Civil Suit
Purpose: To seek a decree for getting a death certificate from the concerned union council.
Forum: Civil
Court
Title/Parties: Aggrieved person/plaintiff vs concerned union
council.
SUIT FOR
DECLARATION TO THE EFFECT THAT MRS. RUBBISH /GRANDMOTHER OF PLAINTIFF DIED ON
10.09.2015, AND FOR MANDATORY INJUNCTION
TO SEEK DIRECTION FOR THE CONCERNED UNION COUNCIL FOR ISSUANCE OF DEATH CERTIFICATE
Respectfully Sheweth:-
That the plaintiff is a law-abiding citizen
of the country and residing at the mentioned above address.
That the grandmother of the plaintiff namely
Mrs. Robish wife of Muhammad Ashraf died on 18.09.2016 in the area of Union
Council No. 7, Tehsil Lalieshan, District Layyah.
That the plaintiff is in aboard Hong Kong
and the father of the plaintiff and son of deceased Mrs. Robish (grandmother of
plaintiff) already died prior to the death of the grandmother of the plaintiff,
therefore, the plaintiff could not enter the death of his grandmother in
concerned Union Council/ defendant office due to lack of knowledge as well as a
shortage of time.
That when the plaintiff required the death
certificate of his grandmother from the concerned union council, it came to the
knowledge of the plaintiff that her date of death was not entered/registered in
the concerned union council’s record.
Thereafter, the plaintiff moved an
application before the defendant’s office but the concerned authority directed
to the plaintiff to approach the competent court of law, hence this suit.
That the cause of action firstly accrued a
few days ago when the defendant’s office refused to accede to the genuine
request of the plaintiff which is continuing day by day.
That the cause of action accrued to the
plaintiff in herein Layyah and the office of the defendant is also situated within
the territorial jurisdiction of this Hon’ble court, hence this Hon’able Court may
entertain and adjudicate upon the matter.
That the value for purpose of jurisdiction
and court fee is fixed Rs.15,000/-, hence plaint exempted from the levy of
court fee.
PRAYER:
In these circumstances, it is, therefore,
most respectfully prayed that a decree for the declaration to the effect that
the grandmother of plaintiff Mrs. Robish wife of Muhammad Ashraf died on 18.09.2016
in Union Council No. 7, Tehsil Laliehsan & District Layyah and a decree for
mandatory injunction by giving direction to the defendant to register/enter the
date of death in the record of union council and issue a death certificate in favor
of the plaintiff, may kindly be passed in favour of the plaintiff, in the
interest of justice.
Plaintiff through
counsel
Verification:
Verified on Oath 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
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