Speciman, draft of Complaint Against Illegal Confiscation of Inherited Property and Request for Enforcement of Legal Rights under Women’s Property Rights Protection Act

Before the Honorable Federal Ombudsman
(For Protection Against Harassment of Women at the Workplace & Women’s Property Rights)
Islamabad

Complainant:
[Complainant’s Full Name]
[CNIC No.]
[Address]
[Contact No.]

1. [Names of Deceased Husband’s Family Members] — (Illegal Occupants)
2. Deputy Commissioner, Islamabad — (Responsible for enforcement of property rights)
3. Chairman, Capital Development Authority (CDA), Islamabad — (For land regulation and property transfer compliance)

…Respondents

Subject: Complaint Against Illegal Confiscation of Inherited Property and Request for Enforcement of Legal Rights under Women’s Property Rights Protection Act

Facts of the Case:

1. That the Complainant is the lawful widow of [Deceased Husband’s Full Name] (hereinafter referred to as the “Deceased”), who passed away on [Date of Death].
2. That upon the death of the Deceased, the Complainant and her lawful children became rightful heirs to the properties left behind, in accordance with Islamic law and the relevant legal framework.
3. That the family members of the Deceased, in blatant violation of the Complainant’s legal rights, have fraudulently confiscated all movable and immovable properties left behind, depriving the Complainant and her children of their lawful inheritance.
4. That despite repeated verbal and written requests made by the Complainant to the Respondents and relevant authorities, no action has been taken, leaving the Complainant vulnerable and deprived of her legal rights.
5. That the Deputy Commissioner Islamabad and the Capital Development Authority (CDA) are legally bound to ensure the protection of women’s property rights but have failed to take action against the illegal occupants.

Details of Confiscated Property:

1. Plot No. [X], Sector [Y], Islamabad — Residential Plot
2. House No. [A], Street [B], Sector [C], Islamabad — Family House
3. Agricultural Land: Khasra No. [XYZ], Area [Acres/Canals], Islamabad
4. Any other movable/immovable properties as per records

Legal Grounds:

1. Violation of the Enforcement of Women’s Property Rights Act, 2020.
2. Breach of Constitutional rights under Articles 23 & 24 (Right to Property) of the Constitution of Pakistan.
3. Failure of the Deputy Commissioner and CDA to fulfill statutory duties regarding property rights enforcement.

Prayer:

In light of the above, the Complainant respectfully prays that this Honorable Office may:

1. Direct the Deputy Commissioner Islamabad and CDA to immediately take legal action to recover and restore the confiscated properties.
2. Initiate proceedings against those responsible for fraudulent confiscation.
3. Ensure the enforcement of the Complainant’s lawful rights as per the Enforcement of Women’s Property Rights Act, 2020.
4. Provide any other relief deemed appropriate by this Honorable Forum.

Date: [Insert Date]
Place: Islamabad

Complainant’s Signature:

through

Asadullah Hassan Hashmi

LLB Hons.(UOS)

LLM-ITL(Medalist)

Advocate High Court