Succession Application

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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,

a

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

E

………. Opponents.

C

I

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

E

………. Opponents.

C

I

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 father’s 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

E

C

I

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

E

C

I

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,

a

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

a

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

a

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

a

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

a

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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