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IN THE COURT OF 1st ADDITIONAL DISTRICT AND SESSION JUDGE,

SHAHEED BENAZIR ABAD


Succession Application No.
Akhtar Hussain.

of 2012.

..Applicant.
VERSUS

Asghar Ali and others

Opponents.

STATEMENT
I humbly submitted on behalf of the opponents the defence
Savings certificates of the minors as under:Name of Minor

Registration No

Certificate No

Amount

Amir Ali
Amir Ali
Amir Ali
Amir Ali
Amir Ali

18355
18355
18355
18355
18355

HF 264363
FC 882145
FC 882146
FC 882147
EA 145184

10000
1000
1000
1000
500
=13,500/=

2.
Imran Ali
Imran Ali
Imran Ali
Imran Ali
Imran Ali

18354
18354
18354
18354
18354

HF 264362
FC 882142
FC 882143
FC 882144
EA 145183

10000
1000
1000
1000
500
=13,500/=

3.
Mst. Fozia
Mst. Fozia
Mst. Fozia

18359
18359
18359

GB 763523
FC 882154
FC 882155

5000
1000
1000
=7,000/=

4.
Mst. Nazia
Mst. Nazia
Mst. Nazia

18358
18358
18358

GB 763522
FC 882152
FC 882153

5000
1000
1000
=7,000/=

5.
Mst. Shakeela
Mst. Fozia
Mst. Fozia

18360
18360
18360

GB 763524
FC 882156
FC 882157

5000
1000
1000
=7,000/=

1.

6.
Mst. Iqra
Mst. Iqra
Mst. Iqra

18356
18356
18356

GB 763520
FC 882148
FC 882149

5000
1000
1000
=7,000/=

7.
Mst. Fiza
Mst. Fiza
Mst. Fiza

18357
18357
18357

GB 763521
FC 882150
FC 882151

5000
1000
1000
=7,000/=

Dated:

Advocate for opponents.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.
Muhammad Basheer S/O Allah Dad, Awan,
adult, Muslim, R/o Village Allah Dad, Awan,
Deh 34, Dad Taluka Nawabshah,
District Shaheed Benazir Abad

of 2013.

Applicant.

VERSUS
1.
2.
3.
4.
5.
6.

Mst. Arshan Wd/o Allah Dad, Awan.


Abdul Majeed,
Mst. Ayesha,
Mst. Siddiqaan,
Mst. Yeshnan,
Mst. Saleema,

Opponents No. 2 to 6, all, son and daughters of


Late Allah Dad Awan, Muslims, Adults, R/O Village Allah Dad, Awan,
Deh 34 Dad, Taluka Nawabshah, District Shaheed Benazir Abad.
7.
Public at large
Opponents.

APPLICATION U/S 218


SUCCESSION ACT,1925.
The applicant named above humbly submits as under:1).

That Late Muhammad Nazeer son of Late Allah Dad, Awan, was

permanent resident of Village Allah Dad Awan, Deh 34 Dad, Taluka


Nawabshah, District Shaheed Benazir Abad and was died on 05-01-2013, for
which death certificate is submitted herewith as annexure A.
2).

That said deceased at the time of his death left the applicant and

opponents No. 01 to 06 as his sole legal heirs. Applicant is brother, while


opponents No. 1 is mother and 2 to 6 are brother and sisters of the said
deceased respectively.
3).

That said deceased was Suni Muslim and so are his legal heirs.

4).

That said deceased namely Hafiz Muhammad Nazeer, Awan,

had obtained loan from National Bank of Pakistan Ltd, main branch
Nawabshah, amounting to Rs. 62,000/- and deposited/ given gold as surety
against such loan/ amount at the time of his such amount was outstanding
against him and the
P/2

P/2
same was deposited by his legal heirs on this account the bank has issued
clearance certificate photocopy of such certificate issued by the concerned
bank is submitted herewith as annexure B.
6).

That after getting clearance certificate, the concerned bank is not

ready to redeem/ release the gold without providing letter of administration of


the Honorable court. Hence this application.
7).

The said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


8).

That no application has been made to any Court so for and no

grant has been made of any certificate, probate or letter of administration in


respect of the documents and estates of the said deceased and there is no
any impediment under the provisions of Succession Act, 1925 or any other
enactment for the time being in force to the grant of the letter of administration
or the validity thereof if it were granted.
9).

That the applicant has fully set forth the amount of loan from

National Bank of Pakistan Ltd, main branch Nawabshah, in Para No.04 above,
in respect of which letter of administration is applied for.

PRAYER

The applicant, therefore, prays that the Honourable court may be


pleased to issue a Letter of Administration in his favour authorizing/
empowering him to get/ receive the aforesaid gold from concerned authorities.

Applicant
Advocate for Applicant.

P/3

P/3

VERIFICATION.
I, Muhammad Basheer S/O Late Allah Dad, Awan, adult, Muslim, r/o:
Village Allah Dad, Awan, Deh 34 Dad, Taluka, Nawabshah, District Shaheed
Benazir Abad, do hereby verify on oath on this ------ day of September 2013 at
Nawabshah, that whatever stated above is true and correct to the best of my
knowledge and belief.

Deponent
I know the deponent
Advocate

Documents filed
As Annexure "A" & "B".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1.

Applicant herself

2.

Abdul Sattar S/o Haji Muhammad Suleman, Awan,

3.

Muhammad Yaseen S/o Ghulam Rasool,

both R/o Village Allah Dad Awan, Taluka Nawabshah,


District Shaheed Benazir Abad.
Drafted by me in my office at Nawabshah, under the instructions of the
applicant.
Addresses of the parties are same as shown in the cause title of the
application
Dated:(ASIF HAM AYUN MUGHAL)

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.
Muhammad Basheer

of 2013.

------------------------------Applicant

VERSUS
Mst. Arshan & Others
------------------------------ Opponents.

A F F I D A V I T.
I, Muhammad Yaseen son of Ghulam Rasool, Awan, adult,
Muslim, r/o: village Allah Dad, Awan, Deh 34 Dad, Taluka, Nawabshah, District
Shaheed Benazir Abad, do hereby state on oath as under:1.

That I know the applicant as well as opponents No. 1 to 6, who are

legal heirs of deceased Hafiz Muhammad Nazeer Awan, son of Late Allah
Dad, Awan, who died on 05.01.2013.
2.

That deceased Hafiz Muhammad Nazeer, Awan, at the time of his

death left some gold which was mortgaged in National Bank of Pakstan Ltd,
main branch Nawabshah.
3.

That applicant and opponents No. 1 to 6 are sole legal heirs of

deceased Hafiz Muhammad Nazeer, Awan, and prior to this no application in


this respect has either been applied for or granted in favour of legal heirs of
deceased.
Whatever stated above is true and correct to the best of my knowledge
and belief.

Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD.
Succession Application No. 21 of 2013.
Muhammad Khan.
------------------------------Applicant
VERSUS
Manthar & Others
------------------------------ Opponents.
STATEMENT.
Share of legal heirs are as under:1.

Muhammad Khan.

Son

Rs. 14,285.71/-

2.

Manthar

Son

Rs. 14,285.71/-

2.

Ahmed Khan.

Son

Rs. 14,285.71/-

3.

Didar Ali.

Son

Rs. 14,285.71/-

3.

Khair Muhammad.

Son

Rs. 14,285.71/-

5.

Nizam Din.

Son

Rs. 14,285.71/-

6.

Mst Mehran.

Daughter

Rs. 7,142.87/-

7.

Mst. Hajani.

Daughter

Rs. 7,142.87/______________
Total= 1, 00,000/______________

Advocate for Applicant

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No. 21 of 2013.
Muhammad Khan.
------------------------------Applicant
VERSUS
Manthar & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Mst. Hajani D/O Late Muhammad Yateem, Khoso, W/O Munawar Ali,
Khoso, adult, Muslim, r/o: Deh 38 Dad Village Khair Muhammad Khoso,
Taluka Nawabshah, District Shaheed Benazir Abad,

do hereby state on oath

as under:1.

That I have received amount Rs. 7142.87 (Seven Thousand One

Hundred Fourty Two Rupees & Eighty Seven paisa Only) being opponent
No. 7, from applicant Muhammad Khan S/O Yateem Khan Khoso, being my
share in the amount left by my late father in Succession Application No. 21 of
2013.
2.

That I have no objection if the surety papers return to the surety.

Whatever stated above is true and correct to the best of my knowledge


and belief.
Deponent.

(Mst. Hajani, Khoso)


I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD


Succession Application No.

Of 2012.

Mst. Rafiqan alias Rubina


--------------------------Applicant.
Versus.
Shakeel Ahmed & Others
-----------------------Opponents.

STATEMENT
I produce Defense Saving Certificate (Original) in the name of
following minor:Baby Maha Khan
D/O Late Muhammad Yaseen Khan.

Nawabshah
Dated:Applicant.

Rs. 12960.83/-

Advocate for

Letter of Administration No.


Mst. Rubina

of 2013.

------------------------------Applicant
VERSUS

Farzand & Others


------------------------------ Opponents.

APPLICATION U/O 32 RULE 3 CPC

It is prayed that this Honourable Court may be pleased to


appoint opponent No.2, as guardian ad-litim for minors opponent No.5 to 9, for
the purpose of obtaining Letter of Administration on the consideration of the
grounds mentioned in the accompanying affidavit.

ADVOCATE FOR APPLICANT


NAWABSHAH.
DATED:

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.
Mst. Rubina

of 2013.

------------------------------Applicant
VERSUS

Farzand & Others


------------------------------ Opponents.
A F F I D A V I T.

I, Rubina Wd/O Buxal, Bughio, adult, Muslim, r/o: Shahbaz Colony,


Near Town Committee Kandiaro, District Naushehrofaroze. House No. 104
Deh 50 Dad Azeem Colony Nawabshah,
1.

do hereby state on oath as under:-

That I am applicant and hence fully conversant with the facts of the

present application.
2.

That accompanying application U/O 32 Rule 3 CPC has been filed by

me, the contents where of are true and may be read as part of this affidavit.
3.

That opponent No.2, is real brother minors, and the minors are under

the care and custody of opponent No.2, and she has no interest in the matter
in controversy in the application adverse that of minors and that she is a fit
person to be so appointed.
4.
That Justice requires that my accompanying application may be
allowed.
5.
That I shall suffer serious loss if the accompanying application is not
allowed.
Whatever stated above is true and correct to the best of my knowledge
and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.

of 2013.

Mst. Rubina Wd/O Bakhshal Bughio,


adult, Muslim, at present R/o Shahbaz Colony,
Near Town Committee Kandiaro, District Naushehrofaroze.

House No. 104 Deh 50 Dad Azeem Colony Nawabshah


Applicant.
VERSUS
6.
7.
8.
9.
10.
11.
12.
13.
14.

Farzand Ali S/o. Bakhshal Bughio,


Javed Ali S/o. Bakhshal Bughio,
Parvez Ali S/o. Bakhshal Bughio,
Naved Ali S/o. Bakhshal Bughio,
Sajida D/o. Bakhshal Bughio,
Aged about 16 years.
Reena D/o. Bakhshal Bughio,
Aged about 15 years.
Faraz S/o. Bakhshal Bughio,
Aged about 14 years.
Tanveer S/o. Bakhshal Bughio,
Aged about 12 years.
Tasveer S/o. Bakhshal Bughio,
Aged about 12 years.

All, Muslims, Adults except minors No. 05 to 09,


through their real brother and ad-litim opponent No. 02 Javed Ali,
R/o Shahbaz Colony, Near Town Committee Kandiaro,
District Naushehrofaroze.
Permanent Address House No. 104 Deh 50 Dad
Azeem Colony Nawabshah.
15.
Public at large
Opponents.

APPLICATION U/S 218


SUCCESSION ACT,1925.
The applicant named above humbly submits as under:1).

That late Bakhshal S/O Imam Bux Bughio, r/o: House No. 104, Deh 50

Dad, Azeem Colony, Nawabshah , District Shaheed Benazir Abad, died on


10.11.1999, for which death certificate is submitted herewith as annexure A.
2).

That said deceased at the time of his death left the applicant and

opponents No. 01 to 09 as his sole legal heirs. Applicant is widow, while


opponents No.1 to 09 are sons and daughters of the said deceased.
3).

That said deceased was Suni Muslim and so are his legal heirs.
P/2

P/..2

4).

That said deceased namely Bakhshal had obtained loan from

House Building Finance Corporation Rs. 1,00,000/-, in 1986. On the house


viz. house No. 104

Deh 50 Dad, Azeem Colony, Nawabshah ,

District

Shaheed Benazir Abad.


5).

That the said loan has been paid in installments, some

installments had been paid in the life of the deceased and after his death the
remaining amount has been paid by his heirs. Thereafter there is no any
outstanding amount against the said house and House Building Finance
Corporation issued clearance certificate in this regard. Photocopy of the same
is attached herewith as annexure B.
6).

That after getting clearance certificate, House Building Finance

Corporation is not ready to redeem the documents of the said house without
providing letter of administration of the Honorable court. Hence this
application.

7).

The said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


8).

That to maintain and look after the same house and redeem the

documents

from

House

Building

Finance

Corporation,

letter

of

administration is required by the applicant and opponents No. 01 to 09, hence


this application.
9).

That no application has been made to any Court so for and no

grant has been made of any certificate, probate or letter of administration in


respect of the documents and estates of the said deceased and there is no
any impediment under the provisions of Succession Act, 1925 or any other
enactment for the time being in force to the grant of the letter of administration
or the validity thereof if it were granted.

10).

That the applicant has fully set forth the amount of loan from

House Building Finance Corporation, in Para No.05 above, in respect of which


letter of administration is applied for.
P/..3
P/..3

PRAYER
The applicant, therefore, prays that the Honourable court may be
pleased to issue a Letter of Administration in her favour authorizing/
empowering her to get/ receive the aforesaid documents from concerned
authorities.
Applicant
Advocate for Applicant.

VERIFICATION.
I, Rubina Wd/O Bakhshal Bughio, adult, Muslim, r/o: House No. 104,
Deh 50 Dad, Azeem Colony, Nawabshah, District Shaheed Benazir Abad and
Permanent Address R/o Shahbaz Colony, Near Town Committee Kandiaro,
District Naushehrofaroze. do hereby verify on oath on this ------ day of July
2013 at Nawabshah, that whatever stated above is true and correct to the
best of my knowledge and belief.
Deponent
I know the deponent
Advocate

Documents filed
As Annexure "A" & "B".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant herself
2. Sher Muhammad S/o. Muhammad Khan Khaskheli,
R/o. Village Fakir Muhammad Deenari,
Near Doctors Colony Nawabshah.

3. Mashooque Ali S/o. Dargahi Kambrani,


R/o. Afzal Shah Town Nawabshah.
Drafted by me in my office at Nawabshah, under the instructions of the
applicant.
Addresses of the parties are same as shown in the cause title of the
application.

Dated:-

(ASIF HAM AYUN MUGHAL)


Advocate for Applicant.

IN THE COURT OF IST ADDITIONAL DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No. 137 of 2012.
Mst. Dildar Akhtar

. Applicant.

Versus
Shakeel Ahmed & Others

-: R

. Opponents.

P T :-

I have received an amount of Rs. 1,40,259.42/-, being


opponent No. 5, from applicant Mst. Dildar Akhtar, being my share in the
amount left by my father in Succession Application No. 137 of 2012.
(Mst. Shumaila)
(S/O Late Muhammad Afzal Khan.)

IN THE COURT OF IST ADDITIONAL DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No. 137 of 2012.
Mst. Dildar Akhtar

. Applicant.

Versus
Shakeel Ahmed & Others

-: R

. Opponents.

P T :-

I have received an amount of Rs.1,40,259.42/-, being


opponent No. 6, from applicant Mst. Dildar Akhtar, being my share in the
amount left by my father in Succession Application No. 137 of 2012.
(Mst. Shaheen Bibi.)
(S/O Late Muhammad Afzal Khan.)

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

of 2012.

Mst. Rafiqan alias Rubina Wd/O Muhammad


Yaseen Khan, adult, Muslim, r/o Habib
Sugar Mills, Colony, Road Nawabshah,
District Shaheed Benazir Abad.
--------------------------Applicant.
Versus.
2. Shakeel Ahmed .
3. Shahid Khan,
4. Zahid Khan,
5. Mst. Shagufta Shaheen,
6. Mst. Shaista Shaheen,
7. Mst. Shabana Khan,
8. Mst. Zahida Parveen,
All adult Muslims,
8. Mst. Maham Khan, Minor aged about 15 years.
All sons and daughters of late Muhammad Yaseen Khan,
R/o: Habib Sugar Mills, Colony Nawabshah. Nawabshah,
No. 8
9. Public at large
-----------------------Opponents.

APPLICATION U/S 218


SUCCESSION ACT,1925.
The applicant named above humbly submits as under:1). That late Buxal S/O Imam Bux Bughio, r/o: House No. 104, Deh 50
Dad, Azeem Colony, Nawabshah , District Shaheed Benazir Abad, died on
10.11.1999, for which death certificate is submitted herewith as annexure
A.
2).

That said deceased at the time of his death left the applicant and

opponents No. 1 to 4

as his sole legal heirs. Applicant is widow, while

opponents No.1 to 4 are sons of the said deceased.


3).

That said deceased was Suni Muslim and so are his legal heirs.
P/2

P/..2
4).

That said deceased namely Buxal had obtained loan from House

Building Finance Corporation Rs. 1,00,000/-, in 1986. On the house viz house
No. 104 Deh 50 Dad, Azeem Colony, Nawabshah , District Shaheed Benazir
Abad.
5).

That the said loan has been paid in installments, some installments had

been paid in the life of the deceased and after his death the remaining amount
has been paid by his heirs. Thereafter there is no any outstanding amount
against the said house and House Building Finance Corporation issued
clearance certificate in this regard. Photocopy of the same is attached
herewith as annexure B.
6).

That after getting clearance certificate, House Building Finance

Corporation is not ready to redeem the documents of the said house without
providing letter of administration of the Honurable court. Hence this
application.
7).

The said deceased died intestate and due and diligent search has been

made for a Will but none is found out.


8).

That to withdraw the documents aforesaid from House Building

Finance Corporation, a letter of administration is required by the applicant and


opponents No. 1 to 4, hence this application.
9).

That no application has been made to any Court so for and no grant

has been made of any certificate, probate or letter of administration in respect


of the documents and estates of the said deceased and there is no any
impediment under the provisions of Succession Act, 1925 or any other
enactment for the time being in force to the grant of the letter of administration
or the validity thereof if it were granted.

10).

That the applicant has fully set forth the amount of loan from House

Building Finance Corporation, in Para No.4 above, in respect of which letter of


administration is applied for.
P/..3

P/..3

PRAYER
The applicant, therefore, prays that the Honourable court may
be pleased to issue a Letter of Administration in her favour
authorizing/ empowering her to get/ receive the aforesaid
documents from concerned authorities.
Applicant
Advocate for Applicant.

VERIFICATION.
I, Rubina Wd/O Buxal, Bughio, adult, Muslim, r/o: House No.
104, Deh 50 Dad, Azeem Colony, Nawabshah, District Shaheed Benazir Abad,
do hereby verify on oath on this ------ day of January, 2013 at Nawabshah, that
whatever stated above is true and correct to the best of my knowledge and
belief.

Deponent
I know the deponent
Advocate
Documents filed
As Annexure "A" & "B".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant herself

2. Loung Khan S/O Dhani Parto Unar.


3. Lakhadino S/O Muhammad Ismail Unar
Both r/o: Village Pir Nazar Muhammad Shah,
Taluka Kazi Ahmed , District Shaheed Benazir Abad.
Drafted by me in my office at Nawabshah, under the instructions
of the applicant.
Addresses of the parties are same as shown in the cause title
of the application.

Dated:-

(ASIF HAMAYUN MUGHAL)


Advocate for Applicant.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.
Mst. Rubina

of 2013.

------------------------------Applicant
VERSUS

Farzand & Others


------------------------------ Opponents.

A F F I D A V I T.
I, Rubina Wd/O Buxal, Bughio, adult, Muslim, r/o: House No.
104, Deh 50 Dad, Azeem Colony, Nawabshah, District Shaheed Benazir Abad,
do hereby state on oath as under:1.

That I am applicant and hence fully conversant with the facts of the

present application.
2.

That my husband late Buxal S/O Imam Bux, Bughio died on 10-11-

1999. I produce death certificate as Annexure A.


3.

That said deceased Late Buxal, Bughio was permanent r/o House No.

104, Deh 50 Dad, Azeem Colony, Nawabshah, District Shaheed Benazir Abad,
and was a Sunni Muslim.
4.

That said deceased left me and opponents Nos. 1 to 4 as his sole legal

heirs. I am widow, while opponent No.1 to 9 are sons and daughters of


deceased Buxal Bughio.
5.

That said deceased left the house No. 104, deh 50 dad Azeem Colony

Nawabshah which was mortgaged against an amount of Rs.1,00,000 /-, with


House Building Finance Corporation, the same loan now has been cleared
and the photo copy of clearance certificate is attached with the application as
annexure B.

6.

That said deceased died intestate and due and diligent search has

been made for a will but none is found out.


8.

That to withdraw the documents aforesaid from the concerned

authorities a Letter of administration certificate is required by us.


P/2

P/2
9.

That no application has been made to any court so far and no grant has

been made of any certificate, probate or letter of administration in respect of


said documents and estate of the said deceased and there is no any
impediment under the provision of Succession Act, 1925 or any other

enactment for the time being enforce to grant the letter of administration or the
validity thereof if it were granted.

10.

That I therefore, pray that letter of administration may pleased be

granted in

my favour authorizing / empowering me to get / receive the

documents aforesaid.
Whatever stated above is true and correct to the best of my knowledge
and belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD

Letter of Administration No.


Mst. Rubina

of 2013.

------------------------------Applicant
VERSUS

Farzand & Others


------------------------------ Opponents.

A F F I D A V I T.

I, Sher Muahmmad son of Muhammad Khan, Khaskheli ,


adult, Muslim, r/o: village Faqeer Muhammad Deenari, Near Doctors
Colony, Nawabshah, District Shaheed Benazir Abad, do hereby state
on oath as under:-

1.

That I know the applicant as well as opponents No. 1 to 4, who

are legal heirs of deceased Buxal, son of Imam Bux, Bughio, who died
on 10.11.1999.
2.

That deceased Buxal, at the time of his death left a house which

was mortgaged in House Building Finance Corporation.

3.

That applicant and opponents No. 1 to 4 are sole legal heirs of

deceased Buxal, Bughio and prior to this no application in this respect


has either been applied for or granted in favour of legal heirs of
deceased.

Whatever stated above is true and correct to the best of my


knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.
Mst. Rubina

of 2013.

------------------------------Applicant
VERSUS

Farzand & Others


------------------------------ Opponents.

A F F I D A V I T.

I, Mashooque Ali son of Dargaahi, Qambrani, adult,


Muslim, r/o: Afzaal Shah Town, Sanghar Road, Nawabshah, , do
hereby state on oath as under:-

1.

That I know the applicant as well as opponents No. 1 to 9, who

are legal heirs of deceased Buxal, son of Imam Bux, Bughio, who died
on 10.11.1999.
2.

That deceased Buxal, at the time of his death left a house which

was mortgaged in House Building Finance Corporation.

3.

That applicant and opponents No. 1 to 9 are sole legal heirs of

deceased Buxal, Bughio and prior to this no application in this respect

has either been applied for or granted in favour of legal heirs of


deceased.

Whatever stated above is true and correct to the best of my


knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.
Mst. Rubina

of 2013.

------------------------------Applicant
VERSUS

Farzand & Others


------------------------------ Opponents.

A F F I D A V I T.

I, Sher Muhammad son of Muhammad Khan, Khaskheli,


adult, Muslim, r/o: Village Faqeer Muhammad Deenari, near Doctors
Colony, Nawabshah, do hereby state on oath as under:-

1.

That I know the applicant as well as opponents No. 1 to 9, who

are legal heirs of deceased Buxal, son of Imam Bux, Bughio, who died
on 10.11.1999.

2.

That deceased Buxal, at the time of his death left a house which

was mortgaged in House Building Finance Corporation.

3.

That applicant and opponents No. 1 to 9 are sole legal heirs of

deceased Buxal, Bughio and prior to this no application in this respect


has either been applied for or granted in favour of legal heirs of
deceased.

Whatever stated above is true and correct to the best of my


knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2012.

Mst. Rafiqan @ Rubina


-------------------------------Applicant
VERSUS
Shakeel Ahmed & another
------------------------------ Opponents.
A F F I D A V I T.
I, Zahida Parveen D/O Late Muhammad Yaseen Khan, adult, muslim, r/o:
H.No. 513/28,29 Mohalla I.C Nawabshah, Municipal Committee Nawabshah District
Shaheed Benazir Abad, do hereby state on oath as under:1.
That I am Opponent No.7 in the above matter and hence fully conversant with
the facts of the present application.
2.
That my father late Muhammad Yaseen Khan S/O Nanny Khan, died on 1304-2012.
3.
That said deceased Muhammad Yaseen Khan was permanent r/o: Habib
Sugar Mills (Pvt) Ltd. Colony Nawabshah, District Shaheed Benazir Abad, and was a
Sunni Muslim.
4.
That said deceased left applicant, and us Opponents Nos. 1 and 8 his sole
legal heirs.
5.
That said deceased left an amount of Rs. 65821/- with National Bank of
Pakistan University branch, Nawabshah, for releasing thereof, for which Succession
Certificate is required.

6.
That said deceased died intestate and due and diligent search has been
made for a will but none is found out.
7.
That to withdraw the amount aforesaid from the concerned branch, a
succession certificate is required to applicant.
8.
That I have no objection if the Honourable court may be pleased to grant
Succession Certificate in favour of applicant, authorizing/ empowering her to get /
withdraw / receive the amount aforesaid with interest to be accrued up to the date of
withdrawal from concerned branch for disbursement thereof amongst all the legal
heirs according to our legal share, in accordance with law.
Whatever stated above is true and correct to the best of my knowledge and
belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2012.

Mst. Sanobar
-------------------------------Applicant
VERSUS
Haji Shahdad Khan & another
------------------------------ Opponents.
A F F I D A V I T.
I, Mst. Sehar Bano W/O Haji Shahdad Khan, Channar, adult, muslim, r/o:
Mehran Colony, Sakrand Road Nawabshah, District Shaheed Benazir Abad, do
hereby state on oath as under:1.
That I am Opponent No.2 in the above matter and hence fully conversant with
the facts of the present application.
2.

That my son late Niaz Hussain Channar, died on 19-08-2012.

3.
That said deceased Niaz Hussain Channar was permanent r/o: Mehran
Colony, Sakrand Road Nawabshah, District Shaheed Benazir Abad, and was a Sunni
Muslim.
4.
That said deceased left applicant, minors 2 to 5 and us Opponents Nos. 1 and
2 his sole legal heirs.
5.
That said deceased left an amount of Rs. 65821/- with National Bank of
Pakistan University branch, Nawabshah, for releasing thereof, for which Succession
Certificate is required.

6.
That said deceased died intestate and due and diligent search has been
made for a will but none is found out.
7.
That to withdraw the amount aforesaid from the concerned branch, a
succession certificate is required to applicant.
8.
That I have no objection if the Honourable court may be pleased to grant
Succession Certificate in favour of applicant, authorizing/ empowering her to get /
withdraw / receive the amount aforesaid with interest to be accrued up to the date of
withdrawal from concerned branch for disbursement thereof amongst all the legal
heirs according to our legal share, in accordance with law.
Whatever stated above is true and correct to the best of my knowledge and
belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.
Mst. Rubina

of 2013.

------------------------------Applicant
VERSUS

Farzand & Others


------------------------------ Opponents.

A F F I D A V I T.

I, Sher Muahmmad son of Muhammad Khan, Khaskheli ,


adult, Muslim, r/o: village Faqeer Muhammad Deenari, Near Doctors
Colony, Nawabshah, District Shaheed Benazir Abad, do hereby state
on oath as under:-

1.

That I know the applicant as well as opponents No. 1 to 4, who

are legal heirs of late Buxal, son of Imam Bux, Bughio, who died on
10.11.1999.
2.

That deceased Buxal, at the time of his death left a house which

was mortgaged in House Building Finance Corporation.

3.

That applicant and opponents No. 1 to 4 are sole legal heirs of

deceased Buxal, Bughio and prior to this no application in this respect


has either been applied for or granted in favour of legal heirs of
deceased.

Whatever stated above is true and correct to the best of my


knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Letter of Administration No.

of 2013.

Mst. Rubina
------------------------------Applicant
VERSUS
Farzand & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Zulekhan Wd/O Muhammad Laique Unar, adult,
Muslim, r/o: village Saleh Shah, Taluka Kazi Ahmed, District Shaheed
Benazir Abad, do hereby state on oath as under:1.

That I am applicant and hence fully conversant with the facts of

the present application.


2.

That my husband late Muhammad Laique S/O Punhoon Khan

Unar died on 05-05-2011. I produce death certificate as Ex:__________.


3.

That said deceased Late Muhammad Laique was permanent r/o

village Saleh Shah, Taluka Kazi Ahmed,

District Shaheed Benazir

Abad and was a Sunni Muslim.


4.

That said deceased left me and opponents Nos. 1 to 4 as his sole

legal heirs. I am widow, while opponent No.1 mother, opponent No.2,


daughter and opponents No. 3 and 4, are brothers of deceased
Muhammad Laique.
5.

That said deceased left an amount of Rs.03,08.192/-, with

United Bank Limited Kazi Ahmed Branch, at the time of his death. I
produce Bank Balance Certificate as Ex. _____________.

6.

That said deceased died intestate and due and diligent search

has been made for a will but none is found out.


P/2

P/2
7.

That such heir ship certificate issued by the Mukhtiarkar

(Revenue), Nawabshah is submitted as Ex._________________.

8.

That to withdraw the amount aforesaid from the concerned

Bank a succession certificate is required by us.

9.

That no application has been made to any court so far and no

grant has been made of any certificate, probate or letter of


administration in respect of debts, securities and estate of the said
deceased and there is no any impediment under the provision of
Succession Act, 1925 or any other enactment for the time being
inforce to grant the succession certificate or the validity thereof if it
were granted.

10.

That I therefore, pray that Succession Certificate may pleased be

granted in my favour authorizing / empowering me to get /


withdraw / receive the amount aforesaid with interest to be accrued
up to the date of withdrawal from bank etc for disbursement thereof

amongst all the legal heirs according to our legal share, in accordance
with law.

Whatever stated above is true and correct to the best of my


knowledge and belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


S.A. NO.

Mst. Zulekhan

2011

-------------------------------Applicant
VERSUS

Mst. Sahiba Khatoon & Others


------------------------------ Opponents.

APPLICATION U/O 32 RULE 3 CPC

It is prayed that this Honourable Court may be pleased to


appoint opponent No.1, as guardian ad litem for minor opponent No.2,
for

the

purpose

of

obtaining

Succession

Certificate

on

the

consideration of the grounds mentioned in the accompanying affidavit.

ADVOCATE FOR APPLICANT


NAWABSHAH.
DATED:

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


S.A. NO.
Mst. Zulekhan

2011
-------------------------------Applicant

VERSUS
Mst. Sahiba Khatoon & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Zulekhan Wd/O Muhammad Laique Unar, adult,
Muslim, r/o: village Saleh Shah, Taluka Kazi Ahmed, District Shaheed
Benazir Abad,
1.

do hereby state on oath as under:-

That I am applicant and hence fully conversant with the facts of

the present application.


2.

That accompanying application U/O 32 Rule 3 CPC has been

filed by me, the contents where of are true and may be read as part of
this affidavit.
3.

That opponent No.1, is real grand mother of minor, and the

minor is under the care and custody of opponent No.1, and she has
no interest in the matter in controversy in the application adverse that
of minors and that she is a fit person to be so appointed.
4.
That Justice requires that my accompanying application may be
allowed.
5.
That I shall suffer serious loss if the accompanying application
is not allowed.

Whatever stated above is true and correct to the best of my


knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD


Succession

Application No.

of 2011.

Mst. Zulekhan Wd/O Mhammad Laique


Unar, adult, Muslim, r/o: Village Saleh
Shah, Taluka Kazi Ahmed, District
Shaheed Benazir Abad.
--------------------------Applicant.
Versus.
10. Sahiba Khatoon Wd/O Punhoon Khan .
11. Baby Hakeeman D/O Late Muhammad Laique ,
aged about 11 years,
12. Muhammad Ismail S/O Late Punhoon Khan.
13. Haji Chutto S/O Late Punhoon Khan.
All adults, Muslims, r/o: Village Saleh
Shah, Taluka Kazi Ahmed, District
Shaheed Benazir Abad.
14. Public at large
-----------------------Opponents.

APPLICATION U/S 370 & 372


SUCCESSION ACT,1925.
The applicant named above humbly submits as under:1).

That late Muhammad Laique S/O Punhoon Khan Unar , r/o:

Village Saleh Shah, Taluka Kazi Ahmed, District Shaheed Benazir


Abad, died on 05.052011, for which death certificate is submitted
herewith as annexure A.
2).

That said deceased at the time of his death left the applicant

and opponents No. 1 to 4 as his sole legal heirs. Applicant is widow,

while opponent No.1, is mother, opponents No.2, is daughters and


opponents No.3 and 4 are brothers of the said deceased.
P/2

P/2
3).

That said deceased was Suni muslim and so are his legal heirs.

4).

That said deceased at the time of his death left an amount of

Rs.3,08,192/- with United Bank Limited Kazi Ahmed Branch, Such


certificate issued by Manger, is submitted herewith as annexure B.
5).

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


6).

That to withdraw the amount aforesaid from Bank, a

succession certificate is required by the applicant and opponents No.


1 to 4, hence this application.
7).

That no application has been made to any Court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in
force to the grant of the succession certificate or the validity thereof
if it were granted.
8).

That

the

applicant

has

fully

set

forth

the

securities/amount/debts in Para No.4 above, in respect of which


succession certificate is applied for.
PRAYER
The applicant, therefore, prays that the Honourable
court may be pleased to issue a Succession Certificate
in her favour authorizing/ empowering her to get/ with
draw/ receive the amount aforesaid with interest to be
accrued up to the date of withdrawal from concerned
Bank,

for disbursement thereof amongst all the legal

heirs, according to their legal shares.

Applicant
Advocate for Applicant
P/3

P/3
VERIFICATION.
I, Zulekhan Wd/O Muhammad Laique Unar, adult,
Muslim, r/o: village Saleh Shah, Taluka Kazi Ahmed, District Shaheed
Benazir Abad, do hereby verify on oath on this ------ day of
November, 2011 at Nawabshah, that whatever stated above is true
and correct to the best of my knowledge and belief.

Deponent
I know the deponent
Advocate
Documents filed
As Annexure "A" & "B".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant herself
4. Loung Khan S/O Dhani Parto Unar.
5. Lakhadino S/O Muhammad Ismail Unar
Both r/o: Village Pir Nazar Muhammad Shah,
Taluka Kazi Ahmed , District Shaheed Benazir Abad.

Drafted by me in my office at Nawabshah, under the


instructions of the applicant.
Addresses of the parties are same as shown in the
cause title of the application.

(AMEER ALI
MAHESSAR)
Advocate for Applicant.
Nawabshah.
Dated:

IN THE COURT OF IIND ADDITIONAL DISTRICT JUDGE, SHAHEED


BENAZIR ABAD.
Letter of Administration NO.

of 2011

Aamir Khan Magsi


-------------------------------Applicant
VERSUS
Mst. Shahjah & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Pathani W/O Ali Hassan Magsi, adult, muslim, r/o: Village
Buxo Magsi, Taluka Sakrand, District Shaheed Benazir Abad, do
hereby state on oath as under:1.
of

2.

That I am Opponent No.3 in the above matter and my son Dost


Muhammad Magsi, died on 10.04.2010 and at the time of death
he was permanent r/o: Village Buxo Magsi, Taluka Sakrand,
District Shaheed Benazir Abad, and was a Sunni Muslim.

for

That said deceased left gold, mortgaged in National Bank of


Pakistan, Mohni Bazar Branch, Nawabshah, weighing 82.700
grams as gross weight which became 53-00 grams as net weight
the gold amounting to Rs.74,000/- for which he obtained loan,
which are to be deposited such certificate / letter dated
01.12.2010, issued by NBP, Mohni Bazar Branch, Nawabshah,
which Letter of administration is required.

3.
has

That said deceased died intestate and due and diligent search
been made for a will but none is found out.

of

5.
That I have no objection if the Honourable court may be pleased
to
grant Letter of administration in favour of applicant,
authorizing/
empowering him to get/ withdraw/ receive the gold
aforesaid from
concerned bank for disbursement thereof amongst
all the legal heirs according to our legal share, in accordance with law.

Whatever stated above is true and correct to the best of my


knowledge and belief.

Deponent.
I know the Deponent.

Advocate.

IN THE COURT OF IIND ADDITIONAL DISTRICT JUDGE, SHAHEED


BENAZIR ABAD.
Letter of Administration NO.

of 2011

Aamir Khan Magsi


-------------------------------Applicant
VERSUS
Mst. Shahjah & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Shahjah Wd/O Dost Muhammad Magsi, adult, muslim, r/o:
Village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir Abad,
do hereby state on oath as under:1.

That I am Opponent No.1 in the above matter and I am natural


guardian and real mother of opponent No.4, and my husband
Dost Muhammad Magsi, died on 10.04.2010 and at the time of
death of he was permanent r/o: Village Buxo Magsi, Taluka
Sakrand, District Shaheed Benazir Abad, and was a Sunni
Muslim.

2.

for

That said deceased left gold, mortgaged in National Bank of


Pakistan, Mohni Bazar Branch, Nawabshah, weighing 82.700
grams as gross weight which became 53-00 grams as net weight
the gold amounting to Rs.74,000/- for which he obtained loan,
which are to be deposited such certificate / letter dated
01.12.2010, issued by NBP, Mohni Bazar Branch, Nawabshah,
which Letter of administration is required.

3.
has

That said deceased died intestate and due and diligent search
been made for a will but none is found out.

of

5.
That I have no objection if the Honourable court may be pleased
to
grant Letter of administration in favour of applicant,
authorizing/
empowering him to get / withdraw / receive the gold
aforesaid
from concerned bank for disbursement thereof amongst
all the
legal heirs according to our legal share, in accordance
with law.

Whatever stated above is true and correct to the best of my


knowledge and belief.

Deponent.
I know the Deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED


BENAZIR ABAD
Succession Application No.

Miss. Mehar Afshan & others

Public at Large

61

of 2008.

...Applicants

Versus
.. Opponents

: - STATEMENT - :

In compliance of order dated: 08.01.2011, of the


Honourable Court, I hereby submit Photostat copy of residence
certificate showing the name of Baby Iqra along with his
fathers name as Abdul Jabbar Memon, and present address of
both is as under:
Address:

H # A-35, Govt. Employees Co-operative Housing Society,


Nawabshah.

Advocate for Applicants


Nawabshah.
Dated:08.03.2011

IN THE COURT OF IIND ADDITIONAL DISTRICT JUDGE, SHAHEED


BENAZIR ABAD.
Letter of Administration NO.

Aamir Khan Magsi

of 2011

-------------------------------Applicant
VERSUS

Mst. Shahjah & Others


------------------------------ Opponents.
A F F I D A V I T.
I, Shahid Latif son of Noor Muhammad Magsi, adult, muslim,
r/o: Village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir
Abad, do hereby state on oath as under:-

1.

That I know the applicant as well as opponents No. 1 to 5, who

are legal heirs of late Dost Muhammad son of Ali Hassan Magsi, who
died on 10.04.2010.
2.

That deceased Dost Muhammad at the time of his death left

gold mortaged in National Bank of Pakistan Mohni Bazar Nawabshah,


weighing 82.700 grams as gross weight which become 53.000 grams
as net weight of the gold against the loan of Rs.74,000/-, which are to
be deposited by his legal heirs.

3.

That applicant and opponents No. 1 to 5 are sole legal heirs of

deceased Dost Muhammad and prior to this no application in this


respect has either been applied for or granted in favour of legal heirs of
deceased.

Whatever stated above is true and correct to the best of my


knowledge and belief.
Deponent.
I know the deponent.
Advocate.

IN THE COURT OF IIND ADDITIONAL DISTRICT JUDGE, SHAHEED


BENAZIR ABAD.
Letter of Administration NO.

of 2011

Aamir Khan Magsi


-------------------------------Applicant
VERSUS
Mst. Shahjah & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Ghulam Murtaza son of Ali Nawaz Magsi, adult, muslim, r/o:
Village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir Abad,
do hereby state on oath as under:-

1.

That I know the applicant as well as opponents No. 1 to 5, who

are legal heirs of late Dost Muhammad son of Ali Hassan Magsi, who
died on 10.04.2010.
2.

That deceased Dost Muhammad at the time of his death left

gold mortaged in National Bank of Pakistan Mohni Bazar Nawabshah,


weighing 82.700 grams as gross weight which become 53.000 grams
as net weight of the gold against the loan of Rs.74,000/-, which are to
be deposited by his legal heirs.

3.

That applicant and opponents No. 1 to 5 are sole legal heirs of

deceased Dost Muhammad and prior to this no application in this


respect has either been applied for or granted in favour of legal heirs of
deceased.

Whatever stated above is true and correct to the best of my


knowledge and belief.

Deponent.
I know the deponent.
Advocate.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Letter of Administration NO.

Muhammad Waseem

of 2011

-------------------------------Applicant

VERSUS
Azeem Shahzore & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Zaheer Ahmed son of Bashir Ahmed, Memon, adult, Muslim,
r/o: Mohni Bazar Nawabshah, do hereby state on oath as under:1.

That I know the applicant as well as opponents No. 1 to 3, who

are legal heirs of late Muhammad Saleem son of Abdul Rasheed,


Rajput, who died on 22-10-2009.
2.

That deceased Muhammad Saleem at the time of his death left a

vehicle bearing registration No. ANR -093, Cultus VXR, Model 2007,
which was obtained by him from UBL, Gul Centre, Hyderabad on
lease. After his death the said vehicle was under the possession of the
legal heirs of deceased Muhammad Saleem, who were paying the lease
money regularly. The bank concerned mistakenly took over the
possession of the vehicle on the issue of non payment, but when the
receipts were shown to Bank authority, they demanded Succession
Certificate/ Letter of Administration from the applicant.
3.
That applicant and opponents No. 1 to 3 are sole legal heirs of
deceased Muhammad Saleem and prior to this no application in this

respect has either been applied for or granted in favour of legal heirs of
deceased.
Whatever stated above is true and correct to the best of my
knowledge and belief.
Deponent.
I know the deponent.
Advocate.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD


Letter of Administration No.
Muhammad
Muhammad

Waseem
Saleem,

son

adult,

of 2011.
of

Muslim,

Rajput by caste, r/o: Shahbaz Plaza,


Liaquat Market Nawabshah.
--------------------------Applicant.
Versus.
15. Azeem Shahzore son of M. Saleem Rajput.
16. Mst. Muqadas D/O Muhammad Saleem.
17. Mst. Nazia Wd/O Muhammad Saleem,
All r/o: Shahbaz Plaza Liaquat Market Nawabshah,
18. Public at Large
---------------------------- opponents
APPLICATION U/S 218 OF
SUCCESSION ACT,1925.
The applicant named above humbly submits as under:1).

That late Muhammad son of Abdul Rasheed Rajput, r/o:

Shahbaz Plaza, Liaquat Market , Nawabshah, died on 22.10.2009,


for which death certificate is submitted herewith as annexure A.
2).

That said deceased at the time of his death left the applicant

and opponents No. 1 to 3 as his sole legal heirs. Applicant is son,

while opponents No. 1 and 2 are son and daughter respectively


while opponent No.3,
3).

is widow, of the said deceased.

That said deceased was Suni muslim and so are his legal heirs,

the applicant and opponents No.1 to 3.


4).

That said deceased at the time of his death left a vehicle

bearing registration No. ANR-093, Cultus VXR, Model 2007, which


was obtained by him by way of lease from United Bank Limited, Gul
Center, Hyderabad. Said deceased was regularly depositing the
lease money till his death viz. 22.10.2009,
P/2
P/2
and there after his son the applicant , hence till January, 2011, there
was no any outstanding of United Bank Limited, Gul Center,
Hyderabad against the leased vehicle, but there after mistakenly
said United Bank Limited took over the possession on the pretext of
non payment, but when the receipts were shown to them, they
asked that Muhammad Saleem may appear before them on which it
was disclosed to them about the death of Muhammad Saleem,
therefore, they refused to hand over the vehicle, until and unless
succession certificate / letter of administration may be handed over
to them, hence the present application has been filed. (Photostat
copies of documents of vehicle are submitted herewith as annexure
B
5).

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


6).

That to take the possession of the vehicle aforementioned

back form M/S United Bank Limited , Gul Center, Hyderabad, a


Letter of administration is required by the applicant and opponents
No. 1 to 3, hence this application.
7).

That no application has been made to any Court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in

force to the grant of the Letter of Administration or the validity


thereof if it were granted.
8).

That

the

applicant

has

fully

set

forth

the

securities/amount/debts in Para No.4 above, in respect of which


Letter of administration is applied for.

PRAYER
The applicant, therefore, prays that the Honourable
Court may be pleased to issue a Letter of administration
in his favour authorizing/ empowering him to get/ with
draw/ receive the vehicle bearing registration No. ANR093, Cultus, VXR, Model 2007, from M/S United Bank
Limited , Gul Center, Hyderabad.

Applicant
Advocate for Applicant
P/3
P/3
VERIFICATION.
I, Muhammad Waseem son of Muhammad Saleem
Rajput, adult, Muslim, r/o: Shahbaz Plaza, Liaquat Market
Nawabshah, do hereby verify on oath on this _________ day of
February, 2011 at Nawabshah, that whatever stated above is true
and correct to the best of my knowledge and belief.

Deponent
I know the deponent

Advocate

Documents filed
As Annexure "A" & B

Documents Relied upon.


1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant himself
2.
3.
Drafted by me in my office at Nawabshah, under the
instructions of the applicant.
Addresses of the parties are same as shown in the
cause title of the application.

(AMEER ALI
MAHESSAR)
Advocate for Applicant.
Nawabshah.
Dated :

IN THE COURT OF IIND. ADDITIONAL DISTRICT JUDGE, SHAHEED


BENAZIR ABAD.
Succession Application No.

OF 2010.

Ameer
-------------------------------Applicant
VERSUS
Mst. Zuhraan & Others
------------------------------ Opponents.
APPLICATION U/S 376 SUCCESSION ACT,1925.

It is prayed that this Honourable court may be pleased


to issue extended Succession Certificate in favour of applicant
authorizing/ empowering him to get/ receive the amount of
Rs.6,03,560/- from Sui Southern Gas Company Limited, requiring
Succession Certificate, vide letter No.REF:IR/HO/1.1-D/1656, dated:
30th December, 2010,

left by deceased Punhoon son of Bux Ali and

for disbursement thereof amongst all the legal heirs viz. applicant
and opponents No.1 to 3, according to their legal share on the
consideration of the following facts and grounds.

F A C T S.
Facts leading to the present application are that the
Honourable Court was pleased to issue Succession Certificate in
respect of amount of Rs.24,322.49, to be withdrawn from Habib
Bank Limited Sakrand Branch. However, the applicant was enquiring
other amounts left by the deceased and have come to know about
the aforesaid assets/ amount / articles of deceased Punhoon and
enquired from the concerned, on which
Certificate,

hence

this

application

they required Succession


for

extended

Succession

Certificate, in favour of the applicant on the following grounds :P/2

G R O U N D S.
1.

That all the legal formalities were complied with while issuing

succession Certificate dated: 31.05.2010, by this Honourable court


with regard to the legal heirs of late Punhoo son of Buxal Viz.

publication in newspaper, report from Mukhtiarkar and evidence of


the witnesses.
2.

That letter bearing No.REF:IR/HO/1.1-D/1656, dated: 30 th

December, 2010, issued by SSCG , requiring Succession Certificate


in respect of amount of Rs.4,03,560/-, as three installments of
compensation and Rs.2,00,000/- as Group insurance, in total
Rs.6,03,560/- is submitted herewith.
3.

That

Photostat

copy

of

Succession

Certificate

dated:

31.05.2010 is submitted herewith as the original was obtained by


concerned authorities after it was issued.
Applicant
Advocate for Applicant
V E R I F I C A T I O N.
I, Amir Channa son of Bux Ali Channa, adult, Muslim, r/o:
village Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District
Shaheed Benazir Abad, do hereby verify on oath on this _______ day
of February, 2011 at Nawabshah, that whatever stated above is true
and correct to the best of my knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


S.A. NO.

2010

Muhammad Yakoob @ Fahad Memon


-------------------------------Applicant
VERSUS
Mst. Husana Begum & Others
------------------------------ Opponents.

APPLICATION U/O 32 RULE 3 CPC


It is prayed that this Honourable Court may be pleased to
appoint opponent No.1, as guardian ad litem for minors opponents
No.2 to 4, for the purpose of obtaining Succession Certificate on the
consideration of the grounds mentioned in the accompanying affidavit.

APPLICANT.
NAWABSHAH.
DATED:

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


S.A. NO.

2010

Muhammad Yakoob @ Fahad Memon


-------------------------------Applicant
VERSUS
Mst. Husana Begum & Others
------------------------------ Opponents.

A F F I D A V I T.
I, Muhammad Yakoob Alias Fahad son of Muhammad Maroof
Memon, adult, Muslim, r/o: House No. 67, Sarfraz Colony, near Excise
Office, Nawabshah, do hereby state on oath as under:1.

That I am applicant and hence fully conversant with the facts of

the present application.


2.

That accompanying application U/O 32 Rule 3 CPC has been

filed by me, the contents where of are true and may be read as part of
this affidavit.
3.

That opponent No.1, is real mother of minors, and the minors

are under the care and custody of opponent No.1, and she has no
interest in the matter in controversy in the application adverse that of
minors and that she is a fit person to be so appointed.
4.
That Justice requires that my accompanying application may be
allowed.

5.
That I shall suffer serious loss if the accompanying application
is not allowed.
Whatever stated above is true and correct to the best of my
knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Letter of Administration No.

Aamir Khan Magsi

of 2011

-------------------------------Applicant
VERSUS

Mst. Shahjahan & Others


------------------------------ Opponents.

APPLICATION U/O 32 RULE 3 CPC

It is prayed

on behalf of the applicant that this

Honourable Court may be pleased to appoint opponent No.1, as


guardian ad litem for minor Opponent No.4, for the purpose of
obtaining Letter of Administration on the consideration of the grounds
mentioned in the accompanying affidavit.

ADVOCATE FOR APPLICANT.


NAWABSHAH.
DATED:

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Letter of Administration No.

of 2011

Aamir Khan Magsi


-------------------------------Applicant
VERSUS
Mst. Shahjahan & Others
------------------------------ Opponents.

A F F I D A V I T.
I, Aamir Khan son of Dost Muhammad Magsi, adult, Muslim,
r/o: Village Buxo Magsi, Taluka Sakrand, District Shaheed Benazir
Abad, Nawabshah, do hereby state on oath as under:-

1.

That I am applicant and hence fully conversant with the facts of

the present application.


2.

That accompanying application U/O 32 Rule 3 CP C has been

filed on my instructions, the contents where of are true and may be


read as part of this affidavit.
3.

That Opponent No.1, is real mother of minor, and the minor is

under the care and custody of opponent No.1, and she has no interest
in the matter in controversy in the application adverse that of minor
and that he is a fit person to be so appointed.
4.
That Justice requires that my accompanying application may be
allowed.
5.
That I shall suffer serious loss if the accompanying application
is not allowed.

Whatever stated above is true and correct to the best of my


knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR


ABAD
Letter of Administration

Application No.

of

2011.
Aamir Khan son of Dost Muhammad
Magsi, muslim, adult, r/o: village Buxo
Magsi, Taluka Sakrand, District
Shaheed Benazir Abad.
--------------------------Applicant.
Versus.
19. Mst. Shahjah Wd/O Dost Muhammad Magsi.
20. Aftab Ahmed so of Dost Muhammad Magsi.
21. Mst. Sindu D/O Dost Muhammad Magsi
22. Baby Sadaf D/O Dost Muhammad Magsi,
minor aged about 15 year, through her
mother and natural guardian, Mst.
Shahjahan, the opponent No.1,
23. Mst. Pathani W/O Ali Hassan Magsi
all r/o: village Buxo Magsi, Taluka
Sakrand, District Shaheed Benazir Abad.
24. Public at large
-----------------------Opponents.

APPLICATION U/S 218 OF


SUCCESSION ACT,1925.
The applicant named above humbly submits as under:1).

That late Dost Muhammad S/O Ali Hassan Magsi, r/o: village

Buxo Magsi, Taluka Sakrand, District Shaheed Benazir Abad, died on

10.04.2010, for which death certificate is submitted herewith as


annexure A.
P/2

2).

P/2
That said deceased at the time of his death left the applicant

and opponents No. 1 to 5 as his sole legal heirs. Applicant is son,


while opponents No. 1

is widow, the opponents No.2 son, 3 and 4

are daughters, opponent No.5, is mother of the said deceased.


3).

That said deceased was Suni muslim and so are his legal heirs,

the applicant and opponents No.1 to 5.


4).

That said deceased at the time of his death left gold,

mortgaged in National Bank of Pakistan, Mohni Bazar Branch,


Nawabshah, weighing 82.700 grams as gross weight which became
53-000 grams as net weight of the gold, amounting to Rs.74,000/for which he obtained loan, which are to be deposited, such
certificate / letter bearing No. MOHNI/HRN/10/, dated: 01.12.2010,
issued by NBP, Mohni Bazar Brnach, Nawabshah

is submitted

herewith as annexure B.
5).

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


6).

That to withdraw the gold aforesaid from the National Bank of

Pakistan, Mohni Bazar Nawabshah, a

Letter of administration is

required by the applicant and opponents No. 1 to 5, hence this


application.
7).

That no application has been made to any Court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in
force to the grant of the Letter of Administration or the validity
thereof if it were granted.

8).

That

the

applicant

has

fully

set

forth

the

securities/amount/debts in Para No.4 above, in respect of which


Letter of administration is applied for.
PRAYER
The applicant, therefore, prays that the Honourable
Court may be pleased to issue a Letter of administration
in his favour authorizing/ empowering him to get/ with
draw/ receive the gold aforesaid, from concerned Bank,
for disbursement thereof amongst all the legal heirs,
according to their legal shares, after deducting the
amount to be deposited against the loan of the gold.

Applicant
Advocate for Applicant
P/3
VERIFICATION.
I, Aamir Khan son of Dost Muhammad Magsi, adult,
Muslim, r/o: village Buxo Magsi, Taluka Sakrand, District Shaheed
Benazir Abad, do hereby verify on oath on this _________ day of
January, 2011 at Nawabshah, that whatever stated above is true and
correct to the best of my knowledge and belief.

Deponent
I know the deponent

Advocate

Documents filed
As Annexure "A" & "B".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant himself

4. Ghulam Murtaza son of Ali Nawaz Magsi.


5. Shahid Latif son of Noor Muhammad Magsi
Village Buxo Magsi, Taluka Sakrand,
District Shaheed Benazir Abad.

Drafted by me in my office at Nawabshah, under the


instructions of the applicant.
Addresses of the parties are same as shown in the
cause title of the application.

(AMEER ALI
MAHESSAR)
Advocate for Applicant.
Nawabshah.
Dated :

IN THE COURT OF THE DISTRICT


JUDGE, SHAHEED BENAZIR ABAD
Succession
Application No.
of 2011.

IN THE COURT OF 2ND


ADDITIONAL DISTRICT JUDGE,
SHAHEED BENAZIR ABAD.
Succession Application No.
OF 2010.

Gul Jahan
------------------------------Applicant.
VERSUS
Gul Rehman &
Others

-----------------------------Opponents.

STATEMENT.
I, with draw the above said
succession application as the same
was filed due to bonafide mistake
and I am to file application for
letter of administration, therefore
the documents attached may be
returned.

Nawabshah
Advocate for Applicant
Dated: 10-03-2010

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

Miss. Mehar Afshan & others

Public at Large

61

of 2008.

...Applicants

Versus
.. Opponents

: - STATEMENT - :

I, hereby produced Photostat copy of NIC of Abdul


Hameed father of deceased Mehar Afroze , as required by the
NADRA.

Advocate for Applicants


Nawabshah.
Dated:

-: R

P T :-

I have received an amount of Rs.52,839-00, being


opponent No.5, from applicant Mst. Yasmeen being my share in
the amount left by my father in Succession Application No. 1 of
2010.

(Ahsan Raza S/O Syed Hassan Raza)

-: R

P T :-

I have received an amount of Rs.52,839-00, being


opponent No.4, from applicant Mst. Yasmeen being my share in
the amount left by my father in Succession Application No. 1 of
2010.

(Shabbar Raza S/O Syed Hassan Raza)

IN THE COURT OF IIND ADDITONAL DISTRICT JUDGE,


SHAHEED BENAZIR ABAD.
Succession Application No.

20

OF 2009.

Mst. Rehana & another


-------------------------------Applicants.
VERSUS
Baby Amna & Others
------------------------------ Opponents.

: - STATEMENT - :

It is jointly prayed by both the parties by admitting the


claim of each other that the Honorable Court may be pleased to
issue two separate Succession Certificate , one in favour of the
applicants authorizing / empowering applicant NO.1, to withdraw the
amount the banks concerned of her as well as applicant No.2, for
their respective share viz. ___________, and an other Succession
Certificate in favour of opponents empowering / authorizing the
attorney of the opponents in respect of the share of the opponents
viz. ________________,

Applicant No.1 for


opponents.

Attorney of the

herself and on behalf of


her minor daughter.

Advocate for applicants


Opponents.

Advocate

for

IN THE COURT OF IIND. ADDITIONAL DISTRICT JUDGE, SHAHEED BENAZIR


ABAD.
Succession Application No.

OF 2010.

Ameer ----------- Versus ------------------- Mst. Zuhraan & Others


A F F I D A V I T.
I, Suleh W/O Bux Ali Channa, adult, muslim, r/o: village Haji Allah
Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed Benazir Abad,
do hereby state on oath as under:1.
That I am Opponent No.2 in the above matter and my son late
Punhoon Died on 10.02.2010 and at the time of death he was permanent
r/o: Village Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District
Shaheed Benazir Abad, and was a Sunni Muslim.

2.
That said deceased left an amount of Rs. 24322.49/- with Habib
Bank, Sakrand Branch, for which Succession Certificate dated
31.05.2010, however, later on enquiry it has come to know that
further amount of Rs.6,03,560/- is lying with SSGC Limited, who
required Succession Certificate for releasing thereof, for which
Succession Certificate is required.
3.
That said deceased died intestate and due and diligent search
has been made for a will but none is found out.
4.
That to withdraw the amount aforesaid from the concerned
department, a succession certificate is required by us.
5.
That I have no objection if the Honourable court may be pleased
to grant Succession Certificate in favour of applicant, authorizing/
empowering him to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from concerned
department for disbursement thereof amongst all the legal heirs
according to our legal share, in accordance with law.
Whatever stated above is true and correct to the best of my
knowledge and belief.

Deponent.

I know the Deponent.

Advocate.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2010.

Ameer
-------------------------------Applicant
VERSUS
Mst. Zhurran & Others
------------------------------ Opponents.

STATEMENT
Share of legal heirs are as under :
1. Mst. Zuhraan

Widow

25%

Rs.6080.62

2. Ameer

Brother .

39%

Rs.9458.75

3. Mst. Suleh

Mother

16.5%

Rs.4053.74

4. Mst. Haseena

Daughter

19.5%

Rs.4729.37

_____________________________

TOTAL

Rs.24322.49

---------------------------------------------

Advocate
Applicant
Nawabshah.
Dated:05.04.2010

for

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2010.

Ameer
-------------------------------Applicant
VERSUS
Mst. Zuhraan & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Haseena D/O Bux Ali Channa, adult, muslim, r/o: village
Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District
Shaheed Benazir Abad, do hereby state on oath as under:1.
That I am Opponent No.3 in the above matter and hence fully
conversant with the facts of the present application.
2.
That my brother
10-02-2010.

late Punhoon S/O Bux Ali Channa, died on

3.
That said deceased Punhoon was permanent r/o: Village Haji
Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad, and was a Sunni Muslim.
4.
That said deceased left applicant and us Opponents Nos. 1 to 3
his sole legal heirs.
5.
That said deceased left an amount of Rs. 24322.49/- with Habib
Bank, Sakrand Branch, for which Succession Certificate dated
31.05.2010, however, later on enquiry it has come to know that
further amount of Rs.6,03,560/- is lying with SSGC Limited, who
required Succession Certificate for releasing thereof, for which
Succession Certificate is required.
6.
That said deceased died intestate and due and diligent search
has been made for a will but none is found out.
7.
That to withdraw the amount aforesaid from the concerned
department , a succession certificate is required by us.
8.
That I have no objection if the Honourable court may be pleased
to grant Succession Certificate in favour of applicant, authorizing/
empowering him to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from concerned

department for disbursement thereof amongst all the legal heirs


according to our legal share, in accordance with law.
Whatever stated above is true and correct to the best of my
knowledge and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2010.

Ameer
-------------------------------Applicant
VERSUS
Mst. Zuhraan & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Zuhraan Wd/O Punhoon Channa, adult, muslim, r/o: village
Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District
Shaheed Benazir Abad, do hereby state on oath as under:1.
That I am Opponent No.1 in the above matter and hence fully
conversant with the facts of the present application.
2.
That my husband late Punhoon S/O Bux Ali Channa, died on
10-02-2010.
3.
That said deceased Punhoon was permanent r/o: Village Haji
Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad, and was a Sunni Muslim.
4.
That said deceased left applicant and us Opponents Nos. 1 to 3
his sole legal heirs.
5.
That said deceased left an amount of Rs. 24322.49/- with Habib
Bank, Sakrand Branch, for which Succession Certificate dated
31.05.2010, however, later on enquiry it has come to know that
further amount of Rs.6,03,560/- is lying with SSGC Limited, who
required Succession Certificate for releasing thereof, for which
Succession Certificate is required.
6.
That said deceased died intestate and due and diligent search
has been made for a will but none is found out.
7.
That to withdraw the amount aforesaid from the concerned
department , a succession certificate is required by us.
8.
That I have no objection if the Honourable court may be pleased
to grant Succession Certificate in favour of applicant, authorizing/
empowering him to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from concerned

department for disbursement thereof amongst all the legal heirs


according to our legal share, in accordance with law.
Whatever stated above is true and correct to the best of my
knowledge and belief.
Deponent.
I know the deponent.

Advocate

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2010.

Ameer
-------------------------------Applicant
VERSUS
Mst. Zuhraan & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Ameer Channa son of Bux Ali Channa, adult, muslim, r/o:
village Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District
Shaheed Benazir Abad, do hereby state on oath as under:1.

That I am applicant and hence fully conversant with the facts of

the present application.


2.

That my brother late Punhoon S/O Bux Ali Channa died on 10-

02-2010. I produce death certificate as Ex:__________.


3.

That said deceased Late Punhoon was permanent r/o village

Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah,


Shaheed Benazir Abad and was a Sunni Muslim.

District

4.

That said deceased left me and opponents Nos. 1 to 3 as his sole

legal heirs. I am brother, while opponents Nos.1 to 3, Widow, mother


and sister respectively of deceased Punhoon.
5.

That said deceased left an amount of Rs.24,322.49, with Habib

Bank Limited Sakrand Branch, at the time of his death.

I produce

Bank Balance Certificate as Ex. _____________.


6.

That said deceased died intestate and due and diligent search

has been made for a will but none is found out.


P/2

P/2
7.

That such heir ship certificate issued by the Mukhtiarkar

(Revenue), Nawabshah is submitted as Ex._________________.

8.

That to withdraw the amount aforesaid from the concerned

Bank a succession certificate is required by us.

9.

That no application has been made to any court so far and no

grant has been made of any certificate, probate or letter of


administration in respect of debts, securities and estate of the said
deceased and there is no any impediment under the provision of
Succession Act, 1925 or any other enactment for the time being
inforce to grant the succession certificate or the validity thereof if it
were granted.

10.

That I therefore, pray that Succession Certificate may pleased be

granted in my favour authorizing / empowering me to get /


withdraw / receive the amount aforesaid with interest to be accrued
up to the date of withdrawal from bank etc for disbursement thereof
amongst all the legal heirs according to our legal share, in accordance
with law.

Whatever stated above is true and correct to the best of my


knowledge and belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2010.

Ameer
-------------------------------Applicant
VERSUS
Mst. Zuhraan & Others
------------------------------ Opponents.
APPLICATION FOR VERIFICATION OF
THE LEGAL HEIRS OF DECEASED PUNHOON S/O BUX ALI
CHANNA
It is submitted that Punhoon S/O Bux Ali Channa, r/o: Village
Haji Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District
Shaheed Benazir Abad, died on 10-02-2010, leaving behind the
following legal heirs;
5.
6.
7.
8.

Ameer
Mst. Zuhrran
Mst. Suleh
Mst. Haseena

Brother.
Widow.
Mother
Sister

All muslims, adults, r/o: Village Bux Ali


Channa, Deh 39 Dad, Taluka Nawabshah,
District Shaheed Benazir Abad.
It is therefore, prayed that Mukhtiarkar (Revenue) Taluka
Nawabshah, may be directed to verify the legal heirs of deceased
PUnhoon S/O Bux Ali Channa, r/o: Village Haji Allah Dad Mari, Deh 39
Dad, Taluka Nawabshah, District Shaheed Benazir Abad.

Advocate
Applicant
Nawabshah.
Dated:05.04.2010

for

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2010.

Ameer
-------------------------------Applicant
VERSUS
Mst. Zuhraan & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Nazeer Ahmed son of Khan Muhammad, adult, muslim, r/o:
Village Imam Bux Mari, Taluka Nawabshah, District Shaheed Benazir
Abad, Nawabshah, do hereby state on oath as under:-

1.

That I know applicant and opponents Nos. 1 to 3.

2).

That deceased Punhoon S/O Bux Ali Channa was my relative

died on 10.02.2010, and left behind him his sole legal heirs the
applicant and Opponents No. 1 to 3.
3).

That said deceased Punhoon Channa was permanent resident of

Village Imam Bux Mari, Taluka Nawabshah, at the time of his death.
4).

That applicant is brother of the said deceased while Opponents

No. 1 to 3 are widow, mother and sister respectively.


5).

That said deceased at the time of his death left behind him an

amount of Rs.24322.49/- with Habib Bank Limited Sakrand Branch,


for which succession certificate is required to the applicant and
Opponents Nos. 1 to 3.
Whatever stated above is true and correct to the best of my knowledge
and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD


Succession

Application No.

of 2010.

Ameer Channa S/O Bux Ali Channa,


adult, muslim, r/o: Village Haji Allah
Dad Mari, Deh 39 Dad, Taluka
Nawabshah, District Shaheed Benazir
Abad.
--------------------------Applicant.
Versus.
25. Mst. Zuhraan Wd/O Punhoon Channa.
26. Mst. Suleh W/O Bux Ali Channa.
27. Mst. Hassena D/O Bux Ali Channa
All adults, muslims, r/o: Village Haji
Allah Dad Mari, Deh 39 Dad, Taluka
Nawabshah, District Shaheed Benazir
Abad.
28. Public at large
-----------------------Opponents.

APPLICATION U/S 370 & 372


SUCCESSION ACT,1925.
The applicant named above humbly submits as under:1).

That late Punhoon S/O Bux Ali Channa, r/o: Village Haji

Allah Dad Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed


Benazir Abad, died on 10.02.2010, for which death certificates is
submitted herewith as annexure A.
2).

That said deceased at the time of his death left the applicant

and opponents No. 1 to 3

as his sole legal heirs. Applicant is

brother, while opponents No. 1 to 3 , is widow, mother and Sister


respectively of the said deceased.
P/2
P/2
3).

That said deceased was Suni muslim and so are his legal heirs,

the applicant and opponents No.1 to 3, such Heir ship Certificate


issued by the Mukhtiarkar (Revenue) Nawabshah is submitted as
annexure B.
4).

That said deceased at the time of his death left an amount of

Rs.24322.49/- with Habib Bank Limited

Sakrand Branch, Such

certificate issued by Manger, is submitted herewith as annexure C.


5).

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


6).

That to withdraw the amount aforesaid from Bank, a

succession certificate is required by the applicant and opponents No.


1 to 3, hence this application.
7).

That no application has been made to any Court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in
force to the grant of the succession certificate or the validity thereof
if it were granted.
8).

That

the

applicant

has

fully

set

forth

the

securities/amount/debts in Para No.4 above, in respect of which


succession certificate is applied for.

PRAYER
The applicant, therefore, prays that the Honourable
court may be pleased to issue a Succession Certificate
in his favour authorizing/ empowering him to get/ with
draw/ receive the amount aforesaid with interest to be
accrued up to the date of withdrawal from concerned

Bank,

for disbursement thereof amongst all the legal

heirs, according to their legal shares.

Applicant
Advocate for Applicant
P/3

P/3
VERIFICATION.
I, Ameer S/O Bux Ali Channa, adult, muslim, r/o: Village
Imam Bux Mari, Deh 39 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad, do hereby verify on oath on this 05th day of April,
2010 at Nawabshah, that whatever stated above is true and correct
to the best of my knowledge and belief.

Deponent
I know the deponent
Advocate
Documents filed
As Annexure "A" to "C".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant herself
2. Mukhtiar Ali son of Rano Khan Channa.
3. Nazeer Ahmed S/O Khan Muhammad
Both r/o: Village Allah Dad Mari, Deh 39 Dad,
Taluka Nawabshah, District Shaheed Benazir Abad.
Drafted by me in my office at Nawabshah, under the
instructions of the applicant.

Addresses of the parties are same as shown in the


cause title of the application.

(AMEER ALI
MAHESSAR)
Advocate for Applicant.
Nawabshah.
Dated: 05.04.2010

IN THE COURT OF 2ND ADDITIONAL DISTRICT JUDGE, SHAHEED


BENAZIR ABAD.
Succession Application No.

OF 2010.

Gul Jahan
-------------------------------Applicant.
VERSUS
Gul Rehman & Others
------------------------------ Opponents.

STATEMENT.
I, with draw the above said succession application as the same was
filed due to bonafide mistake and I am to file application for letter of
administration, therefore the documents attached may be returned.

Nawabshah
Applicant
Dated: 10-03-2010

Advocate

for

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Letter of Administration Application No.

Gul Jahan

OF 2010.

-------------------------------Applicant.
VERSUS

Gul Rehman & Others


------------------------------ Opponents.

APPLICATION FOR VERIFICATION OF


THE LEGAL HEIRSOF DECEASED MANZOOR HUSSAIN S/O
GHULAM MUHAMMAD MAGSI.

It is submitted that Manzoor Hussain S/O Ghulam Muhammad


Magsi, r/o: village Ghulam Ali Magsi, Deh 29 Dad, Taluka
Nawabshah, District Shaheed Benazir Abad, died on 20-01-2008,
leaving behind the following legal heirs;
9. Gul Jahan
10.
Gul Rehman
11.
Mst. Rasheeda

son.
son.
Widow

All muslims, adults, r/o: Village Ghulam Ali


Magsi, Deh 29 Dad, Taluka Nawabshah,
District Shaheed Benazir Abad.
It is therefore, prayed that Mukhtiarkar (Revenue) Taluka
Nawabshah, may be directed to verify the legal heirs of deceased
Manzoor Hussain S/O Ghulam Muhammad Magsi, r/o: village Ghulam
Ali Magsi, Deh 29 Dad, Taluka Nawabshah, District Shaheed Benazir
Abad.

Advocate
Applicant
Nawabshah.
Dated:10.03.2010

for

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Letter of Administration Application No.

Gul Jahan

OF 2010.

-------------------------------Applicant.
VERSUS

Gul Rehman & Others


------------------------------ Opponents.

A F F I D A V I T.
I, Tarique Hussain son of Ghulam Muhammad Magsi, adult,
muslim, r/o: village Ghulam Alli Magsi, Deh 29 Dad, Taluka
Nawabshah , District Shaheed Benazir Abad, do hereby state on oath
as under:1.

That I know applicant and opponents No. 1 and 2.

2).
That deceased Manzoor Hussain Magsi was my close relative,
died on 20.01.2008, and left behind him his sole legal heirs the
applicant and opponent No.1 and 2.
3).
That said deceased Manzoor Hussain Magsi was permanent
resident of Village Ghulam Muhammad Magsi, Deh 29 Dad, Taluka
Nawabshah, District Shaheed Benazir Abad.
4).
That applicant is son of the said deceased while opponents NO.1
and 2 are son and widow respectively .
5).
That said deceased at the time of his death left behind him gold
ornaments in National Bank of Pakistan Mohni Bazaar Branch,
Nawabshah, for which Letter of Administration is required to the
applicant and opponents No.1 and 2.

6).

That prior to this no any application on the part of the applicant

and opponents No. 1 and 2 have been moved before any court or
authority , competent to issue or grant.
Whatever stated above is true and correct to the best of my
knowledge and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR


ABAD
Letter of Administration

Application No.

of

2010.
Gul Jahan S/O Manzoor Hussain , adult,
muslim, r/o: Village Ghulam Ali Magsi,
Deh 29 Dad, Taluka Nawabshah,
District Shaheed Benazir Abad.
--------------------------Applicant.
Versus.
29. Gul Rehman S/O Manzoor Hussain.
30. Mst. Rasheedan Wd/O Manzoor Hussain.
Both adults, muslims, r/o: Village Ghulam Ali Magsi,
Deh 29 Dad, Taluka Nawabshah,
District Shaheed Benazir Abad.
31. Public at Large.
-----------------------Opponents.

APPLICATION U/S 218 OF


SUCCESSION ACT,1925.

The applicant named above humbly submits as under:1).

That late Manzoor Hussain son of Ghulam Muhammad

Magsi, died on 20.01.2008, for which death certificate is submitted


herewith as annexure A.
2).

That said deceased Manzoor Hussain was permanent

resident

of

Village

Ghulam

Ali

Magsi,

Deh

29

Dad,

Taluka

Nawabshah, District Shaheed Benazir Abad.


3).

That said deceased at the time of his death left the applicant

and opponents No. 1 & 2

as his sole legal heirs. Applicant and

opponent No.1, are sons and opponent No.2 is widow of said


deceased.

4).

That said deceased was Sunni muslim and so are his legal

heirs, the applicant and opponents No.1 & 2.


P/2
P/2
5).

That said deceased at the time of his death left gold,

mortgage in National Bank of Pakistan, Mohni Bazar Branch,


Nawabshah, weighing 173 grams as gross weight which became 100
grams as net weight of the gold, amounting to Rs.70,000/- for which
he obtained loan, which has been deposited and such clearance
certificate issued by Manger, NBP, Mohni Bazar, Nawabshah, is
submitted herewith as annexure B & C.
6).

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


7).

That to withdraw the gold aforesaid from the National Bank of

Pakistan,

Limited

Mohni

Bazar

Nawabshah,

Letter

of

administration is required by the applicant and opponents No. 1 & 2,


hence this application.
8).

That no application has been made to any Court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in
force to the grant of the succession certificate or the validity thereof
if it were granted.
9).

That

the

applicant

has

fully

set

forth

the

securities/amount/debts in Para No.5 above, in respect of which


Letter of administration is applied for.
PRAYER
The applicant, therefore, prays that the Honourable
Court may be pleased to issue a Letter of administration
in his favour authorizing/ empowering him to get/ with
draw/ receive the gold aforesaid, from concerned Bank,

for disbursement thereof amongst all the legal heirs,


according to their legal shares.

Applicant
Advocate for Applicant
P/3

P/3
VERIFICATION.
I, Gul Jahan S/O Manzoor Hussain Magsi, adult, muslim,
r/o: village Ghulam Muhammad Magsi, Taluka Nawabshah, District
Shaheed Benazir Abad, do hereby verify on oath on this 10th day of
March, 2010 at Nawabshah, that whatever stated above is true and
correct to the best of my knowledge and belief.

Deponent
I know the deponent

Advocate

Documents filed
As Annexure "A" to "C".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant himself
6. Tarique Hussain S/O Ghulam Muhammad Magsi.
7. Fakir Muhammad S/O Haji Mir Muhammad Magsi

adults, muslims, r/o: Village Ghulam Muhammad,


Deh 29 Dad, Taluka Nawabshah, District Shaheed
Benazir Abad.

Drafted by me in my office at Nawabshah, under the


instructions of the applicant.
Addresses of the parties are same as shown in the
cause title of the application.

(AMEER ALI
MAHESSAR)
Advocate for Applicant.
Nawabshah.
Dated : 10.03.2010

IN THE COURT OF IIND ADDITONAL DISTRICT JUDGE,


SHAHEED BENAZIR ABAD.
Succession Application No.

20

OF 2009.

Mst. Rehana & another


-------------------------------Applicants.
VERSUS
Baby Amna & Others

------------------------------ Opponents.

REPLECATION TO OBJECTIONS FILED


ON BEHALF OF OPPONENTS No.3 ,6 to 11 .
I, Rehana Arshad Wd/O Late Arshad Mehmood Awan,
adult, muslim, r/o: Peela Camp No.1, Line-par, UC No.08,
Nawabshah town, do hereby state on oath as under :1).

That I am applicant No.1, in the above matter and hence fully

conversant with the facts of the same.


2).

That I entered into marriage with late Arshad Mehmood on

25.07.2000, copy of Nikahnama is submitted herewith as annexure


"A".
3).

That from this wedlock I gave birth to a Baby namely Mah

Noor D/O Arshad Mehmood on 10.11.2001, such certificate issued by


Nazim Union Council No.8, Nawabshah is submitted herewith as
annexure "B".
4).

That after the death of my late husband, I applied for special

leave for observing Iddat from Executive District Officer, Education ,

District Shaheed Benazir Abad, such order granting 130 days leave
is submitted herewith as annexure "C".
5).

That my baby Mah Noor D/O Late Arshad Mehmood has been

receiving education in Govt. Girls Model Primary School Line Par,


Nawabshah, such certificate issued by Head Mistress is submitted
herewith as annexure "D".
P/2

P/2
6).

That Form "B" obtained from NADRA , showing Baby Mah Noor

D/O Late Arshad Mehmood Awan is submitted herewith as annexure


"E".
7).

That at the time of death of late Arshad Mehmood opponent

No.1 Baby Amna, who was studying in 08th class was residing with
me but after death of late Arshad Mehmood Awan, opponent No.3
took her with him.
8).

That neither my late husband pronounced divorce to me nor

issued any "Talaq Nama" as alleged dated: 04.01.2006, on behalf


opponents No. 3, 6 to 11, which is creative of mind of the opponents
in collusion with Fida-ur-Rehman nothing but to usurp the valuable
rights of me and my daughter Baby Mah Noor with malafide
intention and for ulterior motive and in this regard they had also
illegally occupied the property of my late husband and the
documents in respect of that property. The witnesses shown by the
respondents to be the alleged witnesses of the Talaq Nama are setup persons of the opponents to defraud me and my daughter to
deprive of our valuable rights. It is further submitted that neither
Haq Mahar in the life time of my late husband was given to me nor
any divorce was taken place. It is strange that the alleged Talaq
Nama which is other wise false is dated: 04.01.2006 and the date of
birth of my daughter Baby Mah Noor is 10.11.2001 and the
Nikahnama is dated: 25.07.2000, therefore, the contention on behalf
of the opponents is itself contradictory form which the malafide
intention on their part is reflecting. It is also submitted that I and my

daughter baby Mah Noor are very much entitled to obtain our legal
rights by inheriting whatever the property left by my late husband
according to our legal share, but opponent No.3 and Fida-urRehman , who are very cunning and shrewd persons have been
trying to deprive us from our valuable rights and have even made a
lot of fraud in respect of property of my late husband. It is further
submitted that the cheque and receipt of Courier service has also
been managed as neither I had been given the cheque nor it was
enchased at all.
9).

That my husband was business man having movable and

immoveable properties in his name in Nawabshah and other cities


and he also to get his brother in law namely Fida-ur-Rehman,
employed in Askari Bank limited Nawabshah, deposited Rs.65/70
Lacks , in his account, but said Fida ur- Rehman in collusion and
connivance of respondent No.3 by playing fraud did not show the
amount of the deceased to usurp the same.

P/3

P/3
10). That after the death of my late husband I went into shock and
taking the undue advantage of the same opponents No. 3 to 11 in
collusion with Fida-ur-Rehman took all the documents of the property
and record of bank deposit and other valuables with them and also
driven me out from the house, that was a reason why, I performed
my Iddat in the house of my parents.
11).

That I also got notices issued to the Manager / M/S National

Bank of Pakistan Mohni Bazaar Branch Nawabshah and M/S Bank AlFlah in which my late husband was running the accounts, but they
refused to provide such information subject to orders from the Court
of law, because of influence of Fida-ur-Rehman.
12).

That the malafide on the part of that Fida-ur-Rehman to whom

my late husband got employed in Bank Askari can be judged that he


got himself appointed the attorney of other opponents and has filed

the objections on his part which is nothing but creative of mind of


him to usurp the valuable rights of the original legal heirs of the
deceased.
13).

That I along with my daughter being the legally wedded wife

and daughter of late Arshad Mehmood Awan respectively are


entitled to get our due share in accordance with law from the
properties of deceased left by him at the time of his death.
Whatever stated above is true and correct to the best of
my knowledge and belief.

Deponent.
I know the deponent.

Advocate.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others
------------------------------ Opponents.

STATEMENT.
I have no objection if the Honourable Court may be
pleased to appoint me as guardian ad litim for the opponent No.6, in
the above matter, as I am ready for the same.

Opponent No.1.

Advocate for Opponents No.1 to 6.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Ahsan Raza S/O Late Hassan Raza, muslim, adult, r/o:
House # 5, Officers Colony, Habib Sugar Mills Limited Nawabshah, do
hereby state on oath as under:1.
That I am Opponent No.5 in the above matter and hence fully
conversant with the facts of the present application.
2.
That my father late Hassan Raza Son of Ghulam Imam died on
11-10-2009.
3.
That said deceased Late Hassan Raza was permanent r/o:
House # 5, Officers Colony, Habib Sugar Mills Limited Nawabshah and
was a Shia Muslim.
4.
That said deceased left applicant and us Opponents Nos. 1 to 6
his sole legal heirs.
5.
That said deceased left an amount of Rs.7775/- with Bank Al
Habib Limited Nawabshah Branch and an amount of Rs.3,54, 749
with Habib Sugar Mills Limited Nawabshah at the time of his death.
6.
That said deceased died intestate and due and diligent search
has been made for a will but none is found out.
7.
That to withdraw the amount aforesaid from the concerned
Bank and Habib Sugar Mills Limited Nawabshah, a succession
certificate is required by us.
8.
That I have no objection if the Honourable court may be pleased
to grant Succession Certificate in favour of applicant, authorizing/
empowering her to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from bank and
Habib Sugar Mills Limited Nawabshah etc for disbursement thereof

amongst all the legal heirs according to our legal share, in accordance
with law.
Whatever stated above is true and correct to the best of my
knowledge and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Ali Asghar son of Hassan Imam, adult, muslim, r/o: Camp
No.2, Nawabshah, do hereby state on oath as under:1.

That I know applicant and opponents Nos. 1 to 6.

2).

That deceased Syed Hassan Raza

was my relative died on

11.10.2009, at left behind him his sole legal heirs the applicant and
Opponents No. 1 to 6.
3).

That said deceased Syed Hassan Raza was permanent resident

of Officers Colony, Habib Sugar Mills Limited Nawabshah,

&

was

serving as Senior Electrician , in Habib Sugar Mills Limited


Nawabshah, at the time of his death.
4).

That applicant is widow of the said deceased while Opponents

No. 1 to 6 are sons of said deceased.


5).

That said deceased at the time of his death left behind him an

amount of Rs.7775/- with Bank Al Habib Limited Nawabshah Branch


and an amount of Rs.3,54,749/-

with Habib Sugar Mills Limited

Nawabshah, for which succession certificate is required to the


applicant and Opponents Nos. 1 to 6.

Whatever stated above is true and correct to the best of my knowledge


and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others
------------------------------ Opponents.

STATEMENT
Share of legal heirs are as under :
12.

Mst. Yasmeen Raza

Widow

Rs.45,290-00
13.

Aamir Raza

son.

Rs.52839-00
14.

Farukh Raza

son

Rs.52839-00
15.

Mubashar Raza

son

Rs.52839-00

16.

Shabbar Raza

son

Rs.52839-00

17.

Ahsan Raza

son

Rs.52839-00
18.

Ali Raza

son ( Minor)

Rs.52839-00
_____________________________

TOTAL

Rs.3,62,324-00

---------------------------------------------

Advocate
Applicant
Nawabshah.

for

Dated:01.01.2010

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others
------------------------------ Opponents.

APPLICATION U/R 14 OF
SINDH CIVIL COURT RULES.

It is prayed on behalf of the applicant that this


Honourable court may be pleased to treat the above matter as
urgent one and take the same up for the purpose of admission as
the same requires urgency on the consideration of the grounds
mentioned in the accompanying affidavit.

Advocate for applicant.


Nawabshah.
Dated: 01.01.2010

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Yasmeen Raza Wd/O Hassan Raza Syed, adult, muslim, r/o:
House No. 5, Officer Colony, Habib Sugar Mills Limited, Nawabshah,
do hereby state on oath as under:1.

That I am applicant and hence fully conversant with the facts

of the present application.


2.

That accompanying application U/R 14 of Sindh Civil Court

Rules has been drafted under my instruction and the contents


whereof to avoid repetition be treated true and correct.
3).

That to withdraw the amount mentioned in para No.5 of

Successions Application and to approach Sindh Worker Welfare


Board, for the dues of the said deceased a Succession Certificate is
required in limited time, hence this application.
4).

That I shall suffer serious loss and injury if my accompanying

application is not allowed.


Whatever stated above is true and correct to the best of my
knowledge and belief.

Deponent.
I know the deponent.

Advocate.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others
------------------------------ Opponents.

APPLICATION FOR VERIFICATION OF


THE LEGAL HEIRSOF DECEASED HASSAN RAZA SON OF
GHULAM IMAM SYED
It is submitted that Hassan Raza son of Ghulam Imam, Syed
r/o: House No.5, Officers colony, Habib Sugar Mills, Limited
Nawabshah, died on 11-10-2009, leaving behind the following legal
heirs;
19.
20.
21.
22.
23.
24.
25.

Mst. Yasmeen Raza


Aamir Raza
Farukh Raza
Mubashar Raza
Shabbar Raza
Ahsan Raza
Ali Raza

Widow
son.
son
son
son
son

son
( Minor)

All muslims, adults, except No.8, who is


minor aged about 13 years, R/O: H # 5,
Officers Colony, Habib Sugar Mills Limited,
Nawabshah.
It is therefore, prayed that Mukhtiarkar (Revenue) Taluka
Nawabshah, may be directed to verify the legal heirs of deceased
Hassan Raza son of Ghulam Imam Syed, r/o: House NO.5, Officers
Colony, Habib Sugar Mills Limited Nawabshah.
Advocate
Applicant
Nawabshah.
Dated:01.01.2010

for

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.

APPLICATION U/O 32 RULE 3 CPC

It is prayed

on behalf of the applicant that this

Honourable Court may be pleased to appoint opponent No.1, as


guardian ad litem for minor Opponent No.6, for the purpose of
obtaining Succession Certificate on the consideration of the grounds
mentioned in the accompanying affidavit.

NAWABSHAH.
DATED: 01-01-2010

ADVOCATE FOR APPLICANT.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Yasmeen
-------------------------------Applicant
VERSUS
Aamir Raza & Others

------------------------------ Opponents.

A F F I D A V I T.
I, Yasmeen Raza Wd/O Hassan Raza Syed, adult, muslim, r/o:
House No. 5, Officer Colony, Habib Sugar Mills Limited, Nawabshah,
do hereby state on oath as under:1.

That I am applicant and hence fully conversant with the facts of

the present application.


2.

That accompanying application U/O 32 Rule 3 CP C has been

filed on my instructions, the contents where of are true and may be


read as part of this affidavit.
3.

That I am real mother of minor, and proposed guardian is real

brother of opponent NO.6, who under the care and custody of


opponent No.1, and he has no interest in the matter in controversy in
the application adverse that of minor and that he is a fit person to be
so appointed.
4.
That Justice requires that my accompanying application may be
allowed.
5.
That I shall suffer serious loss if the accompanying application
is not allowed.

Whatever stated above is true and correct to the best of my


knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD


Succession

Application No.

of 2009.

Mst. Yasmeen Raza Wd/O Hassan Raza


Syed, adult, muslim, r/o: House # F-5,
Officer Colony, Habib Sugar Mills
Colony, Nawabshah.
--------------------------Applicants.
Versus.
32. Aamir Raza son of Hassan Raza, adult, muslim.
33. Farukh Raza son of Hassan Raza, adult, muslim.
34. Mubashar Raza Son of Hassan Raza adult, muslim.
35. Shabbar Raza son of Hassan Raza , adult, muslim.
36. Ahsan Raza son of Hassan Raza, adult, muslim.
37. Ali Raza son of Hassan Raza, minor,
aged about 13 years, through his next
friend and real brother Aamir Raza,
Opponent No.1, all r/o: House # F-5,
Officer Colony, Habib Sugar Mills
Limited, Nawabshah.
38. Public at large
-----------------------Opponents.

APPLICATION U/S 370 & 372


SUCCESSION ACT,1925.
The applicant named above humbly submits as under:1).

That late Hassan Raza son of Ghulam Imam, Syed died

on 11.10.2009, for which death certificate is submitted herewith as


annexure A.
2).

That said deceased Syed Hassan Raza was permanent

resident of House No.F-5, Mohalla Habib Sugar Mills Officers, Colony,


Nawabshah, Taluka Nawabshah, District Shaheed Benazir Abad and

was serving as Senior Electrician in Habib Sugar Mills Limited


Nawabshah.
P/2

3).

P/2
That said deceased at the time of his death left the applicant

and opponents No. 1 to 6 as his sole legal heirs. Applicant is widow,


while opponents No. 1 to 6 are sons of the said deceased.
4).

That said deceased was Shia muslim and so are his legal heirs,

the applicant and opponents No.1 to 6.


5).

That said deceased at the time of his death left an amount of

Rs.7,775/- with Bank Al Habib Limited Nawabshah Branch, Such


certificate issued by Manger, is submitted herewith as annexure B,
and an amount of Rs.3,54, 749-00 with Habib Sugar Mills Limited
Nawabshah, such Certificate dated: 30.12.2009, issued by (General
Manger),Finance and Accounts Nawabshah, is submitted herewith as
annexure "C".
6).

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


7).

That to withdraw the amount aforesaid from the Bank Al

Habib Limited Nawabshah Branch and from Habib

Sugar Mills

Limited Nawabshah, a succession certificate is required by the


applicant and opponents No. 1 to 6, hence this application.
8).

That no application has been made to any Court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in
force to the grant of the succession certificate or the validity thereof
if it were granted.
9).

That

the

applicant

has

fully

set

forth

the

securities/amount/debts in Para No.5 above, in respect of which


succession certificate is applied for.

PRAYER
The applicant, therefore, prays that the Honourable
court may be pleased to issue a Succession Certificate
in her favour authorizing/ empowering her to get/ with
draw/ receive the amount aforesaid with interest to be
accrued up to the date of withdrawal from concerned
Bank and institution, for disbursement thereof amongst
all the legal heirs, according to their legal shares.

Applicant
Advocate for Applicant
P/3
VERIFICATION.
I, Yasmeen Raza Wd/O Hassan Raza Syed, adult, muslim,
r/o: House # 5, Officer Colony, Habib Sugar Mills Limited,
Nawabshah, do hereby verify on oath on this ________day of January,
2010 at Nawabshah, that whatever stated above is true and correct
to the best of my knowledge and belief.

Deponent
I know the deponent
Advocate
Documents filed
As Annexure "A" to "C".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST OF WITNESSES:
1. Applicant herself
2. Ali Asghar son of Hassan Imam
3. Hussain Ali son of Ali Asghar
Both adults, muslim, r/o: Habib Sugar Mills Colony,
Nawabshah.

Drafted by me in my office at Nawabshah, under the


instructions of the applicant.
Addresses of the parties are same as shown in the
cause title of the application.

(AMEER ALI
MAHESSAR)
Advocate for Applicant.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

20

OF 2009.

Mst. Rehana & another


-------------------------------Applicants.
VERSUS
Baby Amna & Others
------------------------------ Opponents.

STATEMENT

I, hereby produced second address of Mst. Alam Ara, as


provided by applicant No.1, as under:-

House No.H-29, near Aqab Central Jail,


Pir Illahi Bux Colony & Ghosia Masjid,
Karachi No.5, District

Advocate for applicant


Nawabshah.
Dated:

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

Mst. Abida

Ghafoor & Others

OF 2009.

-------------------------------Applicant
VERSUS
------------------------------ Opponents.

A F F I D A V I T.
I, Sharifan W/O Ghafoor Sial, muslim, adult, r/o: village
Salahuddin Dahri, Taluka Sakrand, District Shaheed Benazir Abad,
do hereby state on oath as under:1.
That I am Opponent No.2 in the above matter and hence fully
conversant with the facts of the present application.
2.
That my son late Shahbaz Khan son of Ghafoor Sial died on 0403-2009.
3.
That said deceased Late Shahbaz was permanent r/o village
Salahuddin Dahri, Taluka Sakrand, District Shaheed Benazir Abad
and was a Sunni Muslim.
4.
That said deceased left applicant and us Opponents Nos. 1 to 6
his sole legal heirs.
5.
That said deceased left an amount of Rs.1,00,000 and profit
there on Rs.30,630-14, Fixed Deposit of MPDC No.001977 and /- at
the time of his death.
6.
That said deceased died intestate and due and diligent search
has been made for a will but none is found out.
7.
That to withdraw the amount aforesaid from the concerned
Bank a succession certificate is required by us.
8.
That I have no objection if the Honourable court may be pleased
to grant Succession Certificate in favour of applicant, authorizing /
empowering her to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from bank etc for
disbursement thereof amongst all the legal heirs according to our legal
share, in accordance with law.

Whatever stated above is true and correct to the best of my


knowledge and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

Mst. Abida

Ghafoor & Others

OF 2009.

-------------------------------Applicant
VERSUS
------------------------------ Opponents.

A F F I D A V I T.
I, Ghafoor son of Ismail Sial, muslim, adult, r/o: village
Salahuddin Dahri, Taluka Sakrand, District Shaheed Benazir Abad,
do hereby state on oath as under:1.
That I am Opponent No.1 in the above matter and proposed
Guardian of Opponents No. 3 to 6 and also hence fully conversant
with the facts of the present application.
2.
That my son late Shahbaz Khan son of Ghafoor Sial died on 0403-2009.
3.
That said deceased Late Shahbaz was permanent r/o village
Salahuddin Dahri, Taluka Sakrand, District Shaheed Benazir Abad
and was a Sunni Muslim.
4.
That said deceased left applicant and us Opponents Nos. 1 to 6
his sole legal heirs.
5.
That said deceased left an amount of Rs.1,00,000 and profit
there on Rs.30,630-14, Fixed Deposit of MPDC No.001977 and /- at
the time of his death.
6.
That said deceased died intestate and due and diligent search
has been made for a will but none is found out.
7.
That to withdraw the amount aforesaid from the concerned
Bank a succession certificate is required by us.
8.
That I have no objection if the Honourable court may be pleased
to grant Succession Certificate in favour of applicant, authorizing /
empowering her to get / withdraw / receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from bank etc for
disbursement thereof amongst all the legal heirs according to our legal
share, in accordance with law.

Whatever stated above is true and correct to the best of my


knowledge and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Mst. Abida
-------------------------------Applicant

Ghafoor & Others

VERSUS
------------------------------ Opponents.

A F F I D A V I T.

I, Abida Wd/O Shahbaz Khan Sial, muslim, adult, r/o: village


Salahuddin Dahri, Taluka Sakrand, District Shaheed Benazir Abad,
do hereby state on oath as under:1.

That I am applicant and hence fully conversant with the facts of

the present application.


2.

That my husband late Shahbaz Khan son of Ghafoor Sial died

on 04-03-2009. I produce death certificate as Ex:__________.


3.

That said deceased Late Shahbaz was permanent r/o village

Salahuddin Dahri, Taluka Sakrand,

District Shaheed Benazir Abad

and was a Sunni Muslim.


4.

That said deceased left me and opponents Nos. 1 to 6 as his sole

legal heirs. I am widow, while opponent No.2 is father and Opponent


No.3 is mother of deceased Shahbaz; Opponents Nos. 3, 5 and 7 are
sons and opponent No.4 daughter of deceased Shahbaz.

5.

That said deceased left an amount of Rs.1,00,000 and profit

there on Rs.30,630-14, Fixed Deposit of MPDC No.001977 and /- at


the time of his death.

I produce Bank Balance Certificate as Ex.

_____________.
6.

That said deceased died intestate and due and diligent search

has been made for a will but none is found out.


P/2

P/2
7.

That to withdraw the amount aforesaid from the concerned

Bank a succession certificate is required by us.

8.

That no application has been made to any court so far and no

grant has been made of any certificate, probate or letter of


administration in respect of debts, securities and estate of the said
deceased and there is no any impediment under the provision of
Succession Act, 1925 or any other enactment for the time being
inforce to grant the succession certificate or the validity thereof if it
were granted.

9.

That I therefore, pray that Succession Certificate may pleased be

granted in my favour authorizing / empowering me to get /


withdraw / receive the amount aforesaid with interest to be accrued
up to the date of withdrawal from bank etc for disbursement thereof
amongst all the legal heirs according to our legal share, in accordance
with law.

Whatever stated above is true and correct to the best of my


knowledge and belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

Imam Zadi & Others

OF 2009.

-------------------------------Applicants

VERSUS
Public at Large

------------------------------ Opponents.

A F F I D A V I T.
I, Abdul Jabbar son of Waryam Khan Pahi, adult, muslim, r/o:
Village Malook Khan Pahi, Taluka Sakrand, District Shaheed Benazir
Abad, do hereby state on oath as under:1.

That I know applicants.

2).
That deceased Muhammad Rahim was my cousin died on
14.01.2009, at left behind him his sole legal heirs the applicants No. 1
to 6.
3).
That said deceased Muhammad Rahim was permanent resident
of Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad & was serving as dispenser, in Health Department, at
the time of his death.
4).
That applicant No.1 is widow of the said deceased while
applicant No. 2 is mother and applicants No.3 to 6 are son and
daughters respectively.
5).
That said deceased at the time of his death left behind him an
amount of Rs.8500/- in National Bank of Pakistan, Engineering
University Branch Nawabshah, for which succession certificate is
required to the applicants.
6).
That prior to this no any application on the part of the
applicants have been moved before any court or authority , competent
to issue or grant.

Whatever stated above is true and correct to the best of my


knowledge and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Imam Zadi & Others


-------------------------------Applicants

Public at Large

VERSUS
------------------------------ Opponents.

A F F I D A V I T.
I, Abdul Sattar son of Muhammad Malook Pahi, adult, muslim,
r/o: Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad, do hereby state on oath as under:1.

That I know applicants.

2).
That deceased Muhammad Rahim was my maternal nephew
died on 14.01.2009, at left behind him his sole legal heirs the
applicants No. 1 to 6.
3).
That said deceased Muhammad Rahim was permanent resident
of Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad & was serving as dispenser, in Health Department, at
the time of his death.
4).
That applicant No.1 is widow of the said deceased while
applicant No. 2 is mother and applicants No.3 to 6 are son and
daughters respectively.
5).
That said deceased at the time of his death left behind him an
amount of Rs.8500/- in National Bank of Pakistan, Engineering
University Branch Nawabshah, for which succession certificate is
required to the applicants.
6).
That prior to this no any application on the part of the
applicants have been moved before any court or authority , competent
to issue or grant.

Whatever stated above is true and correct to the best of my


knowledge and belief.

I know the deponent.

Advocate

Deponent.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Imam Zadi & Others


-------------------------------Applicants
VERSUS
Public at Large

------------------------------ Opponents.

APPLICATION U/O 32 RULE 3 (2) CPC

It is prayed

on behalf of the applicant No.1, that this

Honourable Court may be pleased to appoint her as guardian ad litem


for minors applicants (1) Abdul Rehman, (2) Mst. Shumaila, (3) Mst.
Aneela and (4) Mst. Fiza for the purpose of obtaining Succession
Certificate on the consideration of the grounds mentioned in the
accompanying affidavit.

NAWABSHAH.
DATED:

-07-2009

ADVOCATE FOR APPLICANTS.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.
Imam Zadi & Others

OF 2009.

-------------------------------Applicants

VERSUS
Public at Large
------------------------------ Opponents.

A F F I D A V I T.
I, Imam Zadi Wd/O Muhammad Rahim Pahi, adult, muslim,
r/o: Village Malook Khan Pahi, Taluka Sakrand, District Shaheed
Benazir Abad, do hereby state on oath as under:1.
That I am applicant and hence fully conversant with the facts of
the present application.
2.
That accompanying application U/O 32 Rule 3 (2) CP C has
been filed on my instructions, the contents where of are true and may
be read as part of this affidavit.

3.
That I am real mother of minors, applicants Nos. 3 to 6 I
have no any interest in the matters in controversy in the
application adverse that of minors and that I am a fit person to
be so appointed.
4.
That Justice requires that my accompanying application may be
allowed.
5.
That I shall suffer serious loss if the accompanying application
is not allowed.
Whatever stated above is true and correct to the best of my
knowledge and belief.

Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD


Succession

Application No.

1. Mst.
Imam
Zadi
Muhammad Rahim Pahi.

of 2009.

Wd/O

2. Mst. Sami W/O Abdul Hakeem ,


mother of late Muhammad Rahim
Pahi.
3. Abdul Rehman son of Late
Muhammad Rahim Pahi, aged
about 09 years.
4. Mst.
Shumaila
D/O
Late
Muhammad Rahim Pahi, aged
about 11 years.
5. Mst. Aneela D/O Late Muhammad
Rahim Pahi, aged about
06
years.
6. Mst. Fiza D/O Late Muhammad
Rhaim Pahi, aged about 03
years.
No. 1 and 2 , adults, muslims,
applicants No. 3 to 6 , minors
through their mother and next
friend

guardian

ad

litm

application No.1, all r/o: Village


Malook

Pahi,

Taluka

Sakrand,

District Shaheed Benazir Abad.


--------------------------Applicants.
Versus.
Public at large
-----------------------Opponents.
APPLICATION U/S 370 & 372
SUCCESSION ACT,1925.

The applicants named above humbly submit as under:1).

That late Muhammad Rahim son of Abdul Hakeem Pahi died on

14.01.2009, for which death certificate is submitted herewith as


annexure A.
P/2
P/2
2).

That said deceased Muhammad Rahim was permanent

resident of Village Malook Pahi, Taluka Sakrand, District Shaheed


Benazir Abad and was serving as Dispenser in Health Department,
therefore, heir ship certificate was required to be produced there at
hence the same was applied before Mukhtiarkar (Revenue) Sakrand
and ultimately same was issued on 12.02.2009, Photostat copy of
which is hereby submitted as annexure B.
3).

That said deceased at the time of his death left the applicants

as his sole legal heirs. Applicant No.1 is widow, application No.2 is


mother while applicant No.3 to 6 are son and daughters respectively
of the said deceased.
4).

That said deceased was Sunni muslim and so are his legal

heirs, the applicants.


5).

That said deceased at the time of his death left an amount of

Rs.8,500/- with National Bank of Pakistan, Engineering University


Branch (293), Nawabshah. Such certificate issued by Manger dated:
28.07.2009, is submitted herewith as annexure C.
6).

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


7).

That to withdraw the amount aforesaid from the concerned

Bank, a succession certificate is required by the applicants, hence


this application.
8).

That no application has been made to any court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in

force to grant of the succession certificate or the validity thereof if it


were granted.
9).

That

the

applicants

have

fully

set

forth

the

securities/amount/debts in Para No.5 above, in respect of which


succession certificate is applied for.
PRAYER
The applicants, therefore, pray that the Honourable
court may be pleased to issue a Succession Certificate
in their favour authorizing/ empowering applicant No.1,
Mst. Imam Zadi Wd/O late Muhammad Rahim Pahi to
get/ with draw/ receive the
P/3
P/3
amount aforesaid with interest to be accrued up to the
date

of

withdrawal

disbursement

thereof

from

concerned

amongst

all

Bank,

the

for

applicants

according to their legal shares.

Applicant No.2.
No.1

applicant
for herself and for minors,
the applicants No. 3 to 6.

Advocate for Applicants


VERIFICATION.
I, Imam Zadi Wd/O Late Muhammad Rahim Pahi, adult,
muslim, r/o: Village Malook Khan Pahi, Taluka Sakrand, District
Shaheed Benazir Abad, do hereby verify on oath on this ________day
of July, 2009 at Nawabshah, that whatever stated above is true and
correct to the best of my knowledge and belief.

Deponent
I know the deponent
Advocate

Documents filed
As Annexure "A" to "C".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
LIST
1.
2.
3.

OF WITNESSES:
Applicant themselves.
Abdul Sattar son of Muhammad Malook Pahi
Abdul Jabbar son of Waryam Khan Pahi
All adults, muslim, r/o: Village Malook Khan Pahi,
Taluka Sakrand, District Shaheed Benazir Abad.
Drafted by me in my office at Nawabshah, under the
instructions of the applicants No.1 & 2.
Addresses of the parties are same as shown in the
cause title of the application.
(AMEER ALI
MAHESSAR)
Advocate for Applicants.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.
Sohni & Others

OF 2009.

-------------------------------Applicants
VERSUS

Public at Large
------------------------------ Opponents.
A F F I D A V I T.

I, Rahim Dad son of Saleem Zardari, adult, muslim, r/o: Village


Muhammad Laique Zardari, UC-Chanessar-II, Taluka Nawabshah,
District Shaheed Benazir Abad, do hereby state on oath as under:1.

That I know applicant Mst. Sohni as well as her children

applicants Nos. 2 to 4 .
2).

That deceased Muhammad Laique Zardari was my cousin died

on 08.04.2009, at left behind him his sole legal heirs the applicants
No. 1 to 4.
3).

That said deceased Muhammad Laique Zardari was permanent

resident of Village Muhammad Laique Zardari, UC Chanessar-II,


Taluka Nawabshah, was serving as Senior Executive Officer, Logistic
Department,

Pakistan State Oil company limited at the time of his

death.
4).

That applicant No.1 is widow of the said deceased while

applicants No. 2 and 3 are daughters and applicant No.4 is son.


5).

That said deceased at the time of his death left behind him an

amount of Rs.51,56,214/- being his provident fund , gratuity and


insurance etc, while in his life time he purchased a flat and obtained
loan of Rs.34,92,156/- and repaid only Rs.7,23,738/- while there is
outstanding of Rs.27,68,418/- of National Bank of Pakistan Awami
Markaz Branch, Karachi in respect of said loan.
P/2

P/2
6).

That to withdraw the amount aforesaid from the concerned

department a Succession Certificate is required to the applicant. The


applicants are Sunni muslims, so also the said deceased

7).

That prior to this no any application on the part of the

applicants have been moved before any court or authority , competent


to issue or grant.

Whatever stated above is true and correct to the best of my


knowledge and belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.
Sohni & Others

OF 2009.

-------------------------------Applicants
VERSUS

Public at Large
------------------------------ Opponents.
A F F I D A V I T.
I, Ghazi Bux son of Ali Bux Khan Zardari, adult, muslim, r/o:
Village Muhammad Laique Zardari, UC-Chanessar-II, Taluka
Nawabshah, District Shaheed Benazir Abad, do hereby state on oath
as under:1.

That I know applicant Mst. Sohni as well as her children

applicants Nos. 2 to 4 .
2).

That deceased Muhammad Laique Zardari was my brother died

on 08.04.2009, at left behind him his sole legal heirs the applicants
No. 1 to 4.
3).

That said deceased Muhammad Laique Zardari was permanent

resident of Village Muhammad Laique Zardari, UC Chanessar-II,


Taluka Nawabshah, was serving as Senior Executive Officer, Logistic
Department,
death.

Pakistan State Oil company limited at the time of his

4).

That applicant No.1 is widow of the said deceased while

applicants No. 2 and 3 are daughters and applicant No.4 is son.


5).

That said deceased at the time of his death left behind him an

amount of Rs.51,56,214/- being his provident fund , gratuity and


insurance etc, while in his life time he purchased a flat and obtained
loan of Rs.34,92,156/- and repaid only Rs.7,23,738/- while there is
outstanding of Rs.27,68,418/- of National Bank of Pakistan Awami
Markaz Branch, Karachi in respect of said loan.
P/2

P/2
6).

That to withdraw the amount aforesaid from the concerned

department a Succession Certificate is required to the applicant. The


applicants are Sunni muslims, so also the said deceased

7).

That prior to this no any application on the part of the

applicants have been moved before any court or authority , competent


to issue or grant.

Whatever stated above is true and correct to the best of my


knowledge and belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Sohni & Others


-------------------------------Applicants
VERSUS
Public at Large

------------------------------ Opponents.

A F F I D A V I T.
I, Sohni Wd/O Late Muhammad Laique Zardari, adult, Muslim,
r/o: Village Muhammad Laique Zardari, UC-Chanessar-II, Taluka
Nawabshah, District Shaheed Benazir Abad, do hereby state on oath
as under:1.

That I am applicant and hence fully conversant with the facts of

the present application.


2.

That my husband late Muhammad Laique s/o Ali Bux Zardari

died on 08-04-09. I produce death certificate as Ex:__________.

3.

That said deceased Muhammad Laique was permanent r/o

village Muhammad Laique Zardari, UC. Chanessar-II, Taluka


Nawabshah, District Shaheed Benazir Abad and was serving as
senior executive officer, Logistic Department, Pakistan State Oil
Company Limited at time of his death.
4.

That said deceased left us (the applicants No 1 to 4) as his sole

legal heirs. I am widow, while applicant No 2 and 3 daughters and


applicant No.4 is son of deceased Muhammad Laique Zardari.

5.

That said deceased was sunni muslim so also we his legal heirs

(the applicants).
6.

That said deceased left an amount of Rs. 51,56,214/- at the

time of his death, which is consisting of provident fund, gratuity and


insurance etc.

I produce letter bearing No.HR/7010/2024, June,

26th , 2009, issued by Sumera Manzar, Manger Human resources,


Pakistan State Oil Karachi, as Ex._____________.
P/2

P/2
7.

That said deceased died intestate and due and diligent search

has been made for a will but none is found out.

8.

That deceased Muhammad Laique Zardari in his life time

obtained loan for purchasing flat in Karachi and amount due against
the said loan was Rs.34,92,156/- while Rs.7,23,738/- were paid by
himself

in

his

life

time

and

there

remains

outstanding

of

Rs.27,68,418/- of National Bank of Pakistan, Awami Markaz Branch,


Karachi, 1920. I produce letter dated: 24.01.2009, along with schedule
as Ex.__________.

9.

That to withdraw the amount aforesaid from the concerned

department a succession certificate is required by us.

10.

That no application has been made to any court so far and no

grant has been made of any certificate, probate

or letter of

administration in respect of debts, securities and estate of the said


deceased and there is no any impediment under the provision of
Succession Act , 1925 or any other enactment for the time being
inforce to grant the succession certificate or the validity thereof if it
were granted.

12,

That I therefore, pray that Succession Certificate may pleased be

granted in our favour authorizing / empowering me to get /


withdraw / receive the amount aforesaid with interest to be accrued
up to the date of withdrawal from logistic department, Pakistan State
Oil Company limited and from other department/institution etc for
disbursement thereof amongst all the legal heirs according to our legal
share after deducting / repaying the loan amount as mentioned above.
Whatever stated above is true and correct to the best of my
knowledge and belief.

Deponent.
I know the deponent.

Advocate

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

Sohni & Others

OF 2009.

-------------------------------Applicants

VERSUS
Public at Large

------------------------------ Opponents.

SCHEDULE OF PROPERTIES /DEBTS / SECURITIES OF


DECEASED MUHAMMAD LAIQUE SON OF ALI BUX
ZARDARI, AS PROVIDED BY APPLICANT No.1

DEBTS

Serial
No.

01

Name of
Debtor

Amount of debt
including interest,
on date of
application for
certificate

Deceased
Rs.27,68,418/Muhammad
Laique S/O Ali of National Bank of
Bux Zardari.
Pakistan
Awami
Markaz
Branch
Karachi, 1920

Description and date of


instrument, if any, by
which the debt is
secured

Loan of National Bank of


Pakistan,

Awami

Branch

against

Late

Markaz

Karachi;

1920-

Muhammad

Laiq

Zardari

as

Loan

letter

dated:

along

with

vide

24.01.2009

Saihban

schedule.

P/2

P/2

SECURITIES

Serial
No.

01

Distinguishing
number or letter
of security

Letter bearing
No.
HR/7010/202
4, June, 26,
2009, issued
by Pakistan
State Oil
Company
Limited to the
application for
requiring
Succession
Certificate for
an amount of
Rs.5,156,214/-

DESCRIPTION
Name, title or Amount or par
class of
value of security
security

Market value of
security on date
of application for
certificate.

Final
Settlement
of account
of Late
Muhammad
Laiq Zardari
includes
Provident
Fund,
Gratuity,
Insurance
etc.

Rs.5,
156,214/(Rupees Five
Million One
hundred fifty
six thousand ,
two hundred
and fourteen
only.

Rs.5, 156,214/(Rupees Five


Million One
hundred fifty six
thousand, two
hundred and
fourteen only,
along with
interest accrued
till receipt of
amount from
concerned
department.

NAWABSHAH.
DATED:

ADVOCATE FOR APPLICANTS.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.

OF 2009.

Sohni & Others


-------------------------------Applicants
VERSUS
Public at Large

------------------------------ Opponents.

APPLICATION U/O 32 RULE 3 (2) CPC

It is prayed

on behalf of the applicant No.1, that this

Honourable Court may be pleased to appoint her as guardian ad litem


for minors applicants (1) Kanwal , Soonh and Muhammad Hanif for
the purpose of obtaining Succession Certificate on the consideration of
the grounds mentioned in the accompanying affidavit.

ADVOCATE FOR APPLICANTS.


NAWABSHAH.
DATED:

-07-2009

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No.
Sohni & Others

OF 2009.

-------------------------------Applicants
VERSUS

Public at Large
------------------------------ Opponents.

A F F I D A V I T.
I, Sohni Wd/O Late Muhammad Laique Zardari, adult, muslim,
r/o: Village Muhammad Laique Zardari, UC-Chanessar-II, Taluka
Nawabshah, District Shaheed Benazir Abad, do hereby state on oath
as under:1.
That I am applicant and hence fully conversant with the facts of
the present application.
2.
That accompanying application U/O 32 Rule 3 (2) CP C has
been filed on my instructions, the contents where of are true and may
be read as part of this affidavit.

3.
That I am real mother of minors, applicants Nos. 2 to 4 so
no any interest in the matters in controversy in the applicantion
adverse that of minors and that I am a fit person to be so
appointed.
4.
That Justice requires that my accompanying application may be
allowed.
5.
That I shall suffer serious loss if the accompanying application
is not allowed.
Whatever stated above is true and correct to the best of my
knowledge and belief.

Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE, SHAHEED BENAZIR ABAD


Succession

Application No.

of 2009.

7. Mst. Sohni wd/o Muhammad Laique


Zardari, muslim, adult, r/o: Village
Muhammad
Laique
Zardari,
UCChanessar-II,
Taluka
Nawabshah,
District Shaheed Benazir Abad.
8. Kanwal D/O Late Muhammad Laique
Zardari, (aged about 14 years)
9. Baby Soonh D/O Late Muhammad
Laique Zardari (aged about 13 years)
10.
Muhammad Hanif son of late
Muhammad Laique Zardari (aged
about 11 years)
Nos. 2 to 4 minors, through their
mother and guardian ad-litem / next
friend Mst. Sohni, the applicant No.1.
--------------------------Applicants.
Versus.
Public at large
-----------------------Opponents.

APPLICATION U/S 370 & 372


SUCCESSION ACT,1925.
The applicants named above humbly submit as under:1).

That Late Muhammad Laique S/O Ali Bux Zardari died on

08-04-2009, for which original death certificate is submitted


herewith as annexure "A".
2).

That said deceased Muhammad Laique Zardari was

permanent resident of Village Muhammad Laique Zardari, UC


Chanessar-II, Taluka Nawabshah, District Shaheed Benazir Abad and

was serving as Senior Executive Officer, Logistic Department ,


Pakistan State Oil Company Limited, at the time of his death.
P/2

P/2
3).

That said deceased at the time of his death left the applicants

as his sole legal heirs being widow, daughters and son. Applicant
No.1 is his widow while applicants Nos.2 & 3 are daughters and
application No.4 is son.
4).

That the said deceased was Sunni Muslim and so are his legal

heirs the applicants.


5).

That the said deceased at the time of his death left an amount

of Rs.51,56,214/-, which includes Provident Fund, Gratuity and


Insurance etc. Photostat copy of such letter requiring Succession
Certificate from the applicants, issued by Sumera Manzar, Manager
Human Resources, Pakistan State Oil Company Karachi, bearing
letter NO. HR/7010/2024, June, 26 th, 2009, which is submitted
herewith as annexure B.
6).

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


7).

That said deceased Muhammad Laique Zardari in his life time

obtained loan for purchasing Flat in Karachi and the amount due
against the said loan was Rs.34,92,156/-, while Rs.7,23,738/- were
paid by the said deceased and there remains outstanding of
Rs.27,68,418/- of National Bank of Pakistan, Awami Markaz Branch,
Karachi. 1920, vide letter dated: 24.01.2009, copy of letter along
with payment schedule is submitted herewith as annexure C.
8).

That to withdraw the amount aforesaid from the concerned

Department, a succession certificate is required by the applicants,


hence this application.
9).

That no application has been made to any court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, security and estates of the

said deceased and there is no any impediment under the provisions


of Succession Act, 1925 or any other enactment for the time being in
force to grant of the succession certificate or the validity of thereof if
it were granted.
10). That

the

applicants

have

fully

set

forth

the

securities/amount/debts in Para No.5 above, in respect of which


succession certificate is applied for.
P/3

P/3
PRAYER
The applicants, therefore, pray that the Honourable
court may be pleased to issue a Succession Certificate
in their favour authorizing/ empowering applicant No.1,
Mst. Sohni Wd/O late Muhammad Laique Khan Zardari
to get/ with draw/ receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from
Logistic Department , Pakistan State Oil Company
Limited and from other departments/ institutions etc, for
disbursement

thereof

amongst

all

the

applicants

according to their legal shares after deducting / repaying the loan amount as mentioned above.

applicant No.1
for herself and for minors.

Advocate for Applicants

VERIFICATION.
I, Sohni Wd/O Late Muhammad Laique Zardari, adult,
muslim, aged about 34 years r/o: Village Muhammad Laique Zardari,
UC-Chanessar-II, Taluka Nawabshah, District Shaheed Benazir Abad,
do hereby verify on oath on this ________

day of July, 2009 at

Nawabshah, that whatever stated above is true and correct to the


best of my knowledge and belief.

Deponent
I know the deponent

Advocate
P/4

P/4

Documents filed
As Annexure "A" to "C".

Documents Relied upon.


1. Same as above
2. Any other evidence, document or record.

LIST OF WITNESSES:
4. Applicant herself
5. Ghazi Bux son of Ali Bux Khan Zardari.
6. Raheem Dad son of Saleem Zardari,
All r/o: Village Muhammad Laique Zardari,
UC Chanessar-II, Taluka Nawabshah,
District Shaheed Benazir Abad.

Drafted by me in my office at Nawabshah, under the


instructions of the applicant No.1.

Addresses of the parties are same as shown in the


cause title of the application.

(AMEER ALI
MAHESSAR)
Advocate for Applicants.

IN THE COURT DISTRICT JUDGE , SHAHEED BENAZIR ABAD.


Succession Application No.

of 2008.

Miss. Mehar Afshan & Others.


..Applicants.
Versus.
Public at large
.
Opponents.
APPLICATION U/S 376 SUCCESSION ACT,1925.
It is prayed that this Honourable court may be pleased
to issue extended Succession Certificate in favour of applicants No.1
to 4 authorizing/ empowering applicant No.1, namely Miss. Mehar
Afshan D/O Late Abdul Hameed Memon to get/ receive the amount
of Rs.4,54,875-23, Rs.50,000/-

on profit and loss sharing basis of

PLS Crore Pati Deposit Certificate bearing NO.CPDC 385283/04/133,


dated: 30.11.1998, till its accrual, Rs.4,56,000/- of State Life
Insurance Corporation of Pakistan vide letter dated: June, 09, 2008,
issued by State Life Insurance Corporation Karachi Southern Zone to
applicant No.1 , requiring Succession Certificate, Certificate issued
by Habib Bank limited New town Branch Karachi with regard to
articles/cash kept in Locker bearing No.593, key No.553,

left by

deceased Mehar Afroze and for disbursement thereof amongst all


the applicants viz. 1 to 4 according to their legal share on the
consideration of the following facts and grounds.
P/2

P/2

F A C T S.

Facts leading to the present application are that the


Honourable Court was pleased to issue Succession Certificate with
regard to amount of Rs.1,43,032/51, maintained with Habib Bank
Limited New town Branch Karachi, grant of Family Pensions, GP
Fund, Final Payment/ Group Insurance and one 180 days death
salary on 25.02.2009. However, the applicants were enquiring other
amounts left by the deceased and have come to know about the
aforesaid assets/ amount / articles of deceased Mehar Afroze and
enquired from the concerned, on which
Certificate,

hence

this

application

they required Succession


for

extended

Succession

Certificate, in favour of the applicants on the following grounds :G R O U N D S.


1.

That all the legal formalities were complied with while issuing

succession Certificate dated:25.2.2009 by this Honourable court with


regard to the legal heirs of late Mehar Afroze D/O Late Abdul
Hameed

Memon

Viz.

publication

in

newspaper,

report

from

Mukhtiarkar and evidence of the witnesses.


2.

That balance certificate issued by Habib Bank Limited Masjid

Road Nawabshah along with letter No.DMA/001, dated: 18.02.2009,


Original Crore Pati PLS Rupee Deposit Certificate in the name of
deceased Mehar Afroze (on behalf of minor Iqra Firdous) bearing
No.CPDC-385283/04/133, dated: 30.11.1998, copy of letter issued
by Deputy Manager Claims , State Life
P/3
P/3
Insurance Corporation of Pakistan, Karachi, Southern Zone, dated:
June 9, 2008 with regard to Policy No.501605694-3 , in the name of
Late Dr. Mehar Afroze containing Rs.4,56,000/- and certificate issued
by Habib Banks Limited New town Brnach Karachi, with regard to
locker bearing NO. 593, Key No.553, for withdrawal of the
articles/cash/assets are submitted herewith.

3.

That Photo copy of Succession Certificate dated:25.2.2009 is

submitted herewith as the original was obtained by concerned


authorities after it was issued.

Applicant No.1

Applicant No.2

Applicant No.3

Applicant No.4

Advocate for Applicants


V E R I F I C A T I O N.
I, Mehar Afshan D/o Late Abdul Hameed Memon, adult,
muslim, r/o: House No. # A-35, Government Employee Co-Operative
Housing Society, Nawabshah, do hereby verify on oath on this
_______ day of April, 2009 at Nawabshah, that whatever stated above
is true and correct to the best of my knowledge and belief.
Deponent.
I know the deponent.

Advocate.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.
Miss. Mehar Afshan & others

Public at Large

of 2008.

...Applicants

Versus
.. Opponents

SCHEDULE OF PROPERTIES /DEBTS / SECURITIES OF


DECEASED MISS. MEHAR AFROZE D/O ABDUL HAMEED
MEMON, AS PROVIDED BY THE APPLICANTS.

DEBTS

Serial
No.

Nil.

Name of
Debtor

Nil.

Amount of debt
including interest,
on date of
application for
certificate

Description and date of


instrument, if any, by
which the debt is secured

Nil.

Nil.

SECURITIES

Serial
No.

Distinguishing
number or
letter of
security

DESCRIPTION
Name, title
Amount or par
or class of
value of security
security

Market value of
security on
date of
application for
certificate.

01

Certificate
dated: 27th
June, 2008 of
PLS Account
No. 8994-3
issued by
Habib Bank
Ltd New Town
Branch
Karachi.

Credit
Balance of
deceased
Miss.
Mehar
Afroze D/O
Abdul
Hameed
Memon
PLS
Account
No.8994-3.

Rs.1,43,032.59
(Rupees One lac
Forty three
thousand,
thirty two and
fifty nine
paisas. along
with interest
accrued till
receipt of
amount from
concerned
bank..

P/2

Rs.1,43,032.5
9 (Rupees One
lac Forty three
thousand,
thirty two and
fifty nine
paisas.

P/2
2.

Letter No.SR
& P (CH) / 1319, dated:
12.02.2008,
issued
by
Medical
Superintenden
t
Civil
Hospital
Karachi .

NAWABSHAH.
DATED:

Family
Pension /
G.P Fund /
Final
Payment /
Group
insurance
and 180
days death
Salary.

Family
Pension / G.P
Fund / Final
Payment /
Group
insurance and
180 days death
Salary,
accruable as per
letter
mentioned in
Column No.1.

Family
Pension / G.P
Fund / Final
Payment /
Group
insurance and
180 days
death Salary,
accruable as
per letter
mentioned in
Column No.1.
along with
interest if any,
till the receipt
of the amount.

ADVOCATE FOR APPLCIANTS.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

36 of 2008.

Murad Ali & others


...Applicants
Versus
Public at Large

.. Opponents

EXTENDED SCHEDULE OF PROPERTIES /DEBTS /


SECURITIES OF DECEASED ALI KHAN SON OF RAHEEM
DAD JAMALI, AS PROVIDED BY THE APPLICANT.

DEBTS
Serial
No.

Nil.

Name of
Debtor

Nil.

Amount of debt
including interest,
on date of
application for
certificate
Nil.

Description and date of


instrument, if any, by
which the debt is secured

Nil.

SECURITIES
Serial
No.

01

DESCRIPTION
Distinguishing
number or
letter of
security

Name, title
or class of
security

Amount or par
value of security

letter No. 493940/DM/SST/H


ESCO/NSH,

Service
claim of
Late Ali

1. Funeral charges
Rs.5,000/

Market value of
security on
date of
application for
certificate.

Rs.3,44,422/of S.No.1,3,4,
and 6. While 2

dated:
28.07.2008,
issued by
Deputy
Manager SS & T
Divisions GSO,
HESCO
Nawabshah

Khan
Mallahi in
SS& T
Division
GSO HESCO,
at 132 KV
Gird Station
Society
Nawabshah

2. WAPDA Welfare
grant in favour of
Widow and minors
of deceased
(conditional if the
widow re-marriage
amount) will be
seized admissible

and 5 is due
since the date
of death of
deceased Ali
Khan,
whatsoever till
the accrual of
the amount
along with
interest, if any.

Rs.870/-.
3. Group Life
insurance
Rs.1,82,000/-

4. Gratuity
Rs.1,26,194/5. Pension Per
month Rs.919/-

6. 180 days
encashment
Rs.24,529/-.
7. G.P. Fund of
Rs.6999/- upto the
death of deceased .

NAWABSHAH.
DATED:

ADVOCATE FOR APPLCIANTS.

IN THE COURTOF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

of 2008.

Miss. Meher Afshan & Others


--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Bhoongar Kathio son of Fazul Mohammad, muslim, adult,
village Syed Khair Shah, Post Office Nawabshah, Taluka Nawabshah,
District Shaheed Benazir Abad presently r/o: Govt: Employees CoOperative Housing Society, Nawabshah, do hereby state on oath as
under:1). That deceased Mehar Afroze as well as applicants are well
known to me.
2). That Mst. Mehar AFroze died on 10.06.2007 and she left
behind her the applicants, as her sole legal heirs.
3). That the said deceased was a Sunni muslim and she left at the
time of her death an amount of Rs.1,43,032-59, in her account No.
8994-3, maintained with Habib Bank Ltd, New Town Branch Karachi
& also left family pension / G.P fund / Final payment / Group
Insurance / 180 days death Salary with health department.
4). That prior to this no any Succession Certificate, probate or
letter of Administration for the property of the deceased has either
been applied or granted to the applicants.

Page-2
5). That since the applicants are sole legal heirs of deceased and
are entitled to be issued a Succession Certificate in their favour.
Whatever stated above is true and correct to the best of
my knowledge and belief.

DEPONENT.
I KNOW THE DEPONENT.
ADVOCATE.
Nawabshah.
Dated:

IN THE COURTOF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

of 2008.

Miss. Meher Afshan & Others


--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Abdul Aziz son of Late Abdul Hameed, muslim, adult, Memon
by caste, r/o: House No. A-35, Govt: Employees Co-Operative
Housing Society, Nawabshah, do hereby state on oath as under:1).

That

deceased Mehar Afroze was my sister, who died on

10.06.2007 and she left behind her we the applicants, as her sole
legal heirs.
2).

That the said deceased was a Sunni muslim and she left at the

time of her death an amount of Rs.1,43,032-59, in her account NO.


8994-3, maintained with Habib Bank Ltd New Town Branch Karachi &
also left family pension / G.P fund / Final payment / Group
Insurance / 180 days death Salary with health department.
4).

That prior to this no any Succession Certificate, probate or

letter of Administration for the property of the deceased has either


been applied or granted to the applicants.
P/2

P/2
5).

That since we viz. applicants are sole legal heirs of deceased

Mehar Afroze Memon and are entitled to be issued a Succession


Certificate in our favour authorizing / empowering applicant No.1
Miss. Mehar Afshan to withdraw the amount from Habib Bank Ltd
New town branch Karachi , Family pension/ G.P Fund/ Final Payment/

Group Insurance and 180 days death Salary from Health Department
and from any other department / institution etc for disbursement
thereof amongst us according to legal share.
Whatever stated above is true and correct to the best of
my knowledge and belief.

DEPONENT.
I KNOW THE DEPONENT.

ADVOCATE.
Nawabshah.
Dated:

IN THE COURTOF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

of 2008.

Miss. Meher Afshan & Others


--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Abdul Jabar son of Late Abdul Hameed, muslim, adult,
Memon by caste, r/o: House No. A-35, Govt: Employees Co-Operative
Housing Society, Nawabshah, do hereby state on oath as under:1).

That

deceased Mehar Afroze was my sister, who died on

10.06.2007 and she left behind her we the applicants, as her sole
legal heirs.
2).

That the said deceased was a Sunni muslim and she left at the

time of her death an amount of Rs.1,43,032-59, in her account NO.


8994-3, maintained with Habib Bank Ltd New Town Branch Karachi &
also left family pension / G.P fund / Final payment / Group
Insurance / 180 days death Salary with health department.
4).

That prior to this no any Succession Certificate, probate or

letter of Administration for the property of the deceased has either


been applied or granted to the applicants.
P/2
P/2
5).

That since we viz. applicants are sole legal heirs of deceased

Mehar Afroze Memon and are entitled to be issued a Succession


Certificate in our favour authorizing / empowering applicant No.1
Miss. Mehar Afshan to withdraw the amount from Habib Bank Ltd
New town branch Karachi , Family pension/ G.P Fund/ Final Payment/

Group Insurance and 180 days death Salary from Health Department
and from any other department / institution etc for disbursement
thereof amongst us according to legal share.
Whatever stated above is true and correct to the best of
my knowledge and belief.

DEPONENT.
I KNOW THE DEPONENT.

ADVOCATE.
Nawabshah.
Dated:

IN THE COURTOF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

of 2008.

Miss. Meher Afshan & Others


--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Abdul Sattar sosn of Late Abdul Hameed, muslim, adult,
Memon by caste, r/o: House No. A-35, Govt: Employees Co-Operative
Housing Society, Nawabshah, do hereby state on oath as under:1).

That

deceased Mehar Afroze was my sister, who died on

10.06.2007 and she left behind her we the applicants, as her sole
legal heirs.
2).

That the said deceased was a Sunni muslim and she left at the

time of her death an amount of Rs.1,43,032-59, in her account NO.


8994-3, maintained with Habib Bank Ltd New Town Branch Karachi &
also left family pension / G.P fund / Final payment / Group
Insurance / 180 days death Salary with health department.
4).

That prior to this no any Succession Certificate, probate or

letter of Administration for the property of the deceased has either


been applied or granted to the applicants.
P/2
P/2
5).

That since we viz. applicants are sole legal heirs of deceased

Mehar Afroze Memon and are entitled to be issued a Succession


Certificate in our favour authorizing / empowering applicant No.1
Miss. Mehar Afshan to withdraw the amount from Habib Bank Ltd
New town branch Karachi , Family pension/ G.P Fund/ Final Payment/

Group Insurance and 180 days death Salary from Health Department
and from any other department / institution etc for disbursement
thereof amongst us according to legal share.
Whatever stated above is true and correct to the best of
my knowledge and belief.

DEPONENT.
I KNOW THE DEPONENT.

ADVOCATE.
Nawabshah.
Dated:

IN THE COURTOF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

of 2008.

Miss. Meher Afshan & Others


--------------------------Applicants.
Versus.
Public at large
--------------------------Opponents.

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.

I, Mehar Afshan D/O Late Abdul Hameed, muslim, adult,


Memon by caste, r/o: House No. A-35, Govt: Employees Co-Operative
Housing Society, Nawabshah, do hereby state on oath as under:1).

That deceased Mehar Afroze D/O Late Abdul Hameed Memon

died on 10.06.2007 and she left behind her we the applicants, as her
sole legal heirs. I produce death Certificate as Ex.____________.
2).

That the said deceased was a Sunni muslim and she left at the

time of her death an amount of Rs.1,43,032-59, in her account NO.


8994-3, maintained with Habib Bank Ltd New Town Branch Karachi. I
produce Bank Statement/Certificate as Ex.______________.
3).

That deceased Mehar Afroze also left family pension / G.P fund

/ Final payment / Group Insurance / 180 days death Salary

with

health department such letter issued by Medical Superintendent


Civil Hospital, Karachi requiring Succession Certificate is submitted
as Ex.__________.
P/2
P/2
4).

That the Honourable Court was pleased to issue a letter to

Mukhtiarkar Revenue, Nawabshah verifying the legal heirs of


deceased Mehar Afroze and such verification submitted before the

Honourable Court by Mukhtiarkar Revenue, Nawabshah is produced


as Ex._________.
5).

That the Honourable Court was further pleased to issue

publication inviting the objections if any from public at large, such


copy of Daily Kawish Hyderabad is submitted as Ex._________.
6).

That prior to this no any Succession Certificate, probate or

letter of Administration for the property of the deceased has either


been applied or granted to the applicants.
7).

That since we viz. applicants are sole legal heirs of deceased

Mehar Afroze Memon and are entitled to be issued a Succession


Certificate in our favour.
8).

That being legal heir I may be authorized to withdraw /

receive/ obtain / get the amount from Habib Bank Ltd New town
branch Karachi , Family pension/ G.P Fund/ Final Payment/ Group
Insurance and 180 days death Salary from Health Department and
from any other department / institution etc for disbursement thereof
amongst all the legal heirs viz. we the applicants Nos. 1 to 4
according to legal share.
Whatever stated above is true and correct to the best of
my knowledge and belief.
DEPONENT.
I KNOW THE DEPONENT.

ADVOCATE.
Nawabshah.
Dated:

IN THE COURTOF THE DISTRICT JUDGE, SHAHEED


MOHTARMA BENAZIR BHUTTO
Succession Application No.
11.
12.
13.
14.

of 2008.

Miss. Meher Afshan D/O Late Abdul Hameed


Abdul Sattar S/O Late Abdul Hameed
Abdul Jabbar S/O Late Abdul Hameed
Abdul Aziz
S/O Late Abdul Hameed

All muslims, adults, Memon by caste,


R/O: H # A-35, Govt. Employees Co-Operative
Housing Society, Nawabshah.
--------------------------Applicants.
Versus.
Public at large
-----------------------Opponents.

APPLICATION U/S 370 & 372


SUCCESSION ACT,1925.
The applicants named above humbly submit as under;
1.

That Meher Afroze D/O Abdul Hameed Memon died on 10-06-

2007, for which death certificate is submitted herewith as annexure


"A".
2.

That said deceased Meher Afroze was permanent resident of

Govt. Employees Co-Operative Housing Society, Nawabshah and


was serving as Senior Women Medical Officer (BPs-19), Civil Hospital
Karachi, at the time of her death.
P/2

P/2
3.

That said deceased at the time of her death left the applicants

as her sole legal heirs being sister and brothers. Applicant No.1 is
her sister while applicants Nos.2 to 4 are her brothers. Father and

mother of the deceased had died during the life time of the
deceased.
4.

That the said deceased was Sunni Muslim and so are her legal

heirs the applicants.


5.

That the said deceased at the time of her death left an amount

of Rs.1,43,032-59 in her account No.8994-3 maintained with Habib


Bank

Limited,

New

Town

Branch

Karachi,

such

Bank

Statement/Certificate dated: June, 27, 2008 is submitted herewith as


annexure "B". The said deceased also left Family Pension /G.P Fund /
Final Payment / Group Insurance, 180 days death salary, to which
amount the applicants are entitled to get as per Muhammadan Law,
such letter requiring Succession Certificate issued by Office of the
Medical Superintendent Civil Hospital Karachi, bearing No.SRP (CH)/1319, dated: 12.02.2008, is submitted herewith as annexure "C".
6.

That since the said deceased was Govt. employee, hence

heirship certificate was applied and such heirship certificate was


issued bearing No. SM/-02 of 2008, Nawabshah, dated: 08.01.2008,
by Mukhtiarkar (Revenue) Nawabshah, is submitted herewith as
annexure "D"
7.

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


8.

That to withdraw the amount aforesaid from the bank

concerned and Health Department, a succession certificate is


required by the applicants, hence this application.
P/3
P/3
9.

That no application has been made to any court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, security and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in
force to grant of the succession certificate or the validity of thereof if
it were granted.

10.

That the applicants have fully set forth the securities/ amount

in Para No.5 above, in respect of which succession certificate is


applied for.

PRAYER
The applicants, therefore, pray that the honourable
court may be pleased to issue a Succession Certificate
in their favour authorizing, empowering applicant No.1,
Miss. Meher Afshan D/O Late Abdul Hameed Memon to
get/ with draw/ receive the amount aforesaid with
interest to be accrued up to the date of withdrawal from
Habib

Bank

Department/

New

Town

Medical

Branch,

Karachi,

Superintendent

Civil

Health
Hospital

Karachi and from other departments/ institutions etc, for


disbursement

thereof

amongst

all

the

applicants

according to their legal shares.

Miss. Meher Afshan


applicant No.1

Abdul Sattar
applicant No.2

Abdul Jabbar
applicant No.3.

Abdul Aziz
applicant No.4.

Advocate for Applicants


P/4

VERIFICATION.
I, Meher Afshan D/O Late Abdul Hamed Memon, muslim,
adult, R/o Govt. Employees Co-Operative Housing Society,
Nawabshah, do hereby verify on oath on this

day of November,

2008 at Nawabshah, that whatever stated above is true and correct


to the best of my knowledge and belief.

Deponent
I know the deponent

Advocate

Documents filed
As Annexure "A" to "D".
Documents Relied upon.
1. Same as above
2. Any other evidence, document or record.
Drafted by me in my office at Nawabshah, under the
instructions of the applicants.
Addresses of the parties are same as shown in the
cause title of the application.

(AMEER ALI
MAHESSAR)
Advocate for Applicants.

IN THE COURTOF THE DISTRICT JUDGE, SHAHEED


MOHTARMA BENAZIR BHUTTO
Succession Application No.

of 2008.

Miss. Meher Afshan & Others


--------------------------Applicants.
Versus.
Public at large
-----------------------Opponents.

APPLICATION FOR VERIFICATION OF


THE LEGAL HEIRSOF DECEASED MEHAR AFROZE
D/O LATE ABDUL HAMEED MEMON
It is submitted that Mehar Afroze D/O Late Abdul Hameed
Memon, permanent r/o: Govt: Employees Co-Operative Housing

Society, Nawabshah, died on 10-06-2007, leaving behind the


following legal heirs;
26.
27.
28.
29.

Miss. Meher Afshan D/O Late Abdul Hameed


Abdul Sattar S/O Late Abdul Hameed
Abdul Jabbar S/O Late Abdul Hameed
Abdul Aziz
S/O Late Abdul Hameed

All muslims, adults, Memon by caste,


R/O: H # A-99, Govt. Employees Co-Operative
Housing Society, Nawabshah.
It is therefore, prayed that Mukhtiarkar (Revenue) Taluka
Nawabshah, may be directed to verify the legal heirs of deceased
Meher Afroze D/O Late Abdul Hameed Memon r/o: Govt. Employees
Co-Operative Housing Society, Nawabshah.
Advocate
Applicants

for

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No.

of 2008.

Muhammad Faheem and others


.Applicants
Versus
Public at Large

Opponents

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Syed Khalid son of Syed Wahid Ali, adult, muslim, R/o:
Kamora Colony, near Gohsia Masjid, Camp No.2, Nawabshah, do
hereby state on oath as under:
1).

That deceased Raziullah Khan son of Shafiullah Khan died on

02.08.2008 and he left behind his the applicants Nos. 1 to 9 as his


sole legal heirs.
2).

That the said deceased was a Sunni muslim and he left at the

time of his death an amount of Rs.1,59,760.86, in his account


NO.042970000016-01, maintained with Habib Bank Ltd Mohni Bazar
Branch, Nawabshah.
3).

That prior to this no any Succession Certificate, probate or

letter of Administration for the property of the deceased has either


been applied or granted to the applicants.
4).

That since applicants Nos. 1 to 9 are sole legal heirs of

deceased Raziullah Khan and are entitled to be issued a Succession


Certificate in their favour.
What ever stated above is true and correct to the best of
my knowledge .
DEPONENT.

I KNOW THE DEPONENT.

ADVOCATE.

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No.

of 2008.

Muhammad Faheem and others


.Applicants
Versus
Public at Large

Opponents

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Fahmida Wd/o Raz-i-ullah Khan, adult, muslim, By caste
Yousifzai Pathan, R/o: near Gohsia Masjid Camp No.2, Nawabshah,
do hereby state on oath as under:
1).

That I am applicant No.9, while applicant No.1 is my son.

2).

That my husband Raz-i-ullah Khan son of Shafiullah Khan died

on 02.08.2008 and

at the time of his death

left

an amount of

Rs.1,59,760.86, in his account NO.042970000016-01, maintained


with Habib Bank Ltd Mohni Bazar Branch, Nawabshah.

3).

That my husband died intestate and due and diligent search

has been made for a will but none is found.


4).

That

to

withdraw

the

amount

aforesaid

Succession

Certificate is required to us by the bank concerned.


P/2

P/2
5).

That I have no objection if the Succession Certificate is

granted by authorizing , empowering my son Muhammad Faheem


(the applicant No.1) to get/ withdraw / receive the amount aforesaid
with the interest to the accrued up to the date from Habib Bank Ltd.
Mohni Bazar Branch Nawabshah and from other departments /
institution etc for disbursement thereof among us the applicants
Nos. 1 to 9, according to legal share.
What ever stated above is true and correct to the best of
my knowledge .

DEPONENT.
I KNOW THE DEPONENT.

ADVOCATE.

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No.

of 2008.

Muhammad Faheem and others


.Applicants
Versus
Public at Large

Opponents

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Muhammad Naeem son of Raz-i-ullah Khan, adult, muslim,
By caste Yousifzai Pathan, R/o: near Gohsia Masjid Camp No.2,
Nawabshah, do hereby state on oath as under:
1).

That I am applicant No.3, while applicant No.1 is my brother.

2).

That my father Raz-i-ullah Khan son of Shafiullah Khan died on

02.08.2008 and

at the time of his death

left

an amount of

Rs.1,59,760.86, in his account NO.042970000016-01, maintained


with Habib Bank Ltd Mohni Bazar Branch, Nawabshah.
3).

That my father died intestate and due and diligent search has

been made for a will but none is found.


4).

That

to

withdraw

the

amount

aforesaid

Succession

Certificate is required to the applicants by the bank concerned.


5).

That I have no objection if the Succession Certificate is

granted by authorizing , empowering my brother Muhammad


Faheem (the applicant No.1) to get / withdraw / receive the amount
aforesaid with the interest to the accrued up to the date from Habib
Bank

Ltd.

Mohni

Bazar

Branch

Nawabshah

and

from

other

departments / institution etc for disbursement thereof among us the


applicants Nos. 1 to 9, according to legal share.
What ever stated above is true and correct to the best of
my knowledge .
DEPONENT.
I KNOW THE DEPONENT.

ADVOCATE.

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No.

of 2008.

Muhammad Faheem and others


.Applicants
Versus
Public at Large
Opponents

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Muhammad Faheem son of Raz-i-ullah Khan, adult, muslim,
By caste Yousifzai Pathan, R/o: near Gohsia Masjid Camp No.2,
Nawabshah, do hereby state on oath as under:
1).

That I am applicant No.1 in the above application, hence fully

conversant with the facts of the same.


2).

That my father Raz-i-ullah Khan son of Shafiullah Khan died on

02.08.2008, such death certificate is submitted as Ex._______


3).

That my father at the time of his death was residing near

Ghosia Masjid Camp No.2, Nawabshah and at the time of death he


left we the applicants Nos. 1 to 9 as his sole legal heirs , such report
of Mukhtiarkar is submitted as Ex.________.
4).
death

That my father was a Suuni muslim and he at the time of his


left

an

amount

of

Rs.1,59,760.86,

in

his

account

NO.042970000016-01, maintained with Habib Bank Ltd Mohni Bazar

Branch, Nawabshah. I submit Bank Statement / Certificate as


Ex.____________.
5).

That my father died intestate and due and diligent search has

been made for a will but none is found.


P/2

P/2
6).

That

to

withdraw

the

amount

aforesaid

Succession

Certificate is required to the applicants by the bank concerned.


7).That prior to this no application has been made to any court and
no grant has been made for any certificate, probate or letter of
administration in respect of the debts, securities and estates of the
said deceased and there is no any impediment under the Succession
Act, 1925 or any other enactment for the time being enforced to the
grant of Succession Certificate or the validity thereof if it were
granted.
8).That we have fully set forth the security / amount in Para No.4,
aforesaid in respect of which Succession Certificate is required.
9).That the notice to public at Large issued in Daily Nawa-e Waqat,
Karachi is submitted as Ex._________.
It is therefore, prayed that the Honourable Court may be
pleased to issue a Succession Certificate in our favour authorizing,
empowering me to get / withdraw / receive the amount aforesaid
with interest to be accrued up to the date of withdrawal from Habib
Bank

Ltd.

Mohni

Bazar

Branch

Nawabshah

and

from

other

departments / institution etc for disbursement thereof among all the


other applicants, according to their legal share.

What ever stated above is true and correct to the best of


my knowledge .

DEPONENT.
I KNOW THE DEPONENT.

ADVOCATE.

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No.

of 2008.

Muhammad Faheem and others


.Applicants
Versus
Public at Large

Opponents

EXPARTE PROOF /
AFFIDAVIT IN EVIDENCE.
I, Muhammad Saleem son of Raz-i-ullah Khan, adult, muslim,
By caste Yousifzai Pathan, R/o: near Gohsia Masjid Camp No.2,
Nawabshah, do hereby state on oath as under:
1).

That I am applicant No.2, while applicant No.1 is my brother.

2).

That my father Raz-i-ullah Khan son of Shafiullah Khan died on

02.08.2008 and

at the time of his death

left

an amount of

Rs.1,59,760.86, in his account NO.042970000016-01, maintained


with Habib Bank Ltd Mohni Bazar Branch, Nawabshah.
3).

That my father died intestate and due and diligent search has

been made for a will but none is found.


4).

That

to

withdraw

the

amount

aforesaid

Succession

Certificate is required to the applicants by the bank concerned.


5).

That I have no objection if the Succession Certificate is

granted by authorizing , empowering my brother Muhammad


Faheem (the applicant No.1) to get / withdraw / receive the amount
aforesaid with the interest to the accrued up to the date from Habib
Bank

Ltd.

Mohni

Bazar

Branch

Nawabshah

and

from

other

departments / institution etc for disbursement thereof among us the


applicants Nos. 1 to 9, according to legal share.
What ever stated above is true and correct to the best of
my knowledge .

DEPONENT.
I KNOW THE DEPONENT.

ADVOCATE.

IN THE COURT DISTRICT JUDGE , NAWABSHAH.


Succession Application No. 16 of 2007.

Sharafuddin and others.


..Applicants.

Versus.
Public at large
.Opponents.

AFFIDAVIT.
I, Nasreen Akhtar Wd/o Sharfuddin Rajput, adult, muslim, R/o
House No.2-A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery
Street, Nawabshah, do hereby state on oath as under:
1.

That I am applicant No.2 in the above application, hence fully

conversant with the facts of the same.


2.

That prior to this Succession Certificate was issued in our

favour, in which my husband was authorized to withdraw the


amount from the Bank but since he has died and now applicant No.3
Fida Hussain is a fit person to be authorized to do the Job of
withdrawing the amount etc from the Bank Al-Habib.
3.

That I have got no objection if applicant No. 3 Fida Hussain

who is my son is issued extended Succession Certificate authorizing


him to withdraw the amount from the bank for distribution according
to legal shares.
Whatever stated above is true and correct to the best of my
knowledge and belief.
I know the deponent.
Deponent.
Advocate.

IN THE COURT DISTRICT JUDGE , NAWABSHAH.


Succession Application No. 16 of 2007.

Sharafuddin and others.


..Applicants.

Versus.
Public at large
.Opponents.

AFFIDAVIT.
I, Sidra D/o Sharfuddin Rajput, adult, muslim, R/o House No.2-A
837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery Street,
Nawabshah, do hereby state on oath as under:
1.

That I am applicant No.7 in the above application, hence fully

conversant with the facts of the same.


2.

That prior to this Succession Certificate was issued in our

favour, in which my father was authorized to withdraw the amount


from the Bank but since he has died and now applicant No.3 Fida
Hussain is a fit person to be authorized to do the Job of withdrawing
the amount etc from the Bank Al-Habib.
3.

That I have got no objection if applicant No. 3 Fida Hussain

who is my real brother is issued extended Succession Certificate


authorizing him to withdraw the amount from the bank for
distribution according to legal shares.

Whatever stated above is true and correct to the best of my


knowledge and belief.
I know the deponent.
Deponent.
Advocate.

IN THE COURT DISTRICT JUDGE , NAWABSHAH.


Succession Application No. 16 of 2007.

Sharafuddin and others.


..Applicants.

Versus.
Public at large
.Opponents.

AFFIDAVIT.
I, Misbah D/o Sharfuddin Rajput, adult, muslim, R/o House
No.2-A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery Street,
Nawabshah, do hereby state on oath as under:
1.

That I am applicant No.6 in the above application, hence fully

conversant with the facts of the same.


2.

That prior to this Succession Certificate was issued in our

favour, in which my father was authorized to withdraw the amount


from the Bank but since he has died and now applicant No.3 Fida
Hussain is a fit person to be authorized to do the Job of withdrawing
the amount etc from the Bank Al-Habib.

3.

That I have got no objection if applicant No. 3 Fida Hussain

who is my real brother is issued extended Succession Certificate


authorizing him to withdraw the amount from the bank for
distribution according to legal shares.
Whatever stated above is true and correct to the best of my
knowledge and belief.
I know the deponent.
Deponent.
Advocate.

IN THE COURT DISTRICT JUDGE , NAWABSHAH.


Succession Application No. 16 of 2007.

Sharafuddin and others.


..Applicants.

Versus.
Public at large
.Opponents.

AFFIDAVIT.
I, Sadia D/o Sharfuddin Rajput, adult, muslim, R/o House No.2A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery Street,
Nawabshah, do hereby state on oath as under:
1.

That I am applicant No.5 in the above application, hence fully

conversant with the facts of the same.

2.

That prior to this Succession Certificate was issued in our

favour, in which my father was authorized to withdraw the amount


from the Bank but since he has died and now applicant No.3 Fida
Hussain is a fit person to be authorized to do the Job of withdrawing
the amount etc from the Bank Al-Habib.
3.

That I have got no objection if applicant No. 3 Fida Hussain

who is my real brother is issued extended Succession Certificate


authorizing him to withdraw the amount from the bank for
distribution according to legal shares.
Whatever stated above is true and correct to the best of my
knowledge and belief.
I know the deponent.
Deponent.
Advocate.

IN THE COURT DISTRICT JUDGE , NAWABSHAH.


Succession Application No. 16 of 2007.

Sharafuddin and others.


..Applicants.

Versus.
Public at large
.Opponents.

AFFIDAVIT.

I, Atta Mohauddin S/o Sharfuddin Rajput, adult, muslim, R/o


House No.2-A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery
Street, Nawabshah, do hereby state on oath as under:
1.

That I am applicant No.4 in the above application, hence fully

conversant with the facts of the same.


2.

That prior to this Succession Certificate was issued in our

favour, in which my father was authorized to withdraw the amount


from the Bank but since he has died and now applicant No.3 Fida
Hussain is a fit person to be authorized to do the Job of withdrawing
the amount etc from the Bank Al-Habib.
3.

That I have got no objection if applicant No. 3 Fida Hussain

who is my real brother is issued extended Succession Certificate


authorizing him to withdraw the amount from the bank for
distribution according to legal shares.
Whatever stated above is true and correct to the best of my
knowledge and belief.
I know the deponent.
Deponent.
Advocate.

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No.

30.
31.
32.
33.
34.
35.
36.
37.
38.

of 2008.

Muhammad Faheem S/o Raziullah Khan


Muhammad Saleem S/o Raziullah Khan
Muhammad Naeem S/o Raziullah Khan
Muhammad Waseem S/o Raziullah Khan
Muhammad Asim S/o Raziullah Khan
Mst.Rozina D/o Raziullah Khan
Mst.Tahseen D/o Raziullah Khan
Mst.Tehreem D/o Raziullah Khan.
Mst. Fahmida Wd/o Raziullah Khan

All Muslims, Adults, Yousufzai Pathan by caste,


R/o near Ghosia Masjid Camp No.2, Nawabshah
..Applicants.

Versus.
Public at large
.Opponents.

APPLICATION U/S 370 & 372


SUCCESSION ACT,1925.
The applicants named above humbly submit as under;
1.

That Raziullah Khan S/o Shafiullah Khan died on 02-08-2008,

for which death certificate is submitted herewith as annexure "A".


2.

That said deceased Raziullah Khan was resident of near Ghosia

Masjid Camp No.2, Nawabshah, at the time of his death, within the
jurisdiction this honourable court.
3.

That said deceased at the time of his death left the applicants

as his sole legal heirs being his sons, daughters and widow.
Applicants No 1 to 5 are sons, applicants No 6 to 8 are daughters
and applicant No. 9 is widow of the deceased.
4.

That the said deceased was Sunni Muslim and so are his legal

heirs the applicants.

(2)
5.

That the said deceased at the time of his death left an amount

of Rs. 1,59,760.86/- in his account No. 042970000016-01 maintained


with Habib Bank Limited, Mohni Bazar Branch, Nawabshah, to which
amount the applicants are entitled to get as per Muhammadan Law,
such bank statement/ certificate is submitted herewith as annexure
"B".
6.

That said deceased died intestate and due and diligent search

has been made for a Will but none is found out.


7.

That to withdraw the amount aforesaid from the bank

concerned, a succession certificate is required by the applicants,


hence this application.
8.

That no application has been made to any court so for and no

grant has been made of any certificate, probate or letter of


administration in respect of the debts, security and estates of the
said deceased and there is no any impediment under the provisions
of Succession Act, 1925 or any other enactment for the time being in
force to grant of the succession certificate or the validity of thereof if
it were granted.
9.

That the applicants have fully set forth the securities/ amount

in para No.4 above, in respect of which succession certificate is


applied for.

PRAYER
The applicants, therefore, pray that the honourable court may
be pleased to issue a succession certificate in their favour
authorizing, empowering applicant No. 1 Muhammad Faheem S/o
Raziullah Khan to get/ with draw/ receive the amount aforesaid with
interest to be accrued up to the date of withdrawl from Habib bank
limited

Mohni

Bazzar,

branch,

Nawabshah

and

from

other

departments/ institutions etc, for disbursement thereof amongst all


the applicants according to their legal shares.

1.Muhammad Faheem
3.Muhammad Naeem

2.Muhammad Saleem

4.Muhammad Waseem
Rozina

5.Muhammad Asim

7. Mst. Tahseen
9.Mst.Fahmida.

8. Mst.Tehreem.

6. Mst.

Advocate for
Applicants

(3)

VERIFICATION.
I, Muhammad Faheem S/o Raziullah Khan, Yousufzai Pathan,
Muslim, Adult, R/o Near Ghosia Masjid, Camp No.2 Nawabshah, do
hereby verify on oath on this 01st day of September 2008 at
Nawabshah, that whatever stated above is true and correct to the
best of my knowledge and belief.

I know the deponent


Deponent
Advocate
Documents filed;
Relied upon.

Documents

1. Original death certificate specified in the


above
Application as annexure "A".

1. Same as

2. Original bank statement / certificate


other evidence,
specified in the application as annexure "B".
record.

2. Any
document or

Drafted by me in my office at Nawabshah, under the


instructions of the applicants.

Addresses of the parties are same as shown in the cause title of


the application.

Advocate
Applicants

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No.

of 2008.

Muhammad Faheem and others


.Applicants
Versus
Public at Large
Opponents

for

APPLICATION FOR VERIFICATION OF THE


LEGAL HEIRS OF DECEASED RAZIULLAH KHAN
It is submitted that Raziullah Khan S/o Shafiullah Khan Yousufzai
Pathan, ordinarily R/o Near Ghosia Masjid, Camp No.2 Nawabshah,
died on 02-08-2008, leaving behind the following legal heirs;
1.Muhammad Faheem S/o Raziullah Khan
2.Muhammad Saleem S/o Raziullah Khan
3.Muhammad Naeem S/o Raziullah Khan
4.Muhammad Waseem S/o Raziullah Khan
5.Muhammad Asim S/o Raziullah Khan
6.Mst.Rozina D/o Raziullah Khan
7.Mst.Tahseen D/o Raziullah Khan
8.Mst.Tehreem D/o Raziullah Khan.
9.Mst. Fahmida Wd/o Raziullah Khan
All Muslims, Adults, Yousufzai Pathan by caste,
R/o near Ghosia Masjid Camp No.2, Nawabshah.

It is therefore, prayed that Mukhtiarkar (Revenue) Taluka


Nawabshah, may be directed to verify the legal heirs of deceased
Raziullah Khan S/o Shafiullah Khan R/o Near Ghosia Masjid, Camp
No.2 Nawabshah, as he is avoiding to issue heirship certificate of the
deceased Raziullah Khan Yousufzai Pathan, as he was not
Government employee and due to the ban imposed by Board of
Revenue.

Advocate
Applicants

for

It is prayed that this honourable court may be pleased to issue


extended Succession Certificate in favour of applicants No.1 to 7
authorizing/empowering applicant No.3, namely Fida Hussain s/o
Sharfuddin Rajput to get/ receive the amount of Rs.1,85,137/(Rs:- One lac eighty five thousands one hundred thirty seven
only) being the death life insurance under Bank Policy of Bank AlHabib Ltd, Nawabshah Branch, Masjid Road. Nawabshah-Pakistan,
of deceased Ghullam Dastagir holding Account N0.071-02878950-0 for disbursement thereof among all the applicants viz 2 to 7
according to their legal share on the consideration of the
following facts and grounds.

F A C T S.
Facts leading to the present application are that Ghullam
Dastagir S/o Sharfuddin Rajput, r/o House No.II-A 837/150-A, Muhalla
Latifabad No.2, Naseer Bakery Street Nawabshah died on 18.3.2007,
such death Certificate is already on record. The said deceased at the
time of his death left behind the applicants No.1 to 7 as his sole
legal heirs. The said deceased at the time of his death left an
amount of Rs.1,22,587-30 in his account No.071-28789-50-0 with
Bank Al-Habib Masjid Road Branch, Nawabshah. Ultimately the
succession application being No. aforesaid was allowed in favour of
applicants No.1 to 7 and applicant No.1 namely Sharfuddin S/o Niaz
Ahmed Rajput r/o House No. II-A 837/150-A Muhalla Latifabad No.2,
Naseer Bakery, Nawabshah was authorized to withdraw
Page-2
the amount aforesaid from the Bank aforesaid and such succession
Certificate dated:-16.8.2007 (Photo copy attached as the original

was handed over to the Bank authorities) was issued by the


honourable court. Applicant No.1 namely Sharfuddin withdrew the
amount aforesaid and distributed among all the legal heirs of late
Ghullam Dastagir as mentioned in Succession Application. The
receipts of amount from applicants No.2 to 7 were also submitted
before the honourable court. After the amount mentioned in
succession

Application

viz

Rs.1,22,587-30

was

obtained

and

distributed the applicants further came to know that the aforesaid


account was also insured with the bank and they further came to
know that Rs.1,85,137/- was also pending with the bank in Account
of deceased Ghullam Dastagir being the death life insurance under
the Bank Policy of Bank Al-Habib Ltd, Nawabshah Branch, Masjid
Road, Pakistan. Unfortunately During the process applicant No.1
namely Sharfuddin passed away and the Bank Authorities demanded
extended Succession Certificate in favour of

the remaining

applicants authorizing any one of legal heirs of deceased Ghullam


Dastagir to withdraw the said amount, hence this application on the
following grounds:-

G R O U N D S.
1.

That all the legal formalities were complied with while issuing

succession Certificate dated:-16.8.2007 by this honourable court


with regard to the legal heirs of late Ghullam Dastagir Viz publication
in newspaper, report from Mukhtiarkar and evidence of the
witnesses.
2.

That balance certificate issued by Bank Al-Habib is submitted

in original herewith.
3.

That death certificate of applicant No.1 Sharfuddin is also

submitted herewith.
4.

That the applicants are same but applicant No.1 and the

account No. is same as mentioned in main application.


5.

That Photo copy of Succession Certificate dated:-16.8.2007 is

submitted herewith as the original was obtained by Bank Authorities.

6.

That Original Death Certificate of Ghullam Dastagir is also

submitted.

Nasreen Akhtar.

Fida Hussain

Atta

Muhauddin
Page-3

Mst. Sadia

Mst. Misbah

Mst. Sidra

Advocate for Applicants No.2


to 7.

V E R I F I C A T I O N.
I, Fida Hussain S/o Sharfuddin Rajput, adult, muslim, R/o House
No.2-A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery Street,
Nawabshah, do hereby verify on oath on this 11 th day of
January,2008 at Nawabshah, that whatever stated above is true and
correct to the best of my knowledge and belief.
I know the deponent.
Deponent.
Advocate.
DOCMENTS FILED.
1. Original Balnace Certificate of Bank Al-Habib.
2. Original death Certificate of Sharfuddin.
3. Photo Stat copy of Succession Certificate.
4. Original Death Certificate of deceased Ghullam Dastagir.
Document Relied upon.
1. Same as above.

2. Any other evidence, documents


or record.
ADDRESSES of the parties are same , as shown in the
cause title of the plaint.
DRAFTED by me in my office as per instructions.

Dated:-11.01.2008.

ADVOCATE FOR APPLICANT


NO.2 TO 7.

IN THE COURT DISTRICT JUDGE , NAWABSHAH.


Succession Application No. 16 of 2007.

Sharafuddin and others.


..Applicants.

Versus.
Public at large
.Opponents.

APPLICATION U/S 376 SUCCESSION


ACT,1925.
It is prayed that this honourable court may be pleased to issue
extended Succession Certificate in favour of applicants No.2 to 7
authorizing/empowering applicant No.3, namely Fida Hussain s/o
Sharfuddin Rajput to get/ receive the amount of Rs.1,85,137/- (Rs:One lac eighty five thousands one hundred thirty seven only) being
the death life insurance

under Bank Policy of Bank Al-Habib Ltd,

Nawabshah Branch, Masjid Road. Nawabshah-Pakistan, of deceased


Ghullam

Dastagir

holding

Account

N0.071-028789-50-0

for

disbursement thereof among all the applicants viz 2 to 7 according


to their legal share on the consideration of the following facts and
grounds.

F A C T S.
Facts leading to the present application are that Ghullam
Dastagir S/o Sharfuddin Rajput, r/o House No.II-A 837/150-A, Muhalla
Latifabad No.2, Naseer Bakery Street Nawabshah died on 18.3.2007,
such death Certificate is already on record. The said deceased at the
time of his death left behind the applicants No.1 to 7 as his sole
legal heirs. The said deceased at the time of his death left an
amount of Rs.1,22,587-30 in his account No.071-28789-50-0 with
Bank Al-Habib Masjid Road Branch, Nawabshah. Ultimately the
succession application being No. aforesaid was allowed in favour of

applicants No.1 to 7 and applicant No.1 namely Sharfuddin S/o Niaz


Ahmed Rajput r/o House No. II-A 837/150-A Muhalla Latifabad No.2,
Naseer Bakery, Nawabshah was authorized to withdraw
Page-2
the amount aforesaid from the Bank aforesaid and such succession
Certificate dated:-16.8.2007 (Photo copy attached as the original
was handed over to the Bank authorities) was issued by the
honourable court. Applicant No.1 namely Sharfuddin withdrew the
amount aforesaid and distributed among all the legal heirs of late
Ghullam Dastagir as mentioned in Succession Application. The
receipts of amount from applicants No.2 to 7 were also submitted
before the honourable court. After the amount mentioned in
succession

Application

viz

Rs.1,22,587-30

was

obtained

and

distributed the applicants further came to know that the aforesaid


account was also insured with the bank and they further came to
know that Rs.1,85,137/- was also pending with the bank in Account
of deceased Ghullam Dastagir being the death life insurance under
the Bank Policy of Bank Al-Habib Ltd, Nawabshah Branch, Masjid
Road, Pakistan. Unfortunately During the process applicant No.1
namely Sharfuddin passed away and the Bank Authorities demanded
extended Succession Certificate in favour of

the remaining

applicants authorizing any one of legal heirs of deceased Ghullam


Dastagir to withdraw the said amount, hence this application on the
following grounds:-

G R O U N D S.
1.

That all the legal formalities were complied with while issuing

succession Certificate dated:-16.8.2007 by this honourable court


with regard to the legal heirs of late Ghullam Dastagir Viz publication
in newspaper, report from Mukhtiarkar and evidence of the
witnesses.
2.

That balance certificate issued by Bank Al-Habib is submitted

in original herewith.

3.

That death certificate of applicant No.1 Sharfuddin is also

submitted herewith.
4.

That the applicants are same but applicant No.1 and the

account No. is same as mentioned in main application.


5.

That Photo copy of Succession Certificate dated:-16.8.2007 is

submitted herewith as the original was obtained by Bank Authorities.


6.

That Original Death Certificate of Ghullam Dastagir is also

submitted.

Nasreen Akhtar.

Fida Hussain

Atta

Muhauddin
Page-3

Mst. Sadia

Mst. Misbah

Mst. Sidra

Advocate for Applicants No.2


to 7.

V E R I F I C A T I O N.
I, Fida Hussain S/o Sharfuddin Rajput, adult, muslim, R/o House
No.2-A 837/150-A, Muhalla Latifabad No.2, Near Nasir Bakery Street,
Nawabshah, do hereby verify on oath on this 11 th day of
January,2008 at Nawabshah, that whatever stated above is true and
correct to the best of my knowledge and belief.
I know the deponent.
Deponent.
Advocate.

DOCMENTS FILED.
1. Original Balance Certificate of Bank Al-Habib.
2. Original death Certificate of Sharfuddin.
3. Photo Stat copy of Succession Certificate.
4. Original Death Certificate of deceased Ghullam Dastagir.
Document Relied upon.
1. Same as above.
2. Any other evidence, documents
or record.
ADDRESSES of the parties are same , as shown in the
cause title of the plaint.
DRAFTED by me in my office as per instructions.

Dated:-11.01.2008.

ADVOCATE FOR APPLICANT


NO.2 TO 7.

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No.

of 2008.

Muhammad Faheem and others


...Applicants
Public at Large

Versus
.. Opponents

SCHEDULE OF PROPERTIES /DEBTS / SECURITIES


OF DECEASED SYED RAZIULLAH KHAN S/O
SHAFIULLAH KHAN, AS PROVIDED BY THE
APPLICANTS.
DEBTS
Serial
No.

Nil.

Name of
Debtor

Nil.

Amount of debt
including interest,
on date of
application for
certificate

Description and date of


instrument, if any, by
which the debt is secured

Nil.

Nil.

SECURITIES
Serial
No.

01

Distinguishing
number or
letter of
security

RAF/0429
dated:
01.09.2008 of
HBL, Mohni
Bazar Branch,
N.Shah

DESCRIPTION
Name, title
Amount or par
or class of
value of security
security

Market value of
security on
date of
application for
certificate.

Credit
Balance of
deceased
Raziullah
son of
Shafiullah

Rs.1,59, 760.86
(Rupees One lac
Fifty nine
thousand seven
hundred sixty
and eighty six

Rs.1,59, 760.86
(Rupees One lac
Fifty nine
thousand seven
hundred sixty
and eighty six

Pakistan.

Khan. Cash
amount in
PLS Account
No.0429700
0001601.

pasas along with


interest accrued
till receipt of
amount from
concerned bank..

pasas

ADVOCATE FOR APPLCIANTS.

NAWABSHAH.
DATED:17.10.2008

IN THE COURTOF THE DISTRICT JUDGE, NAWABSHAH.


Succession Application No. 35
Ghulam Hyder

of 2008.

...Applicant

Punahal Khan & Others

Versus
.. Opponents

SCHEDULE OF PROPERTIES /DEBTS / SECURITIES


OF DECEASED ALI AKBAR SON OF WAZIR KHAN
DAWOODPOTA / ABBASI , AS PROVIDED BY THE
APPLICANT.

DEBTS
Serial
No.

Nil.

Name of
Debtor

Nil.

Amount of debt
including interest,
on date of
application for
certificate
Nil.

Description and date of


instrument, if any, by
which the debt is secured

Nil.

SECURITIES
Serial
No.

01

Distinguishing
number or
letter of
security

PLS Certificate
deposit- profit
payment,
dated of issue
dated: 19.10.06
notice period /
tenure three
years date of
maturity
19.10.2009,
Receipt
No.00091955

NAWABSHAH.
DATED:

DESCRIPTION
Name, title
Amount or par
or class of
value of security
security

Market value of
security on
date of
application for
certificate.

PLS
Certificate
of Deposit
profit
payment in
the name of
deceased Ali
Akbar son of
Wazir Khan
Dawoodpota
/ Abbasi in
UBL Masjid
Road,
Nawabshah,

Rs.1,00,000/(Rupees One lac


only).

Rs.1,00,000/(Rupees One lac)


along with profit
etc accrued till
receipt of
amount from
concerned bank..

ADVOCATE FOR APPLCIANTS.

IN THE COURT OF THE DISTRICT JUDGE,


SHAHEED BENAZIR ABAD
Succession Application No.

36 of 2008.

Murad Ali & others


...Applicants
Versus
Public at Large

.. Opponents

SCHEDULE OF PROPERTIES /DEBTS / SECURITIES


OF DECEASED ALI KHAN SON OF RAHEEM DAD JAMALI,
AS PROVIDED BY THE APPLICANT.

DEBTS
Serial
No.

Nil.

Name of
Debtor

Nil.

Amount of debt
including interest,
on date of
application for
certificate
Nil.

Description and date of


instrument, if any, by
which the debt is secured

Nil.

SECURITIES
Serial
No.

01

DESCRIPTION
Distinguishing
number or
letter of
security

Name, title
or class of
security

Amount or par
value of security

letter No. 493940/DM/SST/H

Service
claim of

1. Funeral charges
Rs.5,000/

Market value of
security on
date of
application for
certificate.

Rs.3,37,723/of S.No.1,3,4,

ESCO/NSH,
dated:
28.07.2008,
issued by
Deputy
Manager SS & T
Divisions GSO,
HESCO
Nawabshah

Late Ali
Khan
Mallahi in
SS& T
Division
GSO HESCO,
at 132 KV
Gird Station
Society
Nawabshah

2. WAPDA Welfare
grant in favour of
Widow and minors
of deceased
(conditional if the
widow re-marriage
amount) will be
seized admissible
Rs.870/-.
3. Group Life
insurance
Rs.1,82,000/-

4. Gratuity
Rs.1,26,194/5. Pension Per
month Rs.919/-

6. 180 days
encashment
Rs.24,529/-.
7. G.P.F A/C
No.190406 of the
deceased as
enquired vide
letter No. 493940/DM/SST/HESC
O/NSH, dated:
28.07.2008, issued
by Deputy Manager
SS & T Divisions
GSO, HESCO
Nawabshah

and 6. While 2
and 5 is due
since the date
of death of
deceased Ali
Khan,
whatsoever till
the accrual of
the amount
along with
interest, if any.
The amount of
S.No.7, is
subject to
furnishing
balance amount
by Director
Accounts
(Funds) WAPDA
House Lahore.

NAWABSHAH.
DATED:

ADVOCATE FOR APPLCIANTS.

IN THE COURT OF DISTRICT JUDGE, SHAHEED BENAZIR ABAD.


Succession Application No. 20

OF 2009.

Mst. Rehana
-------------------------------Applicants
VERSUS
Baby Amna & Others
------------------------------ Opponents.
A F F I D A V I T.
I, Rehana Wd/O Arshad Awan, adult, mulsim, son of Waryam
Khan Pahi, adult, muslim, r/o: Village Malook Khan Pahi, Taluka
Sakrand, District Shaheed Benazir Abad, do hereby state on oath as
under:-

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