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IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

Civil Suit No. ______________/2023

1. MUHAMMAD SHAFIQUE IDREES,

Son of Muhammad Idrees,

2. KIRAN TARIQ,
3. ZUNAIRA YAHYA,
4. FAIZA USMAN,
5. HAJRA ABU BAKR,
Daughters of Muhammad Idrees,
6. FAKHRA IDREES,
Widow of The Deceased,
Resident of 110,Mohalla abbas block Mustafa town , Lahore.
……Plaintiffs
VERSUS

1. PUBLIC AT LARGE.
2. LAHORE DEVELOPMENT AUTHORITY, through its Director
General, LDA Plaza, Egerton Road, Lahore.

……. Defendants

SUIT FOR DECLARATION WITH CONSEQUENTIAL RELIEF

Respectfully Sheweth:

1. That the brief facts are that the plaintiffs are the legal heirs of
Muhammad Idrees son of Sheikh Muhammad Tuffail died on
09.04.2017 and left behind the plaintiffs as his only legal heirs.
Plaintiffs No. 1 is the real son and plaintiffs No. 2 to 5 are the
daughters of the deceased. And the plaintiff No.6 is the widow of
the deceased. All the plaintiffs are major and residing at the
above-mentioned address. The plaint is being filed on
21.03.2023.
2. That the predecessor in interest of the plaintiffs namely
Muhammad Idrees was the Sole owner of the property (i) plot
No. 000110, measuring 5 Marlas, situated at Block/Sector ABS
Mustafa Town Housing Scheme, Lahore. After the death of the
predecessor-in-interest of the plaintiffs and the plaintiffs are in
possession of the suit property.
3. That the plaintiffs are the only legal heirs of the deceased
Muhammad Idrees and are entitled to inherit the above-said
property to their names according to their legal shares as per
the applicable laws of inheritance. Nobody else has any right or
interest towards the suit property, and the plaintiffs seek a
declaration to that effect. Therefore, under law, defendant No. 2
is bound to transfer the suit property situated in his scheme to
the names of the plaintiffs and also to amend his official records
in respect of the same accordingly, failing which the plaintiffs
shall suffer an irreparable loss.
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4. That the cause of action finally arose a fortnightly ago when

the defendant No. 2 refused to transfer the suit property to the
names of the plaintiffs without obtaining a decree from this
Honourable Court that they are the only legal heirs of the
deceased, hence, this suit.
5. That the plaintiffs reside at Lahore, office of the defendants
No. 2 is well as the suit properties are also situated at Lahore,
hence, this Honorable Civil Court at Lahore has jurisdiction to try
the suit.
6. That the value of the suit for the purposes of court fee and
jurisdiction is fixed at Rs. 600/- but no court fee is required to
pay under law.

Under the circumstances mentioned above, it is

most respectfully prayed that a decree for declaration
with consequential relief may very kindly be passed in
favour of the plaintiffs and against the defendants
declaring therein that the plaintiffs are the only legal
heirs of the deceased Muhammad Idrees son of
Muhammad Shafique Adrees and the plaintiffs are
entitled to inherit the suit properties in their name
according to their shares and no one else have any
right, title or interest over the same and as a
consequential relief, the defendant No. 2 may kindly be
directed to incorporate the names of the plaintiffs in his
official record instead the name of the Muhammad
Idrees (deceased).
Any other relief, which this Honourable Court
deems fit in the circumstances of the case may also be
awarded.
Plaintiffs

Through

Ch Sabir Ali Padhyar

Advocate High Court
Office No.11/12 Farid Kot road Sarwar building
Lahore.
VERIFICATION
Verified on oath at Lahore on this 21 st day of March 2023 that
the contents of the paras No. 1 to 3 are correct to the best of my
knowledge and those of remaining paras No. 4 to 6 are correct
to the best of my information and belief.
Plaintiffs