Draft/Specimen/Format:

(i) Application under order 6 rule 17 CPC for amendment in pleadings/Plaint

(ii) Application under Order 7 Rule 11 for Rejection of plaint

(iii) Application under Order 1 Rule 10 for impleading as party

(iv) Application under order 39(1)(2) Cpc for grant of temporary injunction.

4 Applications in 1 post

IN THE COURT OF MR. ____________,

LEARNED CIVIL JUDGE, LAHORE.

IN RE:

___________ V E R S U S __________

A P P L I C A T I O N ON BEHALF OF THE PLAINTIFF/APPLICANT UNDER ORDER 6 RULE 17 C.P.C. FOR

AMENDMENT IN PLAINT.

Respectfully Sheweth:

1. That titled civil suit is pending for adjudication before this Learned Court for today i.e. ____.

2. That through the instant application, the applicant humbly seeks indulgence of this Learned Court for
seeking permission to amend Clause I of paragraph No. 4 of the plaint; proposed amendment is as
following:

“It is pertinent to mention here that the defendant at various occasions demanded huge amount of
money from the plaintiff. Because the plaintiff had always been earning much more than the defendant
as she was working in a higher scale, therefore, she had always fulfilled his demands and gave him a
huge amount of money when the marriage was intact and she is also entitled to file a separate suit for
recovery of said amount.”

3. That inadvertently, aforesaid fact i.e. proposed amendment could not be added in the plaint,
therefore, permission is sought from this Learned Court for amendment of plaint as stated above inter-
alia on the following:

GROUNDS

i. That the aforesaid proposed amendment is not inconsistent with the original version of the
applicant taken in the plaint.
ii. That the omission to mention the sentence stated above as proposed amendment was
neither intentional nor deliberate rather it was inadvertently not mentioned.

iii. That the proposed amendment goes to the root of the case and in order to determine the real
question in controversy by this Learned Court, it is necessary that proposed amendment may be
allowed.

v. That if the applicant is not allowed to amend her plaint as proposed above, irreparable loss will be
suffered by her.

vi. That applicant humbly seeks permission of this Learned Court to raise additional grounds at the stage
of arguments.

PRAYER

In aforementioned circumstances, it is humbly prayed that applicant in hand may kindly be accepted &
the applicant may graciously be allowed to amend her plaint as stated above.

APPLICANT

THROUGH

ZEESHAN AHMAD MALIK

Advocate High Court

“THE LEGAL MENTORS”

66/3, Hajvery Complex, 2-Mozang Road, Lahore.

Format/Draft/Specimen:

Application under order 7 Rule 11 CPC for rejection of plaint.

IN THE COURT OF MR. _____LEARNED CIVIL JUDGE, LAHORE.

In Re:

_________ V E R S U S ______

A P P L I C A T I O N ON BEHALF OF DEFENDANT NO.1 UNDER ORDER 7 RULE 11 C.P.C. FOR REJECTION OF

THE PLAINT.

Respectfully Sheweth:

1. That titled civil suit is pending for adjudication before this Learned Court for today i.e. ____.

2. That the plaintiff/respondent has filed titled civil suit for Specific Performance on the grounds that
property No. 367/34, k-6, Phase-VI, DHA was purchased by the plaintiff/respondent from the
applicant/Defendant No. 1.

3. That through the instant application, the applicant humbly seeks indulgence of this Learned Court for
rejection of the plaint inter-alia on the following:

GROUNDS

i. That a bare perusal of plaint reveals that the plaintiff/respondent has miserably failed to
disclose any cause of action.
ii. That no agreement to sell whatsoever was ever executed between the applicant/defendant
No. 1 and the plaintiff.
iii. That the plaintiff has not appended requisite court fee along with the plaint; hence, plaint
merits rejection on the score along.

iv. That the plaint is barred by law; hence, liable to be rejected.

iv. That applicant humbly seeks permission of this Learned Court to raise additional grounds at
the stage of arguments.

PRAYER
In aforementioned circumstances, it is humbly prayed that applicant in hand may kindly be accepted &
the plaint may graciously be rejected for lack of disclosing any cause of action as same is in the interest
of justice & fair play.

APPLICANT/DEFENDANT NO

THROUGH

ZEESHAN AHMAD MALIK

Advocate High Court

“THE LEGAL MENTORS”

66/3, Hajvery Complex, 2-Mozang Road, Lahore.

Format/Draft/Specimen:

Application under Order 1 Rule 10 for impleading as party

BEFORE HONOURABLE LABOUR COURT NO. 1, LAHORE.

In Re:

MUHAMMAD NAWAZ etc V. SECRETARY IRRIGATION etc

(Grievance Petition)

A P P L I C A T I O N UNDER ORDER 1 RULE 10 C.P.C. FOR IMPLEADING THE APPLICANTS (1. NASEER
AHMAD 2. RASHEED AFTAB 3.MUHAMMAD AMIR & 4. USMAN ALI) AS PESPONDENTS IN THE TITLED
GRIEVANCE PETITION, BEING NECESSARY PARTIES.
Respectfully Sheweth:

1. That the titled grievance petition is pending before this Honourable Court for today i.e. 20.02.2012.

2. That the titled grievance petition has been filed by the respondents against order dated 29.12.2011
passed by Superintending Engineer, Mechanical Circle, Lahore, whereby order passed by Executive
Engineer, Sheikhupura for adjustment of the respondents in District Bhalwal was cancelled.

3. That the applicants humbly seek indulgence of this Honourable Court for allowing them to be
impleaded as respondents in the titled grievance petition inter-alia on the following:

GROUNDS

(i) That the applicants are necessary party in the titled grievance petition and for proper
adjudication of the titled grievance petition, it is required that they may be arrayed as
respondents.
(ii) That the respondents did not array the applicants as party intentional so as to infringe the
applicants of their valuable rights.
(iii) That according to Rules/policy finalized by the Government, the respondents/petitioners
could not be adjusted in Bhalwal District against promotion post, therefore, order for
cancellation of their adjustment was passed in accordance with law.
(iv) That if the respondents/petitioners are adjusted in Bhalwal District against promotion posts,
seniority of the applicants will be disturbed as they are serving in the District Bhalwal in the
Department as fitters and electricians and their priceless rights as conferred upon them by
the Service Laws of the land will severely infringed and same cannot be allowed.

(iv) That if the tiled grievance petition is allowed, applicants will suffer irreparable loss.

(v) That it is in the interest of justice, it is necessary that the applicants may be impleaded as
parties in the titled grievance petition and they may be allowed to contest the same and
bring their version on record.
(vi) That applicants may be allowed to raise additional grounds at the stage of arguments.

PRAYER

In aforementioned circumstances, it is humbly prayed that the applicants may be impleaded as party in
the titled grievance petition as same is in the interest of justice and fair play.

APPLICANTS

THROUGH

Zeeshan Ahmad Malik

Advocate High Court

“THE LEGAL MENTORS”

66/3, Hajvery Complex, 2-Mozang Road, Lahore.

Draft/Specimen/Format:

Application for Temporary Injunction

IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE.

CIVIL SUIT NO: ________________________/2018

________ V. ____

[SUIT FOR SPECIFIC PERFORMANCE]

APPLICTION UNDER ORDER 39 RULE (1)(2) C.P.C. FOR GRANT OF TEMPORARY INJUNCTION.

Respectfully Sheweth:

1. That the plaintiff has filed titled suit in this Learned court in which next date of hearing has not been
fixed so far.

2. That the contents of the titled civil suit may kindly be read as integral part of the instant application.

3. That the applicant has a good prima facie and arguable case and there is every likelihood of his
success.

4. That the balance of convenience also lies in favour of the applicant/plaintiff.

5. That if the respondents are not restrained from alienating, transferring and selling the disputed
property, irreparable loss will be suffered by the applicant.

PRAYER
In aforementioned circumstances, it is humbly prayed that the instant application may kindly be
accepted and the respondent/defendants may graciously be restrained from alienating, transferring and
selling the disputed property till disposal of titled civil suit for specific performance.

APPLICANT/PLAINTIFF

THROUGH

Zeeshan Ahmad Malik

Advocate High Court

“THE LEGAL MENTORS”

66/3, Hajvery Complex, 2-Mozang Road, Lahore.

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