Plaint seeking declaration of title over immovable property with consequential relief of permanent injunction restraining alienation or dispossession.
When to use this draft
Use where the plaintiff is in possession, claims ownership, and a cloud has been cast on title by a forged mutation, fake sale deed or an adverse claim.
Essential contents
- Full description of the property with khasra / khewat numbers
- Basis of title - sale deed, inheritance, gift, allotment
- Details of the disputed document sought to be declared void
- Consequential relief where possession is not with the plaintiff
- Court fee under the Court Fees Act as per valuation
- Notice under Section 80 CPC if a government body is a defendant
Drafting notes
- Where possession is lost, a bare declaration is not maintainable - add a prayer for possession.
- Annex a certified copy of the jamabandi and the impugned mutation.
- Plead the date of knowledge of the fraud - limitation runs from that date.
- File an application under Order XXXIX Rules 1 & 2 CPC along with the plaint.
Adapt before filing
This is a structural template, not advice on your matter. Facts, dates, valuation, jurisdiction and the prayer must be settled by a lawyer licensed to practise in Pakistan.