PETETION FOR GRANT OF SUCCESSION CERTIFICATE
IN THE COURT
OF DISTRICT & SESSION JUDGE EAST AT KARACHI
(Testamentary & In testate Jurisdiction)
S.M.A. No.
/16
Kamran
Yousuf,
S/O Sultan Aalam Khan,
Muslim,
Adult, R/O House No: B-1,
Block-
11, Gulshan Iqbal,
Karachi. ..………. Petitioner.
Sultan
Aalam Khan
S/O
Mehboob Ali Khan. …… Deceased.
PETETION FOR GRANT OF SUCCESSION CERTIFICATE.
The petitioner above name respectfully submits as under:
1.
That the petitioner is the son & one of legal heirs of above named
- Sultan Aalam Khan S/O Mehboob Ali Khan, after it referred to as said deceased, who was died of natural death on
25-03-2015.
[Copy of Death Certificate & NIC is attached as annexure P, P1]
2.
That the father & mother of the said deceased had already died
during his life time and the said deceased, at the time of his death, had left
behind following legal heirs:
|
S.
|
Name
|
Age
|
Relation
|
|
1
|
Ferhat Nayab Baigum
|
63 years
|
Wife
|
|
2
|
Orangzaib Yousuf
|
44 years
|
Son
|
|
3
|
Kamran Yousuf
|
43 years
|
Son
|
3.
That the said deceased at the time of his death had fixed place of
abode at Flat No; A-107, Decent Garden, Block-7, Gulistan Joher, University
Road, Karachi and also had expired with in jurisdiction of Police Station Gulistan
Joher which is also within jurisdiction of this honorable court.
4.
That no other, except the legal heirs shown at serial No. 01, 02 &
03 of table in Paragraph No; 02, are entitled to inherit the rights/ Claims of
said deceased, according to Sunni Muslim.
5.
That said deceased was the owner / Proprietor of the Company M/S.
Bismillah Telecom and by managing & running, at his own, all affairs of the said company he was
maintaining Bank account No: 14718297,
NIB Bank, University road Branch in which available balance amount is Rs:
97751/= (Ninety Seven Thousand seven hundred & fifty one). …………. Further the
deceased had (interests/ Claims) entitlement for recovery of unpaid amounts of
Rs: 3924364/= (Thirty Nine Lac twenty four thousand and three hundred sixty
four) regarding said company’s projects / works completed at sites of “Wateen
WiMAX (Pvt) Ltd
having office at
“Wateen WiMAX”, Parsa Tower, 6th Floor, Plot # 31-1-A, Block-6, P.E.C.H.S, Main
Shahra-e-Faysal, Karachi and Augere Pakistan (Pvt) Ltd, Having Network under
brand “QUBEE” Pakistan, office at 10th Floor, WTC, Khayaban-e-Roomi,
Clifton, Block-5, Karachi.
[Copies of NTN Certificate, Letter / Request
submitted to bank & its reply showing balance amounts & Copy of Invoice
to Wateen Wimax & reply by Wateen & Augere are attached herewith as P2,
P3, P4, P5, P6 & P7]
6.
That the petitioner claims to be entitled for grant the Succession
certificate to inherit all claims / interests/ amounts / properties as other
surviving legal heirs of said deceased have sworn their respective No Objection
Affidavits in favor of the petitioner.
7.
That petitioner has truly given details of properties left by deceased
in Schedule of Property with valuation and there is no property/credits other
than stated in the Schedule of Property as well as in this plaint.
8.
That no application has been made before any other court for Succession
certificate or letters of administration and no proceedings or suit are pending
for managing of the subject estate property.
9.
That the said deceased died in testate and due and diligence search has
been carried out but nothing is found.
10.
That this application is made bona fidely and the required court fee is
duly paid relating to grant of Succession Certificate.
PRAYER
It is therefore prayed that this honorable court may be pleased to grant Succession Certificate in respect of in respect of company “M/S. Bismillah Telecom’s all
interests, Claims deposits i.e (1) Balance amount Rs: 97751/= (Ninety Seven
Thousand seven hundred & fifty one) available in Bank account No:
14718297, NIB Bank, University road Branch, Karachi (2) entitlement to claim for
interests / unpaid amounts Rs: 3924364/= (Thirty Nine Lac twenty four thousand
and three hundred sixty four) of company
Bismillah Telecom regarding projects / works completed at sites of “Wateen WiMAX (Pvt) Ltd Augere Pakistan (Pvt) Ltd.
Karachi. PETITIONER
Dated:
ADVOCATE
VERIFECATION.
I, Kamran Yousuf S/O Sultan Aalam Khan, Muslim, Adult, R/O House No: B-1, Block-
11, Gulshan Iqbal, Karachi, holding NIC No: 42101-8546116-3, do hereby verify on oath that whatever stated
above is true and correct to the best of my knowledge and belief.
DEPONENT
The deponent above named is identified by me.
ADVOCATE
Solemnly affirmed and stated on oath before me at
Karachi on this 08th day of September, 2016 by the deponent above
named who is identified to me by Mr. Farhan Khaliq Anwer Advocate who is known
to me personally.
COMMISSIONER
FOR TAKING AFFIDAVITS
IN THE COURT
OF DISTRICT & SESSION JUDGE EAST AT KARACHI
(Testamentary & In testate Jurisdiction)
S.M.A. No. /16
Kamran
Yousuf,
S/O
Sultan Aalam Khan,
Muslim,
Adult, R/O House No: B-1,
Block-
11, Gulshan Iqbal,
Karachi. ..………. Petitioner.
Sultan
Aalam Khan
S/O Mehboob Ali Khan. ………. Deceased.
SCHEDULE OF PROPERTIES
|
PARTICULARS
|
VALUED
|
|
Balance amount in Bank account of Bismillah Telecom - No:14718297, NIB Bank, University road
Branch, Karachi
|
Rs: 97751/=
|
|
Entitlement of claim interests / unpaid
amounts of company Bismillah Telecom regarding projects / works completed at
sites of “Wateen WiMAX (Pvt) Ltd Augere
Pakistan (Pvt) Ltd.
|
Rs: 3924364/=
|
Karachi.
Dated:
Advocate for the Petitioner
FOR
IMMIDIATEUSE IN COURT
IN THE COURT
OF DISTRICT & SESSION JUDGE EAST AT KARACHI
(Testamentary & In testate Jurisdiction)
S.M.A. No.
/16
Kamran
Yousuf,
S/O Sultan Aalam Khan,
Muslim,
Adult, R/O House No: B-1,
Block-
11, Gulshan Iqbal,
Karachi. ..………. Petitioner.
Sultan
Aalam Khan
S/O Mehboob Ali Khan. ………. Deceased.
AFFIDAVIT BY PETITIONER
I, Kamran Yousuf S/O Sultan Aalam Khan, Muslim, Adult, R/O House No: B-1, Block-
11, Gulshan Iqbal, Karachi, holding NIC No: 42101-8546116-3, do
hereby state on oath as under:
1.
That I am a son & one of legal heirs of above late Sultan Aalam Khan S/O Mehboob Ali Khan, who has died
of natural death on 25-03-2015. Further I say
that at the time of his death, he had fixed place of abode / at Flat No; A-107, Decent Garden, Block-7, Gulistan
Joher, University Road, Karachi which is within jurisdiction of Police Station
Gulistan Joher and also this place is within jurisdiction of this honorable
court.
2.
That I say that no other, except the legal heirs shown at serial No.
01, 02 & 03, hereunder & in table of Paragraph No; 02 of plaint, is
entitled to inherit the rights/ Claims of late Sultan Aalam Khan S/O Mehboob Ali Khan.
|
S.
|
Name
|
Age
|
Relation
|
|
1
|
Ferhat Nayab Baigum
|
63 years
|
Wife
|
|
2
|
Orangzaib Yousuf
|
44 years
|
Son
|
|
3
|
Kamran Yousuf
|
43 years
|
Son
|
3.
That I say that said deceased was the owner / Proprietor of the Company
M/S. Bismillah Telecom and …………….. by managing & running, at his own, all
affairs of the said company he was maintaining Bank account No: 14718297, NIB Bank, University road
Branch in which available balance amount is Rs: 97751/= (Ninety Seven Thousand
seven hundred & fifty one). …………. Further the deceased had (interests/
Claims) entitlement for recovery of unpaid amounts of Rs: 3924364/= (Thirty
Nine Lac twenty four thousand and three hundred sixty four) regarding said
company’s projects / works completed at sites of “Wateen
WiMAX (Pvt) Ltd
having office at
“Wateen WiMAX”, Parsa Tower, 6th Floor, Plot # 31-1-A, Block-6, P.E.C.H.S, Main
Shahra-e-Faysal, Karachi and Augere Pakistan (Pvt) Ltd, Having Network under
brand “QUBEE” Pakistan, office at 10th Floor, WTC, Khayaban-e-Roomi,
Clifton, Block-5, Karachi.
4.
That all other surviving legal heirs of said deceased have sworn their
respective No Objection Affidavits in my favor.
5.
That I say that I have truly given details of properties left by
deceased in Schedule of Property with valuation and as per my knowledge there
is no property/credits other than stated in the Schedule of Property as well as
in this plaint.
6.
That I say that no application has been made before any other court for
Succession certificate or letters of administration and no proceedings or suit
are pending for managing of the subject estate property.
7.
That I say that said deceased died in testate and due and diligence
search has been carried out but nothing is found.
8.
That I say that the accompanying petition has been
drafted under my instructions and averments enumerated therein as well as in
this affidavit are true and correct to the best of my knowledge and belief.
Karachi.
Dated: DEPONENT
FOR IMMIDIATE USE IN COURT
IN THE COURT
OF DISTRICT & SESSION JUDGE EAST AT KARACHI
(Testamentary & In testate Jurisdiction)
S.M.A. No.
/16
Kamran
Yousuf,
S/O Sultan Aalam Khan,
Muslim,
Adult, R/O House No: B-1,
Block-
11, Gulshan Iqbal,
Karachi. ..………. Petitioner.
Sultan
Aalam Khan
S/O Mehboob Ali Khan. ………. Deceased.
AFFIDAVIT BY LEGAL HEIR -
I, Orangzaib Yousuf S/O Sultan Aalam Khan, Muslim, Adult, R/O Flat No; A-107, Decent Garden,
Block-7, University road, Gulistan Joher, Karachi, holding NIC No: 42101-4861415-5, do
hereby state on oath as under:
1. That I am elder son & one of legal heirs of
above late Sultan Aalam Khan S/O Mehboob Ali Khan, who has died
of natural death on 25-03-2015. Further I say
that at the time of his death, he had fixed place of abode / at Flat No; A-107, Decent Garden, Block-7,
Gulistan Joher, University Road, Karachi which is within jurisdiction of Police
Station Gulistan Joher and also this place is within jurisdiction of this
honorable court.
2. That I say that no other, except the legal heirs
shown at serial No. 01, 02 & 03, hereunder & in table of Paragraph No;
02 of plaint, is entitled to inherit the rights/ Claims of late Sultan Aalam Khan S/O Mehboob Ali Khan.
|
S.
|
Name
|
Age
|
Relation
|
|
1
|
Ferhat
Nayab Baigum
|
63
years
|
Wife
|
|
2
|
Orangzaib
Yousuf
|
44
years
|
Son
|
|
3
|
Kamran
Yousuf
|
43
years
|
Son
|
3.
That I say that said deceased was the owner / Proprietor of the Company
M/S. Bismillah Telecom and …………….. by managing & running, at his own, all
affairs of the said company he was maintaining Bank account No: 14718297, NIB Bank, University road
Branch in which available balance amount is Rs: 97751/= (Ninety Seven Thousand
seven hundred & fifty one). …………. Further the deceased had (interests/
Claims) entitlement for recovery of unpaid amounts of Rs: 3924364/= (Thirty
Nine Lac twenty four thousand and three hundred sixty four) regarding said
company’s projects / works completed at sites of “Wateen
WiMAX (Pvt) Ltd
having office at
“Wateen WiMAX”, Parsa Tower, 6th Floor, Plot # 31-1-A, Block-6, P.E.C.H.S, Main
Shahra-e-Faysal, Karachi and Augere Pakistan (Pvt) Ltd, Having Network under
brand “QUBEE” Pakistan, office at 10th Floor, WTC, Khayaban-e-Roomi,
Clifton, Block-5, Karachi.
4.
That Isay that I have no objection if subject petition is granted in
favor of my younger brother / petitioner.
5.
That I say that the details of properties left by deceased in Schedule
of Property with valuation are truly given and as per my knowledge there is no
property/credits other than stated in the Schedule of Property as well as in
this plaint.
6.
That I say that no application has been made before any other court for
Succession certificate or letters of administration and no proceedings or suit
are pending for managing of the subject estate property.
7.
That I say that said deceased died in testate and due and diligence
search has been carried out but nothing is found.
8.
That I say that the accompanying petition has been
drafted under my instructions and averments enumerated therein as well as in
this affidavit are true and correct to the best of my knowledge and belief.
Karachi.
Dated: DEPONENT
FOR IMMIDIATE USE IN COURT
IN THE COURT
OF DISTRICT & SESSION JUDGE EAST AT KARACHI
(Testamentary & In testate Jurisdiction)
S.M.A. No.
/16
Kamran
Yousuf,
S/O Sultan Aalam Khan,
Muslim,
Adult, R/O House No: B-1,
Block-
11, Gulshan Iqbal,
Karachi. ..………. Petitioner.
Sultan
Aalam Khan
S/O Mehboob
Ali Khan. ………. Deceased.
AFFIDAVIT BY LEGAL HEIR -
I, Farhat Nayab Baigum Wd/O Sultan Aalam Khan, Muslim, Adult, R/O Flat No; A-107, Decent
Garden, Block-7, University road, Gulistan Joher, Karachi, holding NIC No:
42101-6349658-4, do
hereby state on oath as under:
1. That I am widow & one of legal heirs of above
late Sultan Aalam Khan S/O Mehboob Ali Khan, who has died
of natural death on 25-03-2015. Further I say
that at the time of his death, he had fixed place of abode / at Flat No; A-107, Decent Garden, Block-7,
Gulistan Joher, University Road, Karachi which is within jurisdiction of Police
Station Gulistan Joher and also this place is within jurisdiction of this
honorable court.
2. That I say that no other, except the legal heirs
shown at serial No. 01, 02 & 03, hereunder & in table of Paragraph No;
02 of plaint, is entitled to inherit the rights/ Claims of late Sultan Aalam Khan S/O Mehboob Ali Khan.
|
S.
|
Name
|
Age
|
Relation
|
|
1
|
Ferhat
Nayab Baigum
|
63
years
|
Wife
|
|
2
|
Orangzaib
Yousuf
|
44
years
|
Son
|
|
3
|
Kamran
Yousuf
|
43
years
|
Son
|
3.
That I say that said deceased was the owner / Proprietor of the Company
M/S. Bismillah Telecom and …………….. by managing & running, at his own, all
affairs of the said company he was maintaining Bank account No: 14718297, NIB Bank, University road
Branch in which available balance amount is Rs: 97751/= (Ninety Seven Thousand
seven hundred & fifty one). …………. Further the deceased had (interests/
Claims) entitlement for recovery of unpaid amounts of Rs: 3924364/= (Thirty
Nine Lac twenty four thousand and three hundred sixty four) regarding said
company’s projects / works completed at sites of “Wateen
WiMAX (Pvt) Ltd
having office at
“Wateen WiMAX”, Parsa Tower, 6th Floor, Plot # 31-1-A, Block-6, P.E.C.H.S, Main
Shahra-e-Faysal, Karachi and Augere Pakistan (Pvt) Ltd, Having Network under
brand “QUBEE” Pakistan, office at 10th Floor, WTC, Khayaban-e-Roomi,
Clifton, Block-5, Karachi.
4.
That Isay that I have no objection if subject petition is granted in
favor of my younger son / petitioner.
5.
That I say that the details of properties left by deceased in Schedule
of Property with valuation are truly given and as per my knowledge there is no
property/credits other than stated in the Schedule of Property as well as in
this plaint.
6.
That I say that no application has been made before any other court for
Succession certificate or letters of administration and no proceedings or suit
are pending for managing of the subject estate property.
7.
That I say that said deceased died in testate and due and diligence
search has been carried out but nothing is found.
8.
That I say that the accompanying petition has been
drafted under my instructions and averments enumerated therein as well as in
this affidavit are true and correct to the best of my knowledge and belief.
Karachi.
Dated: DEPONENT
FOR IMMEDIATE USE IN COURT
IN THE COURT
OF DISTRICT & SESSION JUDGE EAST AT KARACHI
(Testamentary & In testate Jurisdiction)
S.M.A. No.
/16
Kamran
Yousuf,
S/O Sultan Aalam Khan,
Muslim,
Adult, R/O House No: B-1,
Block-
11, Gulshan Iqbal,
Karachi. ..………. Petitioner.
Sultan
Aalam Khan
S/O Mehboob
Ali Khan. ………. Deceased.
AFFIDAVIT BY WITNESS: 01
I, Khalid Quddus S/O Abdul Quddus, Muslim, Adult, R/O
House No: C- 173, Block-9, Gulshan Iqbal, Karachi, holding NIC No: 42201-
0296547-7, do hereby state on
oath as under::
1.
That I say that I am witness as well as deponent
of this affidavit as such I am well conversant with the facts of case.
2.
That I say that I know all legal heirs of late Sultan Aalam Khan S/O Mehboob Ali Khan, who has died
of natural death on 25-03-2015. Further I say
that at the time of his death, he had fixed place of abode / at Flat No; A-107, Decent Garden, Block-7,
Gulistan Joher, University Road, Karachi which is within jurisdiction of Police
Station Gulistan Joher and also this place is within jurisdiction of this
honorable court.
3. That I say that, I know to the best of my
knowledge & belief, no other, except the legal heirs shown at serial No.
01, 02 & 03, hereunder & in table of Paragraph No; 02 of plaint, is
entitled to inherit the rights/ Claims of late Sultan Aalam Khan S/O Mehboob Ali Khan.
|
S.
|
Name
|
Age
|
Relation
|
|
1
|
Ferhat
Nayab Baigum
|
63
years
|
Wife
|
|
2
|
Orangzaib
Yousuf
|
44
years
|
Son
|
|
3
|
Kamran
Yousuf
|
43
years
|
Son
|
4.
That I say that said deceased was the owner / Proprietor of the Company
M/S. Bismillah Telecom.
5.
That I say that whatever stated above is true
& correct to the best of my knowledge and belief.
Karachi.
Dated: DEPONENT
FOR IMMIDIATE
USE IN COURT
IN THE COURT
OF DISTRICT & SESSION JUDGE EAST AT KARACHI
(Testamentary & In testate Jurisdiction)
S.M.A. No. /16
Kamran
Yousuf,
S/O Sultan Aalam Khan,
Muslim,
Adult, R/O House No: B-1,
Block-
11, Gulshan Iqbal,
Karachi. ..………. Petitioner.
Sultan
Aalam Khan
S/O Mehboob
Ali Khan. ………. Deceased.
AFFIDAVIT BY WITNESS: 02
I,
_______________________________________,
Muslim, Adult, R/O_________________________________________, holding NIC No:
____________________, do hereby
state on oath as under::
1.
That I say that I am witness as well as deponent
of this affidavit as such I am well conversant with the facts of case.
2.
That I say that I know all legal heirs of late Sultan Aalam Khan S/O Mehboob Ali Khan, who has died
of natural death on 25-03-2015. Further I say
that at the time of his death, he had fixed place of abode / at Flat No; A-107, Decent Garden, Block-7,
Gulistan Joher, University Road, Karachi which is within jurisdiction of Police
Station Gulistan Joher and also this place is within jurisdiction of this
honorable court.
3. That I say that, I know to the best of my
knowledge & belief, no other, except the legal heirs shown at serial No.
01, 02 & 03, hereunder & in table of Paragraph No; 02 of plaint, is
entitled to inherit the rights/ Claims of late Sultan Aalam Khan S/O Mehboob Ali Khan.
|
S.
|
Name
|
Age
|
Relation
|
|
1
|
Ferhat
Nayab Baigum
|
63
years
|
Wife
|
|
2
|
Orangzaib
Yousuf
|
44
years
|
Son
|
|
3
|
Kamran
Yousuf
|
43
years
|
Son
|
4.
That I say that said deceased was the owner / Proprietor of the Company
M/S. Bismillah Telecom.
5. That I say that whatever stated above is true
& correct to the best of my knowledge and belief.
Karachi.
Dated: DEPONENT
Comments
Post a Comment