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| Suit for Partition and Separate Possession of immovable Property format |
In the name of ALLAH, the most beneficent, the most
merciful
IN
THE COURT OF SENIOR CIVIL JUDGE,
Shakeela Khatoon wife of Sagheer Hussain
(daughter of late Mehmood Alam) resident of House No. 3, Street No. 12,
Mohallah Tehmasapabad, Rawalpindi.
Plaintiff
Versus
1.
Sajid Mehmood
2.
Arslan Ali
3.
Zafran Ali
(all three sons of late Mehmood Alam)
4.
Mst. Shaista Parveen (widow of late Mehmood Alam)
House No. 3, Street No. 12, Mohallah
Tehmasapabad,
5.
Sub Registrar,
Defendants
SUIT FOR SEPARATE POSSESSION
THROUGH PARTITION AND FOR PERMANENT AND MANDATORY INJUNCTION
Respectfully
Sheweth:
1.
That late Mehmood Alam son of
Said Alam was the father of plaintiff & defendants No. 1 to 3 and husband
of defendant No. 4, who was owner in possession of House No. 3, measuring
05 Marlas, Street No. 12, Mohallah Tehmasapabad, Rawalpindi through registered
Sale Deed No. 1212 dated 10-03-1980 registered with Sub registrar, Rawalpindi.
2.
That the father of plaintiff
late Mehmood Alam has died on
3.
That the above suit property
is still joint amongst the plaintiff and the defendants No. 1 to 4 and has not
been partitioned by its metes and bonds.
4.
That the plaintiff does not
want to keep the property joint with defendants No. 1 to 4 and want to get
their share separated.
5.
That the defendants No. 1 to
4 were asked to partition the property and to give due share to the plaintiff
out of the house but they have not acceded the genuine request of the plaintiff
6.
That the cause of action
accrued firstly on 30-01-2001 at the time of death of late Mehmood Alam, and
lastly when the request of plaintiff to
partition the suit was not acceded by the defendants No.1 to 4 which is
still continuing day by day.
7.
That the suit property is
situated at
8.
That the value of the suit
property for the purpose of court fees is fixed as Rs. 20,000/- (Rupees twenty thousand
only) and for the purpose of jurisdiction is fixed as Rs. 15,00,000/- being
value of the shares of the plaintiff, upon which prescribed court fee has been
affixed upon the plaint.
PRAYER:
It is,
therefore, prayed that a decree for separate possession through partition of
the House No. 3, measuring 05 Marlas, Street No. 12, Mohallah Tehmasapabad,
Rawalpindi, giving due share to the plaintiffs out of it, and for permanent
injunction & mandatory restraining the defendants from onward selling, transferring,
creating any third party interest, or changing the nature of the suit property in any manner
whatsoever, may be passed in favour of the plaintiff and against the defendants
with cost.
Any relief which this honourable court deems fit and proper may also be awarded to the plaintiffs.
Plaintiff
Through
VERIFICATION:
Verified on oath at Rawalpindi on 06t day
of February, 2021 that the contents of the plaint from Para No. 1 to 5 above are true and correct to the best of my
knowledge while rest of the paras are believed
to be correct as per information received.
Plaintiff
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