SUIT FOR PARTITION AND SEPARATE POSSESSION
IN THE COURT OF SENIOR CIVIL JUDGE,
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District.
Plaintiff.
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District.
Defendant.
SUIT FOR PARTITION AND SEPARATE POSSESSION.
1. That the father of the plaintiff and defendant died on 03-04-2005. The copy of death certificate is attached with this suit.
2. The deceased father left behind a two story house situated at Model Town Lahore.
3. That the plaintiff and the defendant are brothers and sisters and they are the only legal heirs of the deceased father and there is no other legal heir or claimant of the said property.
4. That since the death of the deceased father of the plaintiff and the defendant the defendant ----------------------------- has occupied the house left by the deceased father of the plaintiff and the defendant and he does not admit the claim of the plaintiff tobe the equal and joint sharer ofthe said property.
5. That repeated demands were made by the plaintiff to the the defendant for the partition of the said house but the defendant flatly refused to do the needful, hence this suit.
6. That the cause of action arose firstly on 05-15-2006 when the father of the plaintiff and defendant died, secondly and finally a weed ago when the defendant flatly refused to divide the joint estate of the plaintiff and the defendant into two equal parts.
7. That since plaintiff and defendant are residing in Lahore and the disputed property is situated at Lahore therefore Civil Courts of Lahore have the jurisdiction to try this suit.
8. That the valuation of the suit for the purposes of court fee and jurisdiction is Rs. 4000/- therefore, no Court fee has to be affixed on the subject plaint.
In view of the above it is respectfully prayed as under:
PRAYERS:
A decree for partition of the joint estate of the plaintiff and defendant may kindly be passed by dividing estate into two equal parts.
Heavy costs may also be awarded to the plaintiff.
Any other relief deemed possible by the Honorable Court may also be granted.
Plaintiff.
Through Counsel,
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VERIFICATION:
Verified on Oath at -----------------on this 4th day of March 2006 that the contents of paras 1 to 5 are correct to the best of my knowledge and remaining of paras 6,7 and 8 are true to the best of my information and belief.
Plaintiff.
COMMENTS