Suit for declaration for issuance of legal heir-ship certificate. How to create a suit for declaration before a civil court for obtaining a legal heir-ship certificate /warasatnama. The sample is given below, please make necessary amendments.

Suit for declaration for issuance of legal heirship certificate

Purpose: To declare person/s as legal heirs of deceased through a competent court of law.

IN THE COURT OF SENIOR CIVIL JUDGE, ISLAMABAD

In the matter of:

(Name, parentage, and address of plaintiff)                   ...Plaintiff

Versus

Public at large                                                                      …Defendant

SUIT FOR DECLARATION FOR ISSUANCE OF LEGAL HEIR-SHIP CERTIFICATE

Respectfully Sheweth:-

That the father of the plaintiff namely (name with parentage) died on 25.01.2021. Copy of death certificate is annexed herewith.

That the deceased father of the plaintiff left behind the following legal heirs: -

(give detail/name with the relation of all the legal heirs of the deceased)

That there are no other legal heirs of the deceased except mentioned above legal heirs, as the parents of the deceased also died during the lifetime of the deceased.

That the deceased was the owner in possession of (1) Plot No. 21, measuring 111-11 Sq. Yards and (2) a vehicle registration No. xxxxxx, Engine No. xxxxxxx 5, Chassis No. xxxxx, Suzuki Swift, Model 2014 along with different moveable and immovable properties, which the mentioned above legal heirs are entitled to get their respective shares in the properties left by their deceased predecessor, according to legal shares.

That the plaintiff along with above mentioned legal heirs approached the concerned departments for the transfer of properties in the name of the legal heirs, who are required a legal heir-ship certificate, and in this regard, the plaintiff approached the office of NADRA but the office of NADRA issued declined certificate vide letter No. 10000000001 dated 17.05.2022, hence this suit.

That the cause of action accrued to the plaintiff firstly on 25.03.2021, when the father of the plaintiff died and the same is continuing day by day.

That the cause of action accrued in Islamabad, hence this Hon’able Court has jurisdictions to try and adjudicate upon the matter.

That the value of the suit for the purpose of court fee and jurisdiction is fixed which is exempt from the levy of court fee.

PRAYER

In view of the above circumstances, it is most respectfully prayed that a decree for a declaration to the effect that the above mentioned in para No. 2 of the plaint are legal heirs of the deceased namely Amir Hassan Khan son of Hassan Khan died on 25.01.2021 and there are no other legal heirs of the deceased in any manner whatsoever, may kindly be passed in favor of the plaintiff.

Any other relief that this Hon’ble Court deems fit and proper may also be awarded to the plaintiff.

 

Plaintiff                  Through                 counsel

 

Verification:

Verified on Oath on this 31^st day of May 2022, that the contents of paras No.1 to 5   are true and correct to the best of my knowledge and belief and reaming paras No. 6 to 8 are believed to be true and correct on the basis of information received.

 …Plaintiff