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.
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.
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.
Dear brother Zubair,
ReplyDeleteI 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
Dear Sir,
ReplyDeleteI 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
test
ReplyDelete