In the court of senior civil judge mianwali
Akbar hyat vs 1.province of Punjab through dc mianwali 2.Tehsildar circle moza dhibba
3.Girdawar circle 4.Patwari circle 5.Farzana Shaheen 6.Yasmeen bibi
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Suit for declaration that plaintiff is owner of land measuring 38k-11m, khewat no 23,24,27,28
according to periodical record of year 2019-20. Mutation no 4325 dated 5/5/2015 is againt the law
and fact and based on the fraud. Muhammad Afzal, sonar Khatoon ,anwar kahtoon d/o mehr khan
never transferred their owned land measuring 38k-11m through mutation mentioned in the the
favors of plaintiff no 5,6 .all the proceeding regarding mutation through the conivence of defendant
no 2,3,,4,5 by to deprive the plaintiff/legal heirs from inheritance.therefor the mutation no 4325
dated 5/5/2015 is able to set aside and not followable/bound by legal heir.with permanent
injunction that defendants to be ordered not interference in suit property not same not be
transferred to anyone forever.
Respectfully sheweth that,
1. That the suit property whose details is mentioned in title of the suit above is under
ownership of Muhammad Afzal s/o mehr khan,anwar kahtoon and sonar kahtoon d/o mehr
khan and plaintiff is real nephew of the same and legal heir.muation no 4325 dated 5/5/15 is
against the law and fact and based on the fraud and result of the conivence of defendant 2
to 6.Muhammad afazal never transferred the land mentioned in the favour of defendant 5
and 6 and same is just to deprive the legal herirs from inheritance.
2. That Muhammad Afzal ,anwar kahtoon and sonar kahtoon are illetrates and mentally
disabled persons.muhammad Afzal died on 25/6/23 and plaintiff when start working for the
transfer of deceased inheritance and defendant no 5 and 6 filed application for partition of
above mentioned land then plaintiff got the knowledge of above mentioned forged and
fectitious mutation that why suit is in time from the date of knowledge and same is liable to
be set aside and not binding on the plaintiff/legal heirs.
3. That regusted the defendants that set aside the above mentioned mutation and transfer the
land owned by muhammaad Afzal deceased through inheritance but defendant denied
hence this suit.
4. That the cause of action occurred on the last denial of defendants before few days agao.
5. That suit land is situated at mianwali that why court has jurisdiction.
6. That suit is exempted from court fee.
prayer
It humbly prayed that above titled suit be decreed in the favour of
Plaintiff and against the defendant.
Plaintiff
Through counsel
