslim,

r/o: Village Muhammad Laique Zardari, UC-Chanessar-II, Taluka
as under:-

2. That my husband late Muhammad Laique s/o Ali Bux Zardari

died on 08-04-09. I produce death certificate as Ex:__________.
3. That said deceased Muhammad Laique was permanent r/o

village Muhammad Laique Zardari, UC. Chanessar-II, Taluka
Nawabshah, District Shaheed Benazir Abad and was serving as
senior executive officer, Logistic Department, Pakistan State Oil
Company Limited at time of his death.
4. That said deceased left us (the applicants No 1 to 4) as his sole

legal heirs. I am widow, while applicant No 2 and 3 daughters and
applicant No.4 is son of deceased Muhammad Laique Zardari.
5. That said deceased was sunni muslim so also we his legal heirs
(the applicants).
6. That said deceased left an amount of Rs. 51,56,214/- at the

time of his death, which is consisting of provident fund, gratuity and
insurance etc. I produce letter bearing No.HR/7010/2024, June,
26th , 2009, issued by Sumera Manzar, Manger Human resources,
Pakistan State Oil Karachi, as Ex._____________.
P/2…
P/2…
8. That deceased Muhammad Laique Zardari in his life time

obtained loan for purchasing flat in Karachi and amount due against
the said loan was Rs.34,92,156/- while Rs.7,23,738/- were paid by
himself in his life time and there remains outstanding of
Rs.27,68,418/- of National Bank of Pakistan, Awami Markaz Branch,
Karachi, 1920. I produce letter dated: 24.01.2009, along with schedule
as Ex.__________.

department a succession certificate is required by us.
Succession Act , 1925 or any other enactment for the time being
were granted.
12, That I therefore, pray that Succession Certificate may pleased be

granted in our favour authorizing / empowering me to get /
withdraw / receive the amount aforesaid with interest to be accrued
up to the date of withdrawal from logistic department, Pakistan State
Oil Company limited and from other department/institution etc for
share after deducting / repaying the loan amount as mentioned above.

Deponent.
Advocate
Sohni & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
SCHEDULE OF PROPERTIES /DEBTS / SECURITIES OF

DECEASED MUHAMMAD LAIQUE SON OF ALI BUX
ZARDARI, AS PROVIDED BY APPLICANT No.1
DEBTS
Serial Name of Amount of debt Description and date of

No. Debtor including interest, instrument, if any, by
on date of which the debt is
application for secured
certificate
01 Deceased Rs.27,68,418/-
Loan of National Bank of
Muhammad
Laique S/O Ali of National Bank of Pakistan, Awami Markaz
Bux Zardari. Pakistan Awami
Branch , Karachi; 1920-
Markaz Branch
Karachi, 1920 against Late Muhammad
Laiq Zardari as Saihban
Loan , vide letter dated:
24.01.2009 along with
schedule.
P/2…
P/2…
SECURITIES
Serial DESCRIPTION Market value of

No. Distinguishing Name, title or Amount or par security on date
number or letter class of value of security of application for
of security security certificate.
01 Letter bearing Final Rs.5, 156,214/- Rs.5,

No. Settlement 156,214/-
(Rupees Five
HR/7010/202 of account (Rupees Five
4, June, 26, of Late Million One Million One
2009, issued Muhammad hundred fifty
hundred fifty six
by Pakistan Laiq Zardari six thousand ,
State Oil includes thousand, two two hundred
Company Provident and fourteen
hundred and
Limited to the Fund, only.
application for Gratuity, fourteen only,
requiring Insurance
along with
Succession etc.
Certificate for interest accrued
an amount of
till receipt of
Rs.5,156,214/-
amount from
concerned
department.

NAWABSHAH.
DATED:
Sohni & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
APPLICATION U/O 32 RULE 3 (2) CPC
It is prayed on behalf of the applicant No.1, that this
Honourable Court may be pleased to appoint her as guardian ad litem
for minors applicants (1) Kanwal , Soonh and Muhammad Hanif for
the purpose of obtaining Succession Certificate on the consideration of
the grounds mentioned in the accompanying affidavit.
NAWABSHAH.
DATED: -07-2009
Sohni & Others

-------------------------------Applicants
VERSUS
Public at Large
------------------------------ Opponents.
A F F I D A V I T.
I, Sohni Wd/O Late Muhammad Laique Zardari, adult, muslim,

r/o: Village Muhammad Laique Zardari, UC-Chanessar-II, Taluka
as under:-

2. That accompanying application U/O 32 Rule 3 (2) CP C has

been filed on my instructions, the contents where of are true and may
be read as part of this affidavit.
3. That I am real mother of minors, applicants Nos. 2 to 4 so

no any interest in the matters in controversy in the applicantion
adverse that of minors and that I am a fit person to be so
appointed.

allowed.

is not allowed.

Deponent.
Advocate.
7. Mst. Sohni wd/o Muhammad Laique

Zardari, muslim, adult, r/o: Village
Muhammad Laique Zardari, UC-Chanessar-
II, Taluka Nawabshah, District Shaheed
Benazir Abad.
8. Kanwal D/O Late Muhammad Laique

Zardari, (aged about 14 years)
9. Baby Soonh D/O Late Muhammad Laique

Zardari (aged about 13 years)
10. Muhammad Hanif son of late Muhammad

Laique Zardari (aged about 11 years)
Nos. 2 to 4 minors, through their mother and

guardian ad-litem / next friend Mst. Sohni,
the applicant No.1.
--------------------------Applicants.
Versus.
Public at large
-----------------------Opponents.

The applicants named above humbly submit as under:-
1). That Late Muhammad Laique S/O Ali Bux Zardari died on 08-
04-2009, for which original death certificate is submitted herewith as annexure
"A".

resident of Village Muhammad Laique Zardari, UC Chanessar-II, Taluka
Nawabshah, District Shaheed Benazir Abad and was serving as Senior
Executive Officer, Logistic Department , Pakistan State Oil Company Limited,
at the time of his death.
P/2…
P/2…
3). That said deceased at the time of his death left the applicants as his sole
legal heirs being widow, daughters and son. Applicant No.1 is his widow
while applicants Nos.2 & 3 are daughters and application No.4 is son.
4). That the said deceased was Sunni Muslim and so are his legal heirs the
applicants.
5). That the said deceased at the time of his death left an amount of
Rs.51,56,214/-, which includes Provident Fund, Gratuity and Insurance etc.
Photostat copy of such letter requiring Succession Certificate from the
applicants, issued by Sumera Manzar, Manager Human Resources, Pakistan
State Oil Company Karachi, bearing letter NO. HR/7010/2024, June, 26 th,
2009, which is submitted herewith as annexure “B”.
7). That said deceased Muhammad Laique Zardari in his life time obtained
loan for purchasing Flat in Karachi and the amount due against the said loan
was Rs.34,92,156/-, while Rs.7,23,738/- were paid by the said deceased and
there remains outstanding of Rs.27,68,418/- of National Bank of Pakistan,
Awami Markaz Branch, Karachi. 1920, vide letter dated: 24.01.2009, copy of
letter along with payment schedule is submitted herewith as annexure “C”.

Department, a succession certificate is required by the applicants, hence this
application.
9). That no application has been made to any court so for and no grant has
the debts, security and estates of the said deceased and there is no any
enactment for the time being in force to grant of the succession certificate or
the validity of thereof if it were granted.
10). That the applicants have fully set forth the securities/amount/debts in
P/3…
P/3…
PRAYER
The applicants, therefore, pray that the Honourable court may
be pleased to issue a Succession Certificate in their favour
authorizing/ empowering applicant No.1, Mst. Sohni Wd/O
late Muhammad Laique Khan Zardari to get/ with draw/
receive the amount aforesaid with interest to be accrued up to
the date of withdrawal from Logistic Department , Pakistan
State Oil Company Limited and from other departments/
institutions etc, for disbursement thereof amongst all the
applicants according to their legal shares after deducting / re-
paying the loan amount as mentioned above.
applicant No.1
for herself and for minors.
VERIFICATION.
I, Sohni Wd/O Late Muhammad Laique Zardari, adult, muslim,

aged about 34 years r/o: Village Muhammad Laique Zardari, UC-Chanessar-
II, Taluka Nawabshah, District Shaheed Benazir Abad, do hereby verify on
oath on this ________ day of July, 2009 at Nawabshah, that whatever
stated above is true and correct to the best of my knowledge and belief.
Deponent
I know the deponent
Advocate
P/4…
P/4…
Documents filed

1. Same as above
LIST OF WITNESSES:
5. Ghazi Bux son of Ali Bux Khan Zardari.
6. Raheem Dad son of Saleem Zardari,
All r/o: Village Muhammad Laique Zardari,

UC Chanessar-II, Taluka Nawabshah,

instructions of the applicant No.1.

the application.
(AMEER ALI
MAHESSAR)
IN THE COURT DISTRICT JUDGE , SHAHEED BENAZIR ABAD.
Miss. Mehar Afshan & Others.

…………………..Applicants.
Versus.
Public at large
………….…Opponents.
APPLICATION U/S 376 SUCCESSION ACT,1925.
It is prayed that this Honourable court may be pleased to
issue extended Succession Certificate in favour of applicants No.1 to 4
authorizing/ empowering applicant No.1, namely Miss. Mehar Afshan
D/O Late Abdul Hameed Memon to get/ receive the amount of
Rs.4,54,875-23, Rs.50,000/- on profit and loss sharing basis of PLS
Crore Pati Deposit Certificate bearing NO.CPDC 385283/04/133,
dated: 30.11.1998, till its accrual, Rs.4,56,000/- of State Life
Insurance Corporation of Pakistan vide letter dated: June, 09, 2008,
issued by State Life Insurance Corporation Karachi Southern Zone to
applicant No.1 , requiring Succession Certificate, Certificate issued by
Habib Bank limited New town Branch Karachi with regard to
articles/cash kept in Locker bearing No.593, key No.553, left by
deceased Mehar Afroze and for disbursement thereof amongst all the
applicants viz. 1 to 4 according to their legal share on the
consideration of the following facts and grounds.
P/2…
P/2…
F A C T S.
Facts leading to the present application are that the
Honourable Court was pleased to issue Succession Certificate with
regard to amount of Rs.1,43,032/51, maintained with Habib Bank
Limited New town Branch Karachi, grant of Family Pensions, GP Fund,
Final Payment/ Group Insurance and one 180 days death salary on
25.02.2009. However, the applicants were enquiring other amounts
left by the deceased and have come to know about the aforesaid
assets/ amount / articles of deceased Mehar Afroze and enquired from
the concerned, on which they required Succession Certificate, hence
this application for extended Succession Certificate, in favour of the
applicants on the following grounds :-
G R O U N D S.
succession Certificate dated:25.2.2009 by this Honourable court with
regard to the legal heirs of late Mehar Afroze D/O Late Abdul Hameed
Memon Viz. publication in newspaper, report from Mukhtiarkar and
evidence of the witnesses.
2. That balance certificate issued by Habib Bank Limited Masjid
Road Nawabshah along with letter No.DMA/001, dated: 18.02.2009,
Original Crore Pati PLS Rupee Deposit Certificate in the name of
deceased Mehar Afroze (on behalf of minor Iqra Firdous) bearing
No.CPDC-385283/04/133, dated: 30.11.1998, copy of letter issued by
Deputy Manager Claims , State Life
P/3…
P/3…
Insurance Corporation of Pakistan, Karachi, Southern Zone, dated: June
9, 2008 with regard to Policy No.501605694-3 , in the name of Late
Dr. Mehar Afroze containing Rs.4,56,000/- and certificate issued by
Habib Banks Limited New town Brnach Karachi, with regard to locker
bearing NO. 593, Key No.553, for withdrawal of the
articles/cash/assets are submitted herewith.
3. That Photo copy of Succession Certificate dated:25.2.2009 is
submitted herewith as the original was obtained by concerned
authorities after it was issued.
Applicant No.1 Applicant No.2
Applicant No.3 Applicant No.4

I, Mehar Afshan D/o Late Abdul Hameed Memon, adult, muslim,

r/o: House No. # A-35, Government Employee Co-Operative Housing
Society, Nawabshah, do hereby verify on oath on this _______ day of
April, 2009 at Nawabshah, that whatever stated above is true and
correct to the best of my knowledge and belief.
Deponent.
Advocate.

Versus
Public at Large
SCHEDULE OF PROPERTIES /DEBTS / SECURITIES OF

DECEASED MISS. MEHAR AFROZE D/O ABDUL HAMEED
MEMON, AS PROVIDED BY THE APPLICANTS.
DEBTS

on date of which the debt is secured
application for
certificate
Nil. Nil. Nil. Nil.
SECURITIES

No. Distinguishing Name, title Amount or par security on date
number or or class of value of security of application
letter of security for certificate.
security
01 Certificate Credit Rs.1,43,032.59 Rs.1,43,032.5

dated: 27th Balance of (Rupees One lac 9 (Rupees One
June, 2008 of deceased Forty three lac Forty three
PLS Account Miss. thousand, thousand,
No. 8994-3 Mehar thirty two and thirty two and
issued by Afroze D/O fifty nine fifty nine
Habib Bank Abdul paisas. along paisas.
Ltd New Hameed with interest
Town Branch Memon accrued till
Karachi. PLS receipt of
Account amount from
No.8994-3. concerned
bank..
P/2…
P/2…
2. Letter No.SR Family Family Family

& P (CH) / - Pension / Pension / G.P Pension / G.P
1319, dated: G.P Fund / Fund / Final Fund / Final
12.02.2008, Final Payment / Payment /
issued by Payment / Group Group
Medical Group insurance and insurance and
Superintenden insurance 180 days death 180 days
t Civil and 180 Salary, death Salary,
Hospital days death accruable as per accruable as
Karachi . Salary. letter per letter
mentioned in mentioned in
Column No.1. Column No.1.
along with
interest if any,
till the receipt
of the amount.
ADVOCATE FOR APPLCIANTS.

NAWABSHAH.
DATED:
Murad Ali & others
Versus
Public at Large
EXTENDED SCHEDULE OF PROPERTIES /DEBTS /

SECURITIES OF DECEASED ALI KHAN SON OF RAHEEM
DAD JAMALI, AS PROVIDED BY THE APPLICANT.
DEBTS

application for
certificate
Nil. Nil. Nil. Nil.
SECURITIES

security
01 letter No. 4939- Service 1. Funeral charges Rs.3,44,422/-

40/DM/SST/H claim of Rs.5,000/ of S.No.1,3,4,
ESCO/NSH, Late Ali and 6. While 2
dated: Khan and 5 is due
2. WAPDA Welfare
28.07.2008, Mallahi in since the date
issued by SS& T grant in favour of of death of
Deputy Division Widow and minors deceased Ali
Manager SS & T GSO HESCO, Khan,
of deceased
Divisions GSO, at 132 KV whatsoever till
HESCO Gird Station (conditional if the the accrual of
Nawabshah Society widow re-marriage the amount
Nawabshah along with
amount) will be interest, if any.
seized admissible
Rs.870/-.
3. Group Life
insurance
Rs.1,82,000/-
4. Gratuity
Rs.1,26,194/-
5. Pension Per
month Rs.919/-
6. 180 days
encashment
Rs.24,529/-.
7. G.P. Fund of
Rs.6999/- upto the
death of deceased .

NAWABSHAH.
DATED:
IN THE COURTOF THE DISTRICT JUDGE,
Miss. Meher Afshan & Others
--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.
EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Bhoongar Kathio son of Fazul Mohammad, muslim, adult,

village Syed Khair Shah, Post Office Nawabshah, Taluka Nawabshah,
District Shaheed Benazir Abad presently r/o: Govt: Employees Co-
Operative Housing Society, Nawabshah, do hereby state on oath as
under:-
1). That deceased Mehar Afroze as well as applicants are well known
to me.
2). That Mst. Mehar AFroze died on 10.06.2007 and she left behind
her the applicants, as her sole legal heirs.
3). That the said deceased was a Sunni muslim and she left at the
time of her death an amount of Rs.1,43,032-59, in her account No.
8994-3, maintained with Habib Bank Ltd, New Town Branch Karachi &
also left family pension / G.P fund / Final payment / Group Insurance /
180 days death Salary with health department.
4). That prior to this no any Succession Certificate, probate or letter

of Administration for the property of the deceased has either been
applied or granted to the applicants.
Page-2
5). That since the applicants are sole legal heirs of deceased and are
entitled to be issued a Succession Certificate in their favour.
Whatever stated above is true and correct to the best of

my knowledge and belief.
DEPONENT.
I KNOW THE DEPONENT.
ADVOCATE.
Nawabshah.
Dated:

--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.
EXPARTE PROOF /
I, Abdul Aziz son of Late Abdul Hameed, muslim, adult, Memon

by caste, r/o: House No. A-35, Govt: Employees Co-Operative Housing
Society, Nawabshah, do hereby state on oath as under:-
1). That deceased Mehar Afroze was my sister, who died on
10.06.2007 and she left behind her we the applicants, as her sole legal
heirs.
time of her death an amount of Rs.1,43,032-59, in her account NO.
8994-3, maintained with Habib Bank Ltd New Town Branch Karachi &

P/2…
P/2…
5). That since we viz. applicants are sole legal heirs of deceased
Mehar Afroze Memon and are entitled to be issued a Succession
Certificate in our favour authorizing / empowering applicant No.1
Miss. Mehar Afshan to withdraw the amount from Habib Bank Ltd New
town branch Karachi , Family pension/ G.P Fund/ Final Payment/ Group
Insurance and 180 days death Salary from Health Department and from
any other department / institution etc for disbursement thereof
amongst us according to legal share.

DEPONENT.
ADVOCATE.
Nawabshah.
Dated:

--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.
EXPARTE PROOF /
I, Abdul Jabar son of Late Abdul Hameed, muslim, adult, Memon

heirs.

P/2…
P/2…

DEPONENT.
ADVOCATE.
Nawabshah.
Dated:

--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.
EXPARTE PROOF /
I, Abdul Sattar sosn of Late Abdul Hameed, muslim, adult,

Memon by caste, r/o: House No. A-35, Govt: Employees Co-Operative
Housing Society, Nawabshah, do hereby state on oath as under:-
heirs.

P/2…
P/2…

DEPONENT.
ADVOCATE.
Nawabshah.
Dated:

--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.
EXPARTE PROOF /
I, Mehar Afshan D/O Late Abdul Hameed, muslim, adult, Memon

1). That deceased Mehar Afroze D/O Late Abdul Hameed Memon
died on 10.06.2007 and she left behind her we the applicants, as her
sole legal heirs. I produce death Certificate as Ex.____________.
8994-3, maintained with Habib Bank Ltd New Town Branch Karachi. I
produce Bank Statement/Certificate as Ex.______________.
3). That deceased Mehar Afroze also left family pension / G.P fund /
Final payment / Group Insurance / 180 days death Salary with health
department such letter issued by Medical Superintendent Civil Hospital,
Karachi requiring Succession Certificate is submitted as Ex.__________.
P/2…
P/2…
4). That the Honourable Court was pleased to issue a letter to
Mukhtiarkar Revenue, Nawabshah verifying the legal heirs of deceased
Mehar Afroze and such verification submitted before the Honourable
Court by Mukhtiarkar Revenue, Nawabshah is produced as
Ex._________.
5). That the Honourable Court was further pleased to issue
publication inviting the objections if any from public at large, such
copy of Daily Kawish Hyderabad is submitted as Ex._________.
Certificate in our favour.
8). That being legal heir I may be authorized to withdraw / receive/
obtain / get the amount from Habib Bank Ltd New town branch Karachi
, Family pension/ G.P Fund/ Final Payment/ Group Insurance and 180
days death Salary from Health Department and from any other
department / institution etc for disbursement thereof amongst all the
legal heirs viz. we the applicants Nos. 1 to 4 according to legal share.

DEPONENT.
ADVOCATE.
Nawabshah.
Dated:
IN THE COURTOF THE DISTRICT JUDGE, SHAHEED
MOHTARMA BENAZIR BHUTTO
11. Miss. Meher Afshan D/O Late Abdul Hameed

12. Abdul Sattar S/O Late Abdul Hameed
13. Abdul Jabbar S/O Late Abdul Hameed
14. Abdul Aziz S/O Late Abdul Hameed
All muslims, adults, Memon by caste,

R/O: H # A-35, Govt. Employees Co-Operative
Housing Society, Nawabshah.
--------------------------Applicants.
Versus.
Public at large
-----------------------Opponents.

The applicants named above humbly submit as under;
1. That Meher Afroze D/O Abdul Hameed Memon died on 10-06-
2007, for which death certificate is submitted herewith as annexure
"A".
2. That said deceased Meher Afroze was permanent resident of
Govt. Employees Co-Operative Housing Society, Nawabshah and was

serving as Senior Women Medical Officer (BPs-19), Civil Hospital
Karachi, at the time of her death.
P/2…
P/2…
3. That said deceased at the time of her death left the applicants as
her sole legal heirs being sister and brothers. Applicant No.1 is her
sister while applicants Nos.2 to 4 are her brothers. Father and mother
of the deceased had died during the life time of the deceased.
4. That the said deceased was Sunni Muslim and so are her legal
heirs the applicants.
5. That the said deceased at the time of her death left an amount of
Rs.1,43,032-59 in her account No.8994-3 maintained with Habib Bank
Limited, New Town Branch Karachi, such Bank Statement/Certificate
dated: June, 27, 2008 is submitted herewith as annexure "B". The said
deceased also left Family Pension /G.P Fund / Final Payment / Group
Insurance, 180 days death salary, to which amount the applicants are
entitled to get as per Muhammadan Law, such letter requiring
Succession Certificate issued by Office of the Medical Superintendent
Civil Hospital Karachi, bearing No.SRP (CH)/-1319, dated: 12.02.2008,
is submitted herewith as annexure "C".
6. That since the said deceased was Govt. employee, hence heirship
certificate was applied and such heirship certificate was issued bearing
No. SM/-02 of 2008, Nawabshah, dated: 08.01.2008, by Mukhtiarkar
(Revenue) Nawabshah, is submitted herewith as annexure "D"

8. That to withdraw the amount aforesaid from the bank concerned
and Health Department, a succession certificate is required by the
applicants, hence this application.
P/3…
P/3…
9. That no application has been made to any court so for and no
administration in respect of the debts, security and estates of the said
deceased and there is no any impediment under the provisions of
Succession Act, 1925 or any other enactment for the time being in
force to grant of the succession certificate or the validity of thereof if it
were granted.
10. That the applicants have fully set forth the securities/ amount in
Para No.5 above, in respect of which succession certificate is applied
for.
PRAYER
The applicants, therefore, pray that the honourable court
may be pleased to issue a Succession Certificate in their
favour authorizing, empowering applicant No.1, Miss.
Meher Afshan D/O Late Abdul Hameed Memon to get/
with draw/ receive the amount aforesaid with interest to
be accrued up to the date of withdrawal from Habib Bank
New Town Branch, Karachi, Health Department/ Medical
Superintendent Civil Hospital Karachi and from other

departments/ institutions etc, for disbursement thereof
amongst all the applicants according to their legal shares.
Miss. Meher Afshan Abdul Sattar

applicant No.1 applicant No.2
Abdul Jabbar Abdul Aziz

applicant No.3. applicant No.4.

P/4…
VERIFICATION .
I, Meher Afshan D/O Late Abdul Hamed Memon, muslim,
adult, R/o Govt. Employees Co-Operative Housing Society, Nawabshah,
do hereby verify on oath on this day of November, 2008 at
Nawabshah, that whatever stated above is true and correct to the best
of my knowledge and belief.
Deponent
I know the deponent
Advocate
Documents filed
As Annexure "A" to "D".

1. Same as above

instructions of the applicants.
Addresses of the parties are same as shown in the cause

title of the application.
(AMEER ALI
MAHESSAR)
IN THE COURTOF THE DISTRICT JUDGE, SHAHEED

MOHTARMA BENAZIR BHUTTO

--------------------------Applicants.
Versus.
Public at large
-----------------------Opponents.

THE LEGAL HEIRSOF DECEASED MEHAR AFROZE
D/O LATE ABDUL HAMEED MEMON
It is submitted that Mehar Afroze D/O Late Abdul Hameed

Memon, permanent r/o: Govt: Employees Co-Operative Housing
Society, Nawabshah, died on 10-06-2007, leaving behind the
following legal heirs;
26. Miss. Meher Afshan D/O Late Abdul Hameed

27. Abdul Sattar S/O Late Abdul Hameed
28. Abdul Jabbar S/O Late Abdul Hameed
29. Abdul Aziz S/O Late Abdul Hameed
All muslims, adults, Memon by caste,

R/O: H # A-99, Govt. Employees Co-Operative
Housing Society, Nawabshah.
Nawabshah, may be directed to verify the legal heirs of deceased
Meher Afroze D/O Late Abdul Hameed Memon r/o: Govt. Employees
Co-Operative Housing Society, Nawabshah.
Advocate for
Applicants
IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.
Muhammad Faheem and others
…………….Applicants
Versus
Public at Large …………….
Opponents
EXPARTE PROOF /
I, Syed Khalid son of Syed Wahid Ali, adult, muslim, R/o: Kamora
Colony, near Gohsia Masjid, Camp No.2, Nawabshah, do hereby state
on oath as under:
1). That deceased Raziullah Khan son of Shafiullah Khan died on
02.08.2008 and he left behind his the applicants Nos. 1 to 9 as his
sole legal heirs.
2). That the said deceased was a Sunni muslim and he left at the
time of his death an amount of Rs.1,59,760.86, in his account
NO.042970000016-01, maintained with Habib Bank Ltd Mohni Bazar
Branch, Nawabshah.
4). That since applicants Nos. 1 to 9 are sole legal heirs of deceased
Raziullah Khan and are entitled to be issued a Succession Certificate in
their favour.
What ever stated above is true and correct to the best of

my knowledge .
DEPONENT.
ADVOCATE.
Versus
Opponents
EXPARTE PROOF /
I, Fahmida Wd/o Raz-i-ullah Khan, adult, muslim, By caste

Yousifzai Pathan, R/o: near Gohsia Masjid Camp No.2, Nawabshah, do
hereby state on oath as under:
1). That I am applicant No.9, while applicant No.1 is my son.
2). That my husband Raz-i-ullah Khan son of Shafiullah Khan died
on 02.08.2008 and at the time of his death left an amount of
Rs.1,59,760.86, in his account NO.042970000016-01, maintained
with Habib Bank Ltd Mohni Bazar Branch, Nawabshah.
3). That my husband died intestate and due and diligent search has
been made for a will but none is found.
4). That to withdraw the amount aforesaid a Succession Certificate
is required to us by the bank concerned.
P/2…
P/2…
5). That I have no objection if the Succession Certificate is granted
by authorizing , empowering my son Muhammad Faheem (the
applicant No.1) to get/ withdraw / receive the amount aforesaid with
the interest to the accrued up to the date from Habib Bank Ltd. Mohni
Bazar Branch Nawabshah and from other departments / institution etc
for disbursement thereof among us the applicants Nos. 1 to 9,
according to legal share.

my knowledge .
DEPONENT.
ADVOCATE.
Versus
Opponents
EXPARTE PROOF /
I, Muhammad Naeem son of Raz-i-ullah Khan, adult, muslim, By

caste Yousifzai Pathan, R/o: near Gohsia Masjid Camp No.2,
Nawabshah, do hereby state on oath as under:
1). That I am applicant No.3, while applicant No.1 is my brother.
2). That my father Raz-i-ullah Khan son of Shafiullah Khan died on
02.08.2008 and at the time of his death left an amount of
3). That my father died intestate and due and diligent search has
is required to the applicants by the bank concerned.
by authorizing , empowering my brother Muhammad Faheem (the
applicant No.1) to get / withdraw / receive the amount aforesaid with


my knowledge .
DEPONENT.
ADVOCATE.

Versus

Opponents
EXPARTE PROOF /
I, Muhammad Faheem son of Raz-i-ullah Khan, adult, muslim,
By caste Yousifzai Pathan, R/o: near Gohsia Masjid Camp No.2,
1). That I am applicant No.1 in the above application, hence fully
02.08.2008, such death certificate is submitted as Ex._______
3). That my father at the time of his death was residing near Ghosia
Masjid Camp No.2, Nawabshah and at the time of death he left we the
applicants Nos. 1 to 9 as his sole legal heirs , such report of
Mukhtiarkar is submitted as Ex.________.
4). That my father was a Suuni muslim and he at the time of his
death left an amount of Rs.1,59,760.86, in his account
NO.042970000016-01, maintained with Habib Bank Ltd Mohni Bazar
Branch, Nawabshah. I submit Bank Statement / Certificate as
Ex.____________.
P/2…
P/2…
7).That prior to this no application has been made to any court and no
grant has been made for any certificate, probate or letter of
administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the Succession
Act, 1925 or any other enactment for the time being enforced to the
grant of Succession Certificate or the validity thereof if it were granted.
8).That we have fully set forth the security / amount in Para No.4,
aforesaid in respect of which Succession Certificate is required.
9).That the notice to public at Large issued in Daily Nawa-e –Waqat,
Karachi is submitted as Ex._________.
It is therefore, prayed that the Honourable Court may be
pleased to issue a Succession Certificate in our favour authorizing,
empowering me to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from Habib Bank
Ltd. Mohni Bazar Branch Nawabshah and from other departments /
institution etc for disbursement thereof among all the other applicants,
according to their legal share.

my knowledge .
DEPONENT.
ADVOCATE.
Versus
Opponents
EXPARTE PROOF /
I, Muhammad Saleem son of Raz-i-ullah Khan, adult, muslim, By

caste Yousifzai Pathan, R/o: near Gohsia Masjid Camp No.2,
1). That I am applicant No.2, while applicant No.1 is my brother.
02.08.2008 and at the time of his death left an amount of
by authorizing , empowering my brother Muhammad Faheem (the

applicant No.1) to get / withdraw / receive the amount aforesaid with

my knowledge .
DEPONENT.
ADVOCATE.
IN THE COURT DISTRICT JUDGE , NAWABSHAH.
Sharafuddin and others.

Versus.
Public at large
……….Opponents.
AFFIDAVIT.
I, Nasreen Akhtar Wd/o Sharfuddin Rajput, adult, muslim, R/o
House No.2-A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery
Street, Nawabshah, do hereby state on oath as under:
1. That I am applicant No.2 in the above application, hence fully
2. That prior to this Succession Certificate was issued in our favour,
in which my husband was authorized to withdraw the amount from the
Bank but since he has died and now applicant No.3 Fida Hussain is a fit
person to be authorized to do the Job of withdrawing the amount etc
from the Bank Al-Habib.

3. That I have got no objection if applicant No. 3 Fida Hussain who
is my son is issued extended Succession Certificate authorizing him to
withdraw the amount from the bank for distribution according to legal
shares.
Deponent.
Advocate.

Versus.
Public at large
AFFIDAVIT.
I, Sidra D/o Sharfuddin Rajput, adult, muslim, R/o House No.2-A
837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery Street,
in which my father was authorized to withdraw the amount from the
is my real brother is issued extended Succession Certificate
authorizing him to withdraw the amount from the bank for distribution
according to legal shares.
Deponent.
Advocate.

Versus.
Public at large
AFFIDAVIT.
I, Misbah D/o Sharfuddin Rajput, adult, muslim, R/o House
No.2-A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery Street,
Deponent.
Advocate.

Versus.
Public at large
AFFIDAVIT.
I, Sadia D/o Sharfuddin Rajput, adult, muslim, R/o House No.2-A
837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery Street,
Deponent.
Advocate.

Versus.
Public at large
AFFIDAVIT.
I, Atta Mohauddin S/o Sharfuddin Rajput, adult, muslim, R/o
House No.2-A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery
Street, Nawabshah, do hereby state on oath as under:

Deponent.
Advocate.
30. Muhammad Faheem S/o Raziullah Khan

31. Muhammad Saleem S/o Raziullah Khan
32. Muhammad Naeem S/o Raziullah Khan
33. Muhammad Waseem S/o Raziullah Khan
34. Muhammad Asim S/o Raziullah Khan
35. Mst.Rozina D/o Raziullah Khan
36. Mst.Tahseen D/o Raziullah Khan
37. Mst.Tehreem D/o Raziullah Khan.
38. Mst. Fahmida Wd/o Raziullah Khan
All Muslims, Adults, Yousufzai Pathan by caste,

R/o near Ghosia Masjid Camp No.2, Nawabshah
…………..Applicants.
Versus.
Public at large
APPLICATION U/S 370 & 372 SUCCESSION

ACT,1925.
The applicants named above humbly submit as under;
1. That Raziullah Khan S/o Shafiullah Khan died on 02-08-2008,
for which death certificate is submitted herewith as annexure "A".

2. That said deceased Raziullah Khan was resident of near Ghosia
Masjid Camp No.2, Nawabshah, at the time of his death, within the
jurisdiction this honourable court.
3. That said deceased at the time of his death left the applicants as
his sole legal heirs being his sons, daughters and widow. Applicants
No 1 to 5 are sons, applicants No 6 to 8 are daughters and applicant
No. 9 is widow of the deceased.
4. That the said deceased was Sunni Muslim and so are his legal
heirs the applicants.
(2)
5. That the said deceased at the time of his death left an amount of
Rs. 1,59,760.86/- in his account No. 042970000016-01 maintained
with Habib Bank Limited, Mohni Bazar Branch, Nawabshah, to which
amount the applicants are entitled to get as per Muhammadan Law,
such bank statement/ certificate is submitted herewith as annexure
"B".
7. That to withdraw the amount aforesaid from the bank
concerned, a succession certificate is required by the applicants, hence
this application.
8. That no application has been made to any court so for and no
administration in respect of the debts, security and estates of the said
deceased and there is no any impediment under the provisions of
Succession Act, 1925 or any other enactment for the time being in
force to grant of the succession certificate or the validity of thereof if it
were granted.
9. That the applicants have fully set forth the securities/ amount in
para No.4 above, in respect of which succession certificate is applied
for.
PRAYER
The applicants, therefore, pray that the honourable court may be
pleased to issue a succession certificate in their favour authorizing,
empowering applicant No. 1 Muhammad Faheem S/o Raziullah Khan to
get/ with draw/ receive the amount aforesaid with interest to be
accrued up to the date of withdrawl from Habib bank limited Mohni
Bazzar, branch, Nawabshah and from other departments/ institutions
etc, for disbursement thereof amongst all the applicants according to
their legal shares.
1.Muhammad Faheem 2.Muhammad Saleem

3.Muhammad Naeem
4.Muhammad Waseem 5.Muhammad Asim 6. Mst.

Rozina
7. Mst. Tahseen 8. Mst.Tehreem.
9.Mst.Fahmida.
Advocate for
Applicants
(3)
VERIFICATION .
I, Muhammad Faheem S/o Raziullah Khan, Yousufzai Pathan,
Muslim, Adult, R/o Near Ghosia Masjid, Camp No.2 Nawabshah, do
hereby verify on oath on this 01st day of September 2008 at
Nawabshah, that whatever stated above is true and correct to the best
of my knowledge and belief.
I know the deponent

Deponent
Advocate
Documents filed; Documents Relied

upon.
1. Original death certificate specified in the 1. Same as above

Application as annexure "A".
2. Original bank statement / certificate 2. Any other

evidence,
specified in the application as annexure "B". document or
record.
Drafted by me in my office at Nawabshah, under the instructions
of the applicants.
application.
Advocate for
Applicants

Versus

Opponents
APPLICATION FOR VERIFICATION OF THE LEGAL

HEIRS OF DECEASED RAZIULLAH KHAN
It is submitted that Raziullah Khan S/o Shafiullah Khan Yousufzai
Pathan, ordinarily R/o Near Ghosia Masjid, Camp No.2 Nawabshah,
died on 02-08-2008, leaving behind the following legal heirs;
1.Muhammad Faheem S/o Raziullah Khan

2.Muhammad Saleem S/o Raziullah Khan
3.Muhammad Naeem S/o Raziullah Khan
4.Muhammad Waseem S/o Raziullah Khan
5.Muhammad Asim S/o Raziullah Khan
6.Mst.Rozina D/o Raziullah Khan
7.Mst.Tahseen D/o Raziullah Khan
8.Mst.Tehreem D/o Raziullah Khan.
9.Mst. Fahmida Wd/o Raziullah Khan
All Muslims, Adults, Yousufzai Pathan by caste,

R/o near Ghosia Masjid Camp No.2, Nawabshah.
Nawabshah, may be directed to verify the legal heirs of deceased
Raziullah Khan S/o Shafiullah Khan R/o Near Ghosia Masjid, Camp
No.2 Nawabshah, as he is avoiding to issue heirship certificate of the
deceased Raziullah Khan Yousufzai Pathan, as he was not Government
employee and due to the ban imposed by Board of Revenue.
Advocate for
Applicants
It is prayed that this honourable court may be pleased to issue
extended Succession Certificate in favour of applicants No.1 to 7
authorizing/empowering applicant No.3, namely Fida Hussain s/o
Sharfuddin Rajput to get/ receive the amount of Rs.1,85,137/-
(Rs:- One lac eighty five thousands one hundred thirty seven only)
being the death life insurance under Bank Policy of Bank Al-Habib
Ltd, Nawabshah Branch, Masjid Road. Nawabshah-Pakistan, of
deceased Ghullam Dastagir holding Account N0.071-028789-50-0
for disbursement thereof among all the applicants viz 2 to 7
according to their legal share on the consideration of the following
facts and grounds.
F A C T S.
Facts leading to the present application are that Ghullam
Dastagir S/o Sharfuddin Rajput, r/o House No.II-A 837/150-A,
Muhalla Latifabad No.2, Naseer Bakery Street Nawabshah died on
18.3.2007, such death Certificate is already on record. The said
deceased at the time of his death left behind the applicants No.1 to 7
as his sole legal heirs. The said deceased at the time of his death left
an amount of Rs.1,22,587-30 in his account No.071-28789-50-0
with Bank Al-Habib Masjid Road Branch, Nawabshah. Ultimately the
succession application being No. aforesaid was allowed in favour of
applicants No.1 to 7 and applicant No.1 namely Sharfuddin S/o Niaz
Ahmed Rajput r/o House No. II-A 837/150-A Muhalla Latifabad No.2,
Naseer Bakery, Nawabshah was authorized to withdraw
Page-2
the amount aforesaid from the Bank aforesaid and such succession
Certificate dated:-16.8.2007 (Photo copy attached as the original was
handed over to the Bank authorities) was issued by the honourable
court. Applicant No.1 namely Sharfuddin withdrew the amount
aforesaid and distributed among all the legal heirs of late Ghullam
Dastagir as mentioned in Succession Application. The receipts of
amount from applicants No.2 to 7 were also submitted before the
honourable court. After the amount mentioned in succession
Application viz Rs.1,22,587-30 was obtained and distributed the
applicants further came to know that the aforesaid account was also
insured with the bank and they further came to know that
Rs.1,85,137/- was also pending with the bank in Account of deceased
Ghullam Dastagir being the death life insurance under the Bank Policy
of Bank Al-Habib Ltd, Nawabshah Branch, Masjid Road, Pakistan.
Unfortunately During the process applicant No.1 namely Sharfuddin
passed away and the Bank Authorities demanded extended Succession
Certificate in favour of the remaining applicants authorizing any one
of legal heirs of deceased Ghullam Dastagir to withdraw the said
amount, hence this application on the following grounds:-
G R O U N D S.
succession Certificate dated:-16.8.2007 by this honourable court with
regard to the legal heirs of late Ghullam Dastagir Viz publication in
newspaper, report from Mukhtiarkar and evidence of the witnesses.
2. That balance certificate issued by Bank Al-Habib is submitted in
original herewith.
3. That death certificate of applicant No.1 Sharfuddin is also
submitted herewith.
4. That the applicants are same but applicant No.1 and the account
No. is same as mentioned in main application.
5. That Photo copy of Succession Certificate dated:-16.8.2007 is
submitted herewith as the original was obtained by Bank Authorities.
6. That Original Death Certificate of Ghullam Dastagir is also
submitted.
Nasreen Akhtar. Fida Hussain Atta
Muhauddin
Page-3
Mst. Sadia Mst. Misbah
Mst. Sidra
Advocate for Applicants No.2
to 7.
I, Fida Hussain S/o Sharfuddin Rajput, adult, muslim, R/o House
Nawabshah, do hereby verify on oath on this 11 th day of January,2008
at Nawabshah, that whatever stated above is true and correct to the
Deponent.
Advocate.
DOCMENTS FILED.
1. Original Balnace Certificate of Bank Al-Habib.
2. Original death Certificate of Sharfuddin.
3. Photo Stat copy of Succession Certificate.
4. Original Death Certificate of deceased Ghullam Dastagir.
Document Relied upon.
1. Same as above.
2. Any other evidence, documents
or record.
ADDRESSES of the parties are same , as shown in the
cause title of the plaint.
DRAFTED by me in my office as per instructions.
Dated:-11.01.2008. ADVOCATE FOR APPLICANT

NO.2 TO 7.

Versus.
Public at large
APPLICATION U/S 376 SUCCESSION

ACT,1925.
It is prayed that this honourable court may be pleased to issue
extended Succession Certificate in favour of applicants No.2 to 7
authorizing/empowering applicant No.3, namely Fida Hussain s/o
Sharfuddin Rajput to get/ receive the amount of Rs.1,85,137/- (Rs:-
One lac eighty five thousands one hundred thirty seven only) being the
death life insurance under Bank Policy of Bank Al-Habib Ltd,
Nawabshah Branch, Masjid Road. Nawabshah-Pakistan, of deceased
Ghullam Dastagir holding Account N0.071-028789-50-0 for
disbursement thereof among all the applicants viz 2 to 7 according to
their legal share on the consideration of the following facts and
grounds.
F A C T S.
Facts leading to the present application are that Ghullam
Dastagir S/o Sharfuddin Rajput, r/o House No.II-A 837/150-A,
Muhalla Latifabad No.2, Naseer Bakery Street Nawabshah died on
18.3.2007, such death Certificate is already on record. The said
deceased at the time of his death left behind the applicants No.1 to 7
as his sole legal heirs. The said deceased at the time of his death left
an amount of Rs.1,22,587-30 in his account No.071-28789-50-0
with Bank Al-Habib Masjid Road Branch, Nawabshah. Ultimately the
succession application being No. aforesaid was allowed in favour of
applicants No.1 to 7 and applicant No.1 namely Sharfuddin S/o Niaz
Ahmed Rajput r/o House No. II-A 837/150-A Muhalla Latifabad No.2,
Naseer Bakery, Nawabshah was authorized to withdraw
Page-2
the amount aforesaid from the Bank aforesaid and such succession
Certificate dated:-16.8.2007 (Photo copy attached as the original was
handed over to the Bank authorities) was issued by the honourable
court. Applicant No.1 namely Sharfuddin withdrew the amount
aforesaid and distributed among all the legal heirs of late Ghullam
Dastagir as mentioned in Succession Application. The receipts of
amount from applicants No.2 to 7 were also submitted before the
honourable court. After the amount mentioned in succession
Application viz Rs.1,22,587-30 was obtained and distributed the
applicants further came to know that the aforesaid account was also
insured with the bank and they further came to know that
Rs.1,85,137/- was also pending with the bank in Account of deceased
Ghullam Dastagir being the death life insurance under the Bank Policy
of Bank Al-Habib Ltd, Nawabshah Branch, Masjid Road, Pakistan.
Unfortunately During the process applicant No.1 namely Sharfuddin
passed away and the Bank Authorities demanded extended Succession

Certificate in favour of the remaining applicants authorizing any one
of legal heirs of deceased Ghullam Dastagir to withdraw the said
amount, hence this application on the following grounds:-
G R O U N D S.
succession Certificate dated:-16.8.2007 by this honourable court with
regard to the legal heirs of late Ghullam Dastagir Viz publication in
newspaper, report from Mukhtiarkar and evidence of the witnesses.
2. That balance certificate issued by Bank Al-Habib is submitted in
original herewith.
3. That death certificate of applicant No.1 Sharfuddin is also
submitted herewith.
4. That the applicants are same but applicant No.1 and the account
No. is same as mentioned in main application.
5. That Photo copy of Succession Certificate dated:-16.8.2007 is
submitted herewith as the original was obtained by Bank Authorities.
6. That Original Death Certificate of Ghullam Dastagir is also
submitted.
Nasreen Akhtar. Fida Hussain Atta
Muhauddin
Page-3
Mst. Sadia Mst. Misbah
Mst. Sidra
Advocate for Applicants No.2
to 7.
I, Fida Hussain S/o Sharfuddin Rajput, adult, muslim, R/o House
Nawabshah, do hereby verify on oath on this 11 th day of January,2008
at Nawabshah, that whatever stated above is true and correct to the
Deponent.
Advocate.
DOCMENTS FILED.
1. Original Balance Certificate of Bank Al-Habib.
2. Original death Certificate of Sharfuddin.
3. Photo Stat copy of Succession Certificate.
4. Original Death Certificate of deceased Ghullam Dastagir.

Document Relied upon.
1. Same as above.
2. Any other evidence, documents
or record.
ADDRESSES of the parties are same , as shown in the
cause title of the plaint.
DRAFTED by me in my office as per instructions.
Dated:-11.01.2008. ADVOCATE FOR APPLICANT

NO.2 TO 7.

Versus
Public at Large
SCHEDULE OF PROPERTIES /DEBTS / SECURITIES

OF DECEASED SYED RAZIULLAH KHAN S/O
SHAFIULLAH KHAN, AS PROVIDED BY THE
APPLICANTS.
DEBTS

application for
certificate
Nil. Nil. Nil. Nil.
SECURITIES

security
01 RAF/0429 Credit Rs.1,59, 760.86 Rs.1,59, 760.86

dated: Balance of (Rupees One lac (Rupees One lac
01.09.2008 of deceased Fifty nine Fifty nine
HBL, Mohni Raziullah thousand seven thousand seven
Bazar Branch, son of hundred sixty hundred sixty
N.Shah Shafiullah and eighty six and eighty six
Pakistan. Khan. Cash pasas along with pasas
amount in interest accrued
PLS Account till receipt of
No.0429700 amount from
0001601. concerned bank..
NAWABSHAH.
DATED:17.10.2008
Ghulam Hyder
……..…………….Applicant
Versus
Punahal Khan & Others

OF DECEASED ALI AKBAR SON OF WAZIR KHAN
DAWOODPOTA / ABBASI , AS PROVIDED BY THE
APPLICANT.
DEBTS

application for
certificate
Nil. Nil. Nil. Nil.
SECURITIES

security
01 PLS Certificate PLS Rs.1,00,000/- Rs.1,00,000/-

deposit- profit Certificate (Rupees One lac) (Rupees One lac
payment, of Deposit – along with profit only).
dated of issue profit etc accrued till
dated: 19.10.06 payment in receipt of
notice period / the name of amount from
tenure three deceased Ali concerned bank..
years date of Akbar son of
maturity Wazir Khan
19.10.2009, Dawoodpota
Receipt / Abbasi in
No.00091955 UBL Masjid
Road,
Nawabshah,

NAWABSHAH.
DATED:
Murad Ali & others
Versus
Public at Large

OF DECEASED ALI KHAN SON OF RAHEEM DAD JAMALI,
AS PROVIDED BY THE APPLICANT.
DEBTS

application for
certificate
Nil. Nil. Nil. Nil.
SECURITIES

security
01 letter No. 4939- Service 1. Funeral charges Rs.3,37,723/-

40/DM/SST/H claim of Rs.5,000/ of S.No.1,3,4,
ESCO/NSH, Late Ali and 6. While 2
dated: Khan and 5 is due
2. WAPDA Welfare
28.07.2008, Mallahi in since the date
issued by SS& T grant in favour of of death of
Deputy Division Widow and minors deceased Ali
Manager SS & T GSO HESCO, Khan,
of deceased
Divisions GSO, at 132 KV whatsoever till
HESCO Gird Station (conditional if the the accrual of
Nawabshah Society widow re-marriage the amount
Nawabshah along with
amount) will be interest, if any.
seized admissible The amount of
Rs.870/-. S.No.7, is
subject to
furnishing
3. Group Life
balance amount
insurance by Director
Rs.1,82,000/- Accounts
(Funds) WAPDA
House Lahore.
4. Gratuity
Rs.1,26,194/-
5. Pension Per
month Rs.919/-
6. 180 days
encashment
Rs.24,529/-.
7. G.P.F A/C
No.190406 of the
deceased as
enquired vide
letter No. 4939-
40/DM/SST/HESC
O/NSH, dated:
28.07.2008, issued
by Deputy Manager
SS & T Divisions
GSO, HESCO
Nawabshah

NAWABSHAH.
DATED:
Mst. Rehana
-------------------------------Applicants
VERSUS
Baby Amna & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Rehana Wd/O Arshad Awan, adult, mulsim, son of Waryam

Khan Pahi, adult, muslim, r/o: Village Malook Khan Pahi, Taluka
Sakrand, District Shaheed Benazir Abad, do hereby state on oath as
under:-

Succession Application

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Succession Application

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IN THE COURT OF 1st ADDITIONAL DISTRICT AND SESSION JUDGE,

SHAHEED BENAZIR ABAD

Succession Application No. of 2012.

Akhtar Hussain. …..………………Applicant.

Asghar Ali and others …………………Opponents.

I humbly submitted on behalf of the opponents the defence

Savings certificates of the minors as under:-

Name of Minor Registration No Certificate No Amount

Dated: Advocate for opponents.

Letter of Administration No. of 2013.

Muhammad Basheer S/O Allah Dad, Awan,

1. Mst. Arshan Wd/o Allah Dad, Awan.

Opponents No. 2 to 6, all, son and daughters of

7. Public at large ………………………………………………………

APPLICATION U/S 218

The applicant named above humbly submits as under:-

6). That after getting clearance certificate, the concerned bank is

of the Honorable court. Hence this application.

has been made for a Will but none is found out.

grant has been made of any certificate, probate or letter of administration in

or the validity thereof if it were granted.

in respect of which letter of administration is applied for.

Documents Relied upon.

2. Abdul Sattar S/o Haji Muhammad Suleman, Awan,

Drafted by me in my office at Nawabshah, under the instructions of the

Letter of Administration No. of 2013.

Muhammad Basheer ------------------------------Applicant

Mst. Arshan & Others

I, Muhammad Yaseen son of Ghulam Rasool, Awan, adult,

1. That I know the applicant as well as opponents No. 1 to 6, who are

2. That deceased Hafiz Muhammad Nazeer, Awan, at the time of his

3. That applicant and opponents No. 1 to 6 are sole legal heirs of

Whatever stated above is true and correct to the best of my knowledge

Succession Application No. 21 of 2013.

Manthar & Others

Share of legal heirs are as under:-

1. Muhammad Khan. Son Rs. 14,285.71/-

Advocate for Applicant

Succession Application No. 21 of 2013.

Manthar & Others

1. That I have received amount Rs. 7142.87 (Seven Thousand One

2. That I have no objection if the surety papers return to the surety.

Whatever stated above is true and correct to the best of my knowledge

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD

Succession Application No. Of 2012.

Mst. Rafiqan alias Rubina

Shakeel Ahmed & Others

I produce Defense Saving Certificate (Original) in the name of

Baby Maha Khan

Mst. Rubina ------------------------------Applicant

Farzand & Others

APPLICATION U/O 32 RULE 3 CPC

the purpose of obtaining Letter of Administration on the consideration of the

grounds mentioned in the accompanying affidavit.

ADVOCATE FOR APPLICANT

IN THE COURT OF THE DISTRICT JUDGE,

Letter of Administration No. of 2013.

Mst. Rubina ------------------------------Applicant

Farzand & Others

2. That accompanying application U/O 32 Rule 3 CPC has been filed by

4. That Justice requires that my accompanying application may be

5. That I shall suffer serious loss if the accompanying application is not

Whatever stated above is true and correct to the best of my knowledge