IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE.

Civil Suit No._______________/2018

1. ASIM IQBAL BUTT SON OF MUHAMMAD IQBAL BUTT

RESIDENT OF HOUSE NO.50/1, STREET NO.1 CAVLARY
GROUND, LAHORE CANTT.

2. KASHIF IQBAL BUTT SON OF MUHAMMAD IQBAL BUTT

RESIDENT OF HOUSE NO.17, STREET NO.7, ASIF BLOCK,
ALLAMA IQBAL TOWN, LAHORE.

3. MST. SAMRA MAJEED BUTT DAUGHTER OF MUHAMMAD

IQBAL BUTT RESIDENT OF HOUSE NO.P-46, NEAR MUGHAL
BAZAR, EX-WARD NO.4, SAMUNDARI DISTRICT FAISALABAD.

4. MST. SHAZIA SOHAIL DAUGHTER OF MUHAMMAD IQBAL

BUTT RESIDENT OF HOUSE NO.19 STREET NO.19, ANWAR
STREET, ISLAMIA PARK, POONCH ROAD, LAHORE.

……Plaintiffs
Versus

1. PUBLIC-AT-LARGE.

2. OLYMPIANS COOPERATIVE HOUSING SOCIETY LTD.

OFFICE AT RAKH JEHDU, KAHNA NAU, LAHORE THROUGH
ITS SECRETARY.
……Defendants

-: SUIT FOR DECLARATION WITH CONSEQUENTIAL RELIEF :-

Respectfully Sheweth:-

1. That the names and addresses of the parties as mentioned in the head

note of the suit for the purposes of the summons and notices are

correct and sufficient.

2. That brief facts giving rise to the institution of the titled suit are that

Muhammad Iqbal Butt (deceased) father of the plaintiffs was died on

 14.01.2004 leaving behind the plaintiffs being his only surviving legal

heirs and successor–in –interest. Needless to say that Mst. Saeeda

Akhtar mother of the plaintiffs and wife of the deceased Muhammad

Iqbal Butt has already passed away on 04.09.1996. (Copies of death

certificates of both the deceased are attached herewith)

3. That Muhammad Iqbal Butt (deceased) the predecessor of the

plaintiffs was exclusive owner in possession of plot No.118 Block A

situated at Olympians Cooperative Housing Society Ltd. (hereinafter

referred to as suit property) through Allotment Letter of the defendant

No.2 Society.(Copy attached)

4. That after sad demise of the predecessor of the plaintiffs the legacy of

in the shape of the suit property was inherited which they are enjoyed

till date. There is no other legal heir of the deceased except the

plaintiffs. Presently the situation which necessitated the formal

transfer of the suit property in the names of the plaintiffs, therefore,

the plaintiffs approached defendant No.2 for transfer of ownership of

the suit property in the names of the plaintiffs against the name of

Muhammad Iqbal Butt (deceased) but the officials/officers of

defendant No.2 denied this request rather directed them to get a

declaratory decree from the learned Civil Court, Lahore.

5. That under the circumstances, the plaintiffs have left with no other

option but to invoke the jurisdiction of this honorable Court for

redressal of their grievance.

6. That the cause of action firstly arose in favour of the plaintiffs and

against the defendants with sad demise of the predecessor of the

plaintiffs i.e. Muhammad Iqbal Butt, subsequently with the refusal of

defendant No.2 and other concerned authorities to transfer the suit

 property in the names of the plaintiffs without the decree of this

Honorable Court and the cause of action is still continuing.

7. That the suit property situated with the territorial jurisdiction of

Lahore, the cause of action has arose at Lahore, therefore, this

honorable court has got jurisdiction to adjudicate upon the matter.

8. That the valuation of the suit property for the purposes of Court fee

and jurisdiction is fixed as Rs. 200/ which is exempted from the

payment of court fee under the law.

Under the above mentioned circumstances, it is respectfully

prayed that a decree for declaration may kindly be passed in favour

of the plaintiffs and against the defendants declaring the plaintiffs

are the only surviving legal heirs and successor- in- interest of the

deceased Muhammad Iqbal Butt and the plaintiffs are entitled to

inherent the suit property as per their legal and sharai share, owned

by the deceased.

As a consequential relief, the defendant No.2 and other

concerned authorities may kindly be directed to enter the names of

the plaintiffs in its record as being the successor-in-interest of the

deceased and to transfer the suit property the names of the plaintiffs

in accordance with their respective shares.

Any other relief which this honorable court deems fit and

appropriate may also granted.

Plaintiffs
Through
 Muhammad Faizan Saleem
Advocate High Court
SALEEM LAW ASSOCIATES/CO.
Office at 33-A, Upper Mall, Lahore.

Verification:-
Verified on oath at Lahore on this 17 th day of September, 2018 that the
contents of the above Para No.1 to 5 are true and correct to the best of my
knowledge and rest of the paras No. 6 to 8 are correct and true to the best of
my knowledge and belief.

Plaintiffs