Thursday, September 6, 2012

Application U/R. 110 Sindh Chief Court Ruled


IN THE HIGH COURT OF SINDH
AT KARACHI

Civil Suit #          /2011

Butt            ……………....…………….…………...…                  Plaintiff

                                                VERSUS

Mohammad        ………….………………………           Defendant

 

APPLICATION UNDER RULE 110
SINDH CHIEF COURT RULES


On consideration of facts and grounds disclosed in the accompanying affidavit as well as in the memo of plaint, it is most respectfully prayed on behalf of the plaintiff above named that this Honorable Court may be pleased to treat this matter as urgent motion and hear the injunction application on   .01.2012, as the defendant has refused to receive the balance amount of Rs.5,00,000/- and execute sale deed as per sale agreement dated 03.01.2011. The defendant has already received Rs.20,00,000/- from the plaintiff.  on 24.05.2007, it borne out that he malafidely is going to sell the said plot to some body else on higher rates. In such circumstances, there is sever apprehension that if immediately restraining order is not passed against the defendant, the possibility can not be ruled out that the plaintiff shall suffer an irreparable loss.


Karachi.                                           Advocate for the plaintiff
Dated:31-12-2011     



For Immediate Use Only 


IN THE HIGH COURT OF SINDH
AT KARACHI

Civil Suit #          /2011


Butt            ……………....…………….…………...…                  Plaintiff

                                                VERSUS

Mohammad        ………….………………………           Defendant
 
A F F I D A V I T

I, Butt S/o.   , Muslim adult, resident of karachi do hereby state on oath as under:-


1.         That I am plaintiff in the above matter, as such am fully conversant with the facts thereof. The accompanying application under Rule 110 Sindh Chief Court Rules has been drafted and filed by my counsel under my specific instructions, contents therein are true and correct.

2.       That for the seek of brevity, I adopt the contents of accompanying application as well as the contents of the plaint as an integral part and parcel of this affidavit and  do not repeat the same in order to avoid duplication.

3.       That I shall be seriously prejudiced and shall suffer an irreparable loss, until       accompanying application is allowed.


4.       That whatever stated above is true and correct to the best of my knowledge information and belief.


Karachi     
Dated: 31-12-2011.                                              DEPONENT.

                        Identified by me.

 Advocate.
Stated on oath before me by the deponent at Karachi, on this 31th day of Dec, 2011, the deponent was identified to me by Mr. S M Zubair, Advocate, who is personally known to me.

Commissioner for taking affidavit.


3 comments:

  1. Dear brother Zubair,
    I am deeply impressed with your specimen of urgent motion. Have you published specimens of petitions, suits and other legal documents. If so please do let me know. Thanks and regards.
    Yours sincerely,
    Rap Abdul Tauheed Khan

    ReplyDelete
  2. Dear Sir,

    I have filed rejoinder in 2nd civil appeal at High Court. Can you please guide me which rule will be submitted for hearing of above rejoinder

    ReplyDelete