IN THE COURT OF LEARNED SENIOR CIVIL JUDGE, RAWALPINDI
IN THE COURT OF LEARNED SENIOR CIVIL JUDGE, RAWALPINDI
1. Abdul Sabir Khan
2. Abdul Rashid Khan
3. Said Imran Khan
4. Abdul Saad Khan
5. Abdul Haseeb Khan>>>>>>>>>>>>>>>>
6. Amanat Ullah Khan>>>>>>>>>>>>>>>>
7. Shujat Ullah Khan
8. Hakim Ullah Khan
9. Mst. Bibi Shaheen
W/o Said Imran Khan
10 Mst. Fitrani Bibi
W/o Ameer Saeed
All resident of House No. 1 , Satellite town , Scheme No. 1, Rawalpindi.
Plaintiffs.
Versus
Public at Large
Defendant.
SUIT FOR DECLARATION
Respectfully
Sheweth:-
1. That
Sheikh Jahngir Khan S/o Sheikh Dost Muhammad Khan, father of the Plaintiffs
died on 14-08-2012, at the given address in Rawalpindi.
2. That
the said Sheikh Jahngir Khan has following legal heirs:-
1. Abdul Sabir Khan
2. Abdul Rashid Khan
3. Said Imran Khan
4. Abdul Saad Khan
5. Abdul Haseeb Khan
6. Amanat Ullah Khan>>>>>>>>>>>>>>>>Sheikh Jahngir Khan
7. Shujat Ullah Khan
8. Hakim Ullah Khan
9. Mst. Bibi Shaheen
W/o Said Imran Khan
10 Mst. Fitrani Bibi
W/o Ameer Saeed
3. That
Sheikh Jahngir Khan contracted single marriage with Mst. Gull Shaheen, who also
died on 26 Aug 2009 during the life time Sheikh Jahngir Khan it is pertinent to mention here that the parents
of said Late Sheikh Jahngir Khan had already died during his life time,
therefore the above said persons i.e. the plaintiffs are the only legal heirs
left behind by Sheikh Jahngir Khan (deceased). The death certificate of Sheikh
Jahngir Khan (deceased) is Annexed herewith as Annexure-A.
4. That
as per law and in the interest of justice a declaration to this affect is
required that the plaintiffs are the only legal heirs of their above named
deceased / predecessor, and there is no
any other legal heir of said deceased, (Sheikh Jahngir Khan), hence this
suit.
5. That
the plaintiffs are residing, the death of said deceased, (Sheikh Jahngir Khan)
took place and the cause of action also accrued herein Rawalpindi, therefore,
this Honourable Court has got jurisdiction to entertain the suit and adjudicate
upon the matter.
6. That
the value of the suit for the purpose of court fee and jurisdiction is fixed at
Rs. 2,000/- which is exempted
from the levy of court fee.
It
is therefore, respectfully prayed that a decree for declaration may kindly be
passed in favour of the Plaintiffs that the plaintiffs are the only legal heirs
of their above named deceased / predecessor, (namely Sheikh Jahngir Khan), fully described
in para No. 1 of the plaint.
Plaintiffs,
Through,
(Name of Advocate /Lawyer)
Advocate High Court, Rawalpindi
VERIFICATION:
Verified on
oath at Rawalpindi on this ______day of Jan 2014 that the of contents Para No.
1 to 4 are true and correct to the best of our knowledge and belief and rest of the paras, on the information received.
Plaintiffs,
IN THE COURT OF LEARNED SENIOR CIVIL JUDGE, RAWALPINDI
Abdul Sabir Khan. Versus Public at
Large
SUIT
FOR DECLARATION
AFFIDAVIT
I,
Abdul Sabir Khan S/o Sheikh Jahngir Khan (late) House No. BB-780, Muhallah Ibrahim,
Scheme No. 1, Rawalpindi, do hereby solemnly affirm and declare that the
contents of above captioned suit are true and correct to the best of my
knowledge and belief and nothing has been concealed thereto.
DEPONENT
Further
verified on oath this _______ day of Jan, 2014 at Rawalpindi that the contents
of above said affidavit are true and correct to the best of my knowledge and
belief and nothing has been concealed thereto.
DEPONENT
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