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APPEAL AGAINST THE ORDER

Posted by Mumtaz Yousaf


Date: November 19, 2016
in: Legal Drafts
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IN THE COURT OF LEARNED DISTRICT & SESSIONS JUDGE


ISLAMABAD
Mr. _____ D/o _____R/o ________, Islamabad.

…APPELLANT

VERSUS

Mr. _______S/o _______R/o ______, Islamabad.

…RESPONDENT

APPEAL AGAINST THE ORDER DATED _____ PASSED BY


______,LEARNED FAMILY JUDGE, ISLAMABAD.

RESPECTFULLY SHEWETH:-

1. That the appellant filed a suit for dissolution of marriage on basis of khulla before
________, Learned Civil Judge/Judge Family Court/Guardian Judge Islamabad which
was decreed in favour of the appellant on _____. (Copy of the order is enclosed herewith
as Annexure “A”).

2. That the respondent filed the execution petition before _______, Learned Civil
Judge/Judge Family Court/Guardian Judge Islamabad on _____ whereby the respondent
requested the court for the return of the dower given to the appellant in shape of gold
ornaments at the time of Nikah.

3. That on ______the appellant filed the objection petition before _______, Learned Civil
Judge, Islamabad and respondent submitted their reply _______. That on _____ through a
single Order the Learned Civil Judge disposed off the objection petition and framed the
issues.
4. That after framing of issues the appellant and respondent got recorded their evidence
before ______Civil Judge 1st Class/ Judge Family Islamabad.

5. That on _______ Learned Civil Judge 1st Class/Family Judge Islamabad has accepted the
execution petition and objection petition is turned down (Copy of the order dated
______is enclosed herewith as Annexure “B”)

6. That if the appeal is not accepted, the appellant will suffer an irreparable loss.

GROUNDS:-

 That the learned judge has not applied the mind judicially.

 That impugned order has been passed by misreading and non-reading of the facts, record
and documents produced by the Appellant.

 That the impugned order is not found on cogent reasons. It is based on conjectures and
surmises.

 That the impugned order contained a patent irregularity and against the law which is
liable to be set aside.

 That the impugned order is against the law and facts of the case which are liable to be set
aside.

 That if impugned order is not set aside, the appellant will suffer an irreparable loss.

PRAYER:-

It is, therefore, respectfully prayed that the appeal may please be accepted and impugned order
dated ______be set aside, in the best interest of justice.

Any other relief which this Honorable Court deem fit and proper may also be awarded in favor
of the appellant.

APPELLANT

THROUGH
Advocate

IN THE COURT OF LEARNED DISTRICT & SESSIONS JUDGE


ISLAMABAD

Mst______ Vs. Mr. ______

APPEAL AGAINST THE ORDER DATED ______ PASSED BY


_______,LEARNED FAMILY JUDGE, ISLAMABAD.
APPLICATION FOR GRANT OF INTERIM RELIEF AND SUSPENSION OF
IMPUGNED ORDER DATED _______.

RESPECTFULLY SHEWETH:-

1. That the petitioner has filed the above captioned appeal before this Honourable Court, the
contents of which may kindly be read as integral part of this application.

2. That the petitioner has brought a good prima facie case and there is likely hood to
succeed it.

3. That balance of convenience lies in favour of the appellant.

4. That if the application for grant of interim injunction is not accepted, the appellant will
suffer an irreparable loss.

It is, therefore, respectfully prayed that the operation of the impugned order dated
_______may very graciously be suspended till the final decision of the appeal.

APPELLANT

Through

Advocate
IN THE COURT OF LEARNED DISTRICT & SESSIONS JUDGE
ISLAMABAD
Mst______ Vs. Mr. ______

APPEAL AGAINST THE ORDER DATED ____ PASSED BY


____,LEARNED FAMILY JUDGE, ISLAMABAD.
APPLICATION FOR GRANT OF INTERIM RELIEF AND SUSPENSION OF
IMPUGNED ORDER DATED _______.

AFFIDAVIT

I, _____ D/o ______ R/o ______, Islamabad, do hereby solemnly affirm and declare as under:

1. That the deponent has filed the above-mentioned application in this Honourable Court,
the contents of the said application are true and correct to the best of my knowledge and
belief.

2. That the contents of this affidavit are correct and true to the best of my knowledge and
belief and nothing has been concealed thereof.

DEPONENT

IN THE COURT OF LEARNED DISTRICT & SESSIONS JUDGE


ISLAMABAD
Mst______ Vs. Mr. ______

APPEAL AGAINST THE ORDER DATED ______ PASSED BY


____,LEARNED FAMILY JUDGE, ISLAMABAD.
APPLICATION FOR GRANT OF INTERIM RELIEF AND SUSPENSION OF
IMPUGNED ORDER DATED _______.

CERTIFICATE

It is certified that as per the information imparted to me by appellant, this is the first appeal being
moved on the captioned subject before this Honorable Court.

1. That the instant appeal has been filed on the instructions of the appellant.

2. That there is no appeal is pending adjudication in any court.

APPELLANT

Through Counsel

Advocate