IN THE COURT OFSENIOR CIVIL JUDGE LAHORE

1. Amir Mahmood Janjua R/o House No. 626-D Street Shahrae Tufail Presenly R/o House No. 608-2 Street No. 50 Sayar Road, Lahore. 2. Aliya Amir Qureshi R/o 29-B Ali View Garden Society Beiden Road, Lahore Presently R/o House No. 200 Pinehurst Drive, Dothan Alabama 36303.

PLAINIFFS Vs

(1) Public at Large (2) Employees Housing Scheme Punjab through its director University Quaid-iAzam Campus, Lahore.

DEFENDANT

SUIT FOR DECLARATION

RESPECTFULLY SHEWEH:

1. That late Mahmood Janjua S/o Feroz Din R/o House No. 626/D Shahrae Tufail Lahore breathed his last on 15.07.2004 leaving behind the following as his legal heirs.

1. Amir Mahmood Janjua S/o Mahmood Janjua 2. Aliya Amir Qureshi D/o Mahmood Janjua 3. Musarrat Mahmmod W/o Mahmood Janjua 2. That at the time of his death (Late) Mahmood Janjua was owner of a Plot No. 626 measuring 500 Sq.yds Green View Cooperative Housing Society Lahore. The copy of Lease Deed is attached here with the plaint and a Plot of 15-Marla in Employees Housing Scheme Punjab University, Lahore. 3. That Musarrat Mahmood has unfortunately expired on 03.11.2005 after her death shares are transferred to the (1) Amir Mahmood Janjua (2) Mst. Aliya Amir Qureshi is the only remaining legal heirs of deceased. 4. That a week ago plaintiff approached to the defendant No. 2 to his office for the transfer of the names of plaintiffs No. 1 and 2 as the legal heres of late Mahmood Janjua in the above said property after the death of their beloved father. But they flatly refused from transferring the name of plaintiffs and also seeks a declaration form the Court hence his Suit. 5. That the cause of action accrued in favour of Plaintiff a week ago when defendant No. 2 flatly refused to enter the name of plaintiff No. 1 to 2 as he legal heir of Mahmood Janjua which still continues. 6. That the parties belong to Lahore and the property is also situated in Lahore therefore Honable court got jurisdiction to adjudicate upon the matter.

7. That requisite court fees has been fixed.

It is therefore must respectfully prayed that this Honable court may very graciously Declare the Plaintiffs No. 2 to 6 as the only legal heirs of Deceased Mahmood Janjua as according to their Sharia Shares. It is further prayed that a direction may also be granted in favour of plaintiff and against the defendant No. 2 to enter their names as he only legal heirs and reaming owners deceased Mahmood Janjua in their record of the property. It is therefore most respectfully any other relief which this Honable Court may deems fit may also be awarded in favour of the plaintiff.
PLAINTIFF: Amir Mahmood Janjua

Through

Muhammad Kamran Siddiquei

Advocate High Court

Sardar M.Masood Iqbal

Advocate High Court Zahid Law Associates 2nd Floor Nawa-I-Waqt Building Shahra-e- Fatima Jinnah Lahore

Verification
Verified on oath at Lahore on this 8th day of October 2008 that the contents of the pares 1 to 4 are true to the best of our knowledge & those of pares 5 to 7 are correct to the best of our information.

PLAINTIFF: Amir Mahmood Janjua