SUIT FOR DECLARATION OF LEGAL HEIRS - FORMAT

IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE.

CIVIL SUIT NO: ________________________/2013
1. ___________ widow of deceased
2. ___________ son of deceased
3. ________ daughter of deceased
All residents of House No. ______, Lahore.
……PLAINTIFFS
VERSUS
1. PUBLIC AT LARGE
2. LAHORE DEVELOPMENT AUTHORITY, THROUGH ITS
DIRECTOR GENERAL,
.….DEFENDANTS
SUIT FOR DECLARATION WITH MANDATORY
INJUNCTION
Respectfully Sheweth:
1. That the addresses of the parties for the purpose of
service by this Learned Court have correctly been given
above.
2. That succinctly stated, facts giving rise to the filing of
instant suit are that the plaintiffs are the only legal
heirs of Late ______ deceased. Plaintiff No. 1 is his
widow, Plaintiffs No. 2 & 3 are his son & daughter
respectively. There are no legal heirs of ____ deceased
except the plaintiffs.
3. That Late _____ was owner of House No. ___,
situated at ___, Lahore (hereinafter referred to as “the
suit property”). Late ____ became owner of the suit
property vide transfer letter bearing No._____ dated
____ issued by LDA/Defendant No. 2. ( or sale deed if
any with details)
4. That unfortunately, _____deceased died on ____,
thereafter, the plaintiffs approached the office of
LDA/Defendant No. 2 for transfer of suit property in
their name, however, officials of LDA flately refused to
do the same and directed the plaintiffs to get a
declaratory decree from civil court.
5. That the plaintiffs, after death of _____deceased,
have stepped into his shoes as they are his only legal
heirs and defendants No. 2 is duty bound to transfer
the suit property in the name of the plaintiffs.
6. That the cause of action arose firstly on _____ when
____deceased died and for the second time when the
plaintiffs approached officials of Defendant No. 2 &
they refused to consider the plaintiffs as legal heirs of
_____deceased; the cause of action still continues.
7. That the suit property is situated at Lahore,
therefore, this Honourable Court has got jurisdiction to
adjudicate upon the matter.
8. That value of the suit for the purpose of jurisdiction
and court fee is fixed at Rs. 200/-; required court fee
has been affixed on the plaint.
PRAYER
In aforementioned circumstances, it is humbly prayed
that the instant suit for declaration and mandatory
injunction may kindly be decreed in favour of the
plaintiffs as mentioned below:
(i) That the plaintiffs may kindly be declared as only
legal heirs of Late ____ &
(ii) That defendant No. 2 may kindly be directed to
transfer the suit property in the name of the plaintiffs.
Any other relief which this Honourable Court deems fit
and proper and which has not been prayed for
inadvertently may kindly also be granted.
PLAINTIFFS
Through
Zeeshan Ahmad Malik
Advocate High Court
VERIFICATION:
Verified on Oath at Lahore on this ____ day of
____2013 that the contents of Paras No. 1 to 5 are
correct to the best of our knowledge and those of
paras No. 6 to 8 are correct to the best of our belief.
PLAINTIFFS