Heirship Certificate NADRA declined (Suit for heirship certificate format)

 

Suit for heirship Certificate after decline certificate of NADRA for succession certificate 

In the name of ALLAH, the most beneficent, the most merciful

IN THE COURT OF SENIOR CIVIL JUDGE, RAWALPINDI

 

Mrs. Fatima Ali Ahmed widow of Nisar Khan Ahmed R/o House No. 787, Chishti Street, Mohanpura, Rawalpindi

 

        Plaintiff

 

Versus

 

Public at Large

                                                                          Defendant

 

SUIT FOR DECLARATION OF LEGAL HEIRS

OF DECEASED KAMRAN MALIK GUJAR  

 

Respectfully Sheweth:-

 

1.   That the husband of the plaintiff namely Kamran Malik Gujar  son of Malik Jan Khan has died on 30-05-2021. (Copy of death certificate is attached herewith).

 

2.   That the deceased was owner of following properties:-

 

                     i.            House No. CB-4547, Jani Mohallah, Tahli Mohri Road, Rawalpindi

 

                  ii.            Shop No. 6, Jugnu Market, Al Muzafar Centre, Saddar, Rawalpindi

 

3.   That  after the death of deceased Kamran Malik Gujar, following are the surviving legal heirs of deceased:-

 

 

Sr. No.	Name of Heir	Relation with deceased
i.	Mrs. Fatima Ali Ahmed	Widow
ii.	Chaudhary Gulbahar Khan	Minor son
iii.	Samina Tariq Ahmed	Minor daughter
iv.	Saima Noureen Kausar	Minor daughter
v.	Malik Jan Khan	Father
vi.	Nighat Ahmed	Mother

 

4.   That the above stated legal heirs are the only legal heir of Kamran Malik Gujar (Late) and there is no any other legal heir(s) of deceased Kamran Malik Gujar .

 

5.   That the plaintiff applied for Succession Certificate/ Letter of Administration before NADRA authority, but the request of plaintiff was declined by NADRA by way of issuance of Pre-Processing  Decline Certificate on 20-05-2022.

 

6.   That the cause of action accrued to the plaintiff on 30-05-2021 when the husband of plaintiff died and lastly on 20-05-2022  when request of plaintiff for issuance of Succession Certificate/ Letter of Administration was declined by NADRA, which is still continuing.

 

7.   That the cause of action accrued at Rawalpindi, properties of deceased are also situated in Rawalpindi, therefore, this Honourable court has jurisdiction to adjudicate upon the matter.

 

8.   That the prescribed court fee has been fixed on the plaint.

 

PRAYER:

 

Under the foregoing circumstances, it is, therefore, prayed that the instant suit may kindly be decreed in favour of plaintiff to the effect that the following are the only legal heirs of deceased Kamran Malik Gujar:-

 

 

 

Sr. No.	Name of Heir	Relation with deceased
i.	Mrs. Fatima Ali Ahmed	Widow
ii.	Chaudhary Gulbahar Khan	Minor son
iii.	Samina Tariq Ahmed	Minor daughter
iv.	Saima Noureen Kausar	Minor daughter
v.	Malik Jan Khan	Father
vi.	Nighat Ahmed	Mother

 

        and are entitled to inherit their legal shares from the properties of deceased Kamran Malik Gujar  .  

 

 

Plaintiff

Through

 

 

Counsel

Advocate High Court   

VERIFICATION

 

Verified on oath at Rawalpindi on this __ day of June, 2022 that the contents of the plaint are true and correct to the best of my knowledge and belief and nothing has been concealed from this Honourable Court.

 

Plaintiff 

Download heirship Certificate suit after nadra declines