IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE
Suit No. __________/2015

In the matter of:

1. Plaintiff No. 1, W/o _____________________ (Late),
   R/o House No. ________________________________________, Lahore.

2. Plaintiff No. 2, D/o ____________________,
   R/o House No. ________________________________________, Lahore.

3. Plaintiff No. 3, S/o _____________________,
   R/o _______________________________________________, Lahore.

4. Plaintiff No. 4, D/o ______________________,
   R/o _______________________________________________, Lahore.

… Plaintiffs

VERSUS

1. Public at Large

2. Tehsildar, ________________, Lahore.

3. Patwari, ___________________, Tehsil Lahore.

4. And others.

… Defendants

SUIT FOR DECLARATION OF LEGAL HEIRS WITH MANDATORY INJUNCTION

Respectfully Sheweth:

1. That the deceased, Mr. __________, S/o _______________, died on 02-11-2001, leaving behind the following legal heirs:

   • Widow (Plaintiff No. 1)

   • Daughter (Plaintiff No. 2)
     (Death certificate attached as Annexure “A”)

2. That Plaintiff No. 1 is the widow, and Plaintiff No. 2 is the daughter of the deceased. This suit for declaration is being filed under their signatures in their personal capacity. The addresses provided in the title are sufficient for issuance of notices.

3. That the deceased was the lawful owner in possession of property bearing Property No. ____________________________, measuring 5.5 Marlas, situated at _____________________________, Mauza ___________________, Tehsil & District Lahore (hereinafter referred to as “the suit property”).

4. That the title of the deceased in the suit property stems from a registered Sale Deed, Document No. ________, Volume No. 1, Book No. ________, dated 18-06-1989, registered with the Sub-Registrar, City District Lahore. (Copy annexed as Annexure “B”)

5. That the Plaintiffs are the only surviving legal heirs of the deceased and are thus entitled to succeed to the ownership of the suit property. Consequently, their names should be incorporated in the revenue record by Defendants No. 2 and 3.

6. That despite repeated approaches by the Plaintiffs, Defendants No. 2 and 3 have failed to effect the necessary mutation, demanding proof of their status as legal heirs. Hence, this suit is being filed.

7. That the cause of action initially arose upon the death of the deceased on 02-11-2001, and subsequently each time the Defendants refused to acknowledge the Plaintiffs as legal heirs. The cause of action is continuing.

8. That the suit property is located within the jurisdiction of this Hon’ble Court, and the cause of action also accrued herein; thus, this Court is competent to adjudicate this matter.

9. That the value of the suit for the purposes of court fees is affixed in accordance with law.

PRAYER

In view of the foregoing, it is respectfully prayed that this Hon’ble Court may graciously be pleased to:

a. Declare the Plaintiffs as the only legal heirs of the deceased Mr. __________ S/o __________.

b. Direct Defendants No. 2 and 3 to mutate and incorporate the names of the Plaintiffs in the relevant revenue and property records with respect to the suit property.

c. Grant any other relief deemed just and appropriate in the circumstances of the case.

Plaintiffs
Through Counsel:

__________________________
Advocate High Court

Law Associates

VERIFICATION

Verified on oath at Lahore this ___ day of January, 2015, that the contents of paragraphs 1 to 6 are true and correct to the best of our knowledge and belief, and paragraphs 7 and 8 are true to the best of our information and belief.

__________________________
Plaintiffs