Model Drafts

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [CIVIL JUDGE (SENIOR DIVISION) / COMPETENT CIVIL COURT], [PLACE]

Civil Suit No. ____ of 20__

MEMO OF PARTIES

SUIT FOR RECOVERY OF ₹[AMOUNT] (RUPEES [AMOUNT IN WORDS] ONLY) ALONG WITH PENDENTE LITE AND FUTURE INTEREST AND COSTS

Respectfully showeth:

1. That the plaintiff is [DESCRIPTION OF PLAINTIFF — individual / proprietorship / partnership firm / company] carrying on [BUSINESS / PROFESSION] at [ADDRESS]. [If the plaintiff is a firm or company: the suit is filed through [NAME], who is authorised vide [AUTHORITY / RESOLUTION dated __].]
2. That the defendant [approached the plaintiff on [DATE] for / entered into a transaction with the plaintiff for] [SUPPLY OF GOODS / LOAN / SERVICES / OTHER] on the terms that [STATE TERMS — price, credit period, rate of interest, if any].
3. That in pursuance thereof the plaintiff [supplied goods / advanced a sum / rendered services] of the value of ₹[AMOUNT] vide [INVOICES / RECEIPTS / AGREEMENT dated __], copies of which are annexed as Annexure P-1 (colly).
4. That the defendant has paid only ₹[AMOUNT] and a principal sum of ₹[AMOUNT] remains outstanding, as reflected in the statement of account annexed as Annexure P-2. [The defendant acknowledged the liability on [DATE] vide [DOCUMENT], Annexure P-3.]
5. That despite repeated requests, the defendant has failed to pay the outstanding amount. The plaintiff served a legal notice dated [DATE] (Annexure P-4) by [MODE], which was [received on __ / returned with the report __], but the defendant has neither paid nor replied [or: sent an evasive reply dated __].
6. That the plaintiff is entitled to interest at the rate of [__]% per annum [as agreed between the parties / as is reasonable under Section 34 of the Code of Civil Procedure, 1908] from [DATE] till realisation. The amount claimed is: principal ₹[__] + interest up to the date of filing ₹[__] = ₹[TOTAL].
7. That the cause of action arose on [DATE] when [the goods were supplied / the amount was advanced], on [DATE] when payment fell due, on [DATE] when the legal notice was served, and it is continuing as the amount remains unpaid.
8. That this Court has territorial jurisdiction as [the defendant resides / carries on business / the cause of action, wholly or in part, arose] at [PLACE], within the jurisdiction of this Court. The suit is within the pecuniary jurisdiction of this Court.
9. That the suit is within limitation, being filed within three years from [DATE OF DUE DATE / LAST PAYMENT / ACKNOWLEDGMENT] [Article __ of the Schedule to the Limitation Act, 1963].
10. That the suit is valued at ₹[AMOUNT] for the purposes of court fee and jurisdiction, and the requisite court fee of ₹[__] has been affixed.
11. That [no other suit or proceeding on the same cause of action is pending or decided / all earlier proceedings and outcomes are disclosed as follows: ___].
12. That the transaction giving rise to the claim was [loan / supply / services / other], concluded on [date] at [place], between [identified parties]. The agreed performance, due date and payment terms were [terms], evidenced by [agreement / purchase order / correspondence, annexure].
13. That the plaintiff performed the obligation by [delivery / transfer / service] on [dates]. The defendant acknowledged receipt or performance by [document and date]. Any objection raised by the defendant and the plaintiff’s response were [particulars].
14. That the amount claimed is reconciled as follows: principal ₹[ ]; payments and credits ₹[ ]; outstanding principal ₹[ ]; pre-suit interest ₹[ ] calculated at [rate] for [period] on the basis of [contract / statute / established usage]. A transaction-wise statement and underlying records are annexed as [ ].
15. That the applicable limitation article is [ ], the right to sue accrued on [date and event], and the last date for filing, after lawful exclusions, is [ ]. If relying on acknowledgment or part-payment, its date, signature, timing before expiry and legal effect are [particulars]. A later demand alone is not pleaded as restarting limitation.
16. That this Court has territorial jurisdiction because [specific performance, payment, residence or business facts], and pecuniary jurisdiction because the suit value is ₹[ ]. [If a commercial dispute of specified value: identify the commercial transaction and compliance with Section 12A of the Commercial Courts Act, or genuine urgent interim relief sought and supporting facts.]
17. That the documents relied upon are listed with their dates, custodians and annexure numbers. Electronic records will be produced with the certificate required by the applicable evidence law. The valuation for court fee is ₹[ ]; the court fee payable is ₹____, subject to the applicable local law.

It is, therefore, respectfully prayed that a decree for recovery of ₹[AMOUNT] (Rupees [AMOUNT IN WORDS] only) may kindly be passed in favour of the plaintiff and against the defendant, along with pendente lite and future interest at the rate of [__]% per annum from the date of filing of the suit till realisation, with costs of the suit, and any other relief which this Hon'ble Court deems fit in the facts and circumstances of the case.

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above plaint are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.

PLAINTIFF

Note: Annex: list of documents relied upon (Order VII Rule 14 CPC), list of witnesses, court fee, process fee, and copies for service. For a commercial dispute of the specified value, follow the Commercial Courts Act, 2015 (pre-institution mediation and statement of truth).

IN THE COURT OF [CIVIL JUDGE (SENIOR DIVISION) / COMPETENT CIVIL COURT], [PLACE]

Civil Suit No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [CIVIL JUDGE (SENIOR DIVISION) / COMPETENT CIVIL COURT], [PLACE]

Civil Suit No. ____ of 20__

MEMO OF PARTIES

SUIT FOR PERMANENT INJUNCTION RESTRAINING THE DEFENDANT, HIS AGENTS, SERVANTS AND ANYONE ACTING ON HIS BEHALF FROM [INTERFERING IN THE PEACEFUL POSSESSION OF THE PLAINTIFF / RAISING CONSTRUCTION / ALIENATING] OVER THE SUIT PROPERTY DESCRIBED IN PARAGRAPH 2

Respectfully showeth:

1. That the plaintiff is the [owner / lawful tenant / co-owner] in possession of the suit property by virtue of [SALE DEED / INHERITANCE / RENT AGREEMENT / OTHER] dated [DATE] (Annexure P-1).
2. That the suit property is [DESCRIPTION: House / Plot / Shop No. __, Khasra / Khewat No. __, measuring __, situated at __], bounded as: East [__], West [__], North [__], South [__]. A site plan is annexed as Annexure P-2.
3. That the plaintiff is in settled, peaceful and continuous possession of the suit property since [DATE / YEAR], as evidenced by [ELECTRICITY BILLS / JAMABANDI / TAX RECEIPTS] (Annexure P-3).
4. That the defendant has no right, title or interest in the suit property. On [DATE], the defendant [DESCRIBE THE ACT OR THREAT — e.g. tried to forcibly enter / started digging / threatened to dispossess].
5. That the plaintiff reported the matter to [POLICE STATION / AUTHORITY] vide [DD No. / complaint dated __] (Annexure P-4). The defendant continues to threaten the plaintiff and may carry out the threat at any time.
6. That if the defendant is not restrained, the plaintiff will suffer irreparable loss and injury which cannot be compensated in money, and multiplicity of litigation will follow.
7. That the cause of action arose on [DATE] when [__], and further on [DATE] when [__], and it is continuing.
8. That the suit property is situated within the territorial jurisdiction of this Court, and the suit is within its pecuniary jurisdiction.
9. That the suit is valued at ₹[__] for the purposes of court fee and jurisdiction [under the applicable Court Fees Act and Suits Valuation Act], and the requisite court fee has been affixed.
10. That the suit is within limitation, and no other suit on the same cause of action is pending or has been decided between the parties.
11. That the suit property is specifically identifiable by [municipal / khasra / plot numbers], area [ ], boundaries [north, south, east, west] and the site plan annexed as [ ]. The source and extent of the plaintiff’s right are [document and particulars].
12. That the plaintiff’s possession on the date of institution is shown by [occupation / cultivation / tenant / keys / utility or revenue records] from [date]. The defendant’s competing claim, if any, is [exact claim and document], and the plaintiff’s response is [facts].
13. That on [dates], the defendant threatened or attempted [specific interference] at [location], witnessed or recorded by [evidence]. The apprehended recurrence is supported by [recent act], and not merely a general assertion of fear.
14. That [there is no substantial cloud on title / the asserted competing title requires declaration, for which appropriate additional relief is sought]. [If already dispossessed: plead when and how and seek the appropriate possession relief; do not retain an injunction-only prayer.]
15. That the precise restraint sought is against [identified act] concerning [identified portion]. It preserves the plaintiff’s existing lawful possession and does not seek to recover possession indirectly or prevent a lawful proceeding.
16. That the cause of action arose on [events and dates] within [place]. Territorial and pecuniary jurisdiction, applicable limitation and valuation are [particulars]; court fee payable is ₹____ under the applicable local law.
17. That [OPTIONAL: retain only after verifying the cited rule and these facts] the plaintiff’s lawful possession is shown by [annexures], the interference is [act], and the title position is [facts]. Applying Anathula Sudhakar, the selected relief is [injunction / declaration with consequential relief / possession] because [matching circumstances]; the adverse title material is addressed by [response].

It is, therefore, respectfully prayed that a decree for permanent injunction may kindly be passed in favour of the plaintiff and against the defendant, restraining the defendant, his agents, servants, relatives and anyone acting on his behalf from [interfering in the peaceful possession of the plaintiff / raising any construction / alienating or creating any third-party interest] over the suit property described in paragraph 2, with costs of the suit, and any other relief which this Hon'ble Court deems fit.

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above plaint are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.

PLAINTIFF

Note: An application for temporary injunction under Order XXXIX Rules 1 & 2 CPC is usually filed along with this suit (see Miscellaneous Applications).

IN THE COURT OF [CIVIL JUDGE (SENIOR DIVISION) / COMPETENT CIVIL COURT], [PLACE]

Civil Suit No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [JUDICIAL MAGISTRATE FIRST CLASS], [PLACE]

Complaint No. ____ of 20__

MEMO OF PARTIES

COMPLAINT UNDER SECTION 138 READ WITH SECTION 142 OF THE NEGOTIABLE INSTRUMENTS ACT, 1881

Respectfully showeth:

1. That the complainant and the accused are known to each other [STATE RELATIONSHIP / BUSINESS DEALINGS].
2. That the accused owed a legally enforceable debt / liability of ₹[AMOUNT] to the complainant on account of [LOAN / SALE OF GOODS / SERVICES / OTHER — brief facts].
3. That in discharge of the said liability, the accused issued cheque No. [__] dated [DATE] for ₹[AMOUNT], drawn on [BANK, BRANCH] (Annexure C-1).
4. That the complainant presented the cheque within its validity through [his / its] bank, [BANK, BRANCH], on [DATE]. The cheque was returned unpaid with the remark "[FUNDS INSUFFICIENT / EXCEEDS ARRANGEMENT / ACCOUNT CLOSED / PAYMENT STOPPED / OTHER]" vide return memo dated [DATE] (Annexure C-2).
5. That within thirty days of receiving information of dishonour, the complainant served a legal notice dated [DATE] on the accused by [REGISTERED / SPEED POST / COURIER / EMAIL / WHATSAPP] (Annexure C-3), demanding payment of the cheque amount. The postal receipts and tracking report are Annexures C-4 and C-5. The notice was [delivered on __ / returned with the report __, which amounts to deemed service].
6. That the accused failed to pay the cheque amount within fifteen days of receipt of the notice, and has thereby committed an offence punishable under Section 138 of the Negotiable Instruments Act, 1881.
7. That the cause of action arose on [DATE], on expiry of fifteen days from receipt of the notice, and this complaint is filed within one month therefrom, as required by Section 142(1)(b) of the Act.
8. That this Court has jurisdiction under Section 142(2) of the Act, as the cheque was delivered for collection through the complainant's account maintained at [BANK, BRANCH], which is within the territorial jurisdiction of this Court.
9. [If the accused is a company / firm: That accused No. __ is the company / firm, and accused Nos. __ to __ were in charge of and responsible for the conduct of its business at the relevant time, and are liable under Section 141 of the Act.]
10. That the debt arose from [transaction], on [date], for consideration of ₹[ ], proved by [agreement / invoices / bank transfer / ledger]. The sum legally due at presentation, after every payment or credit, was ₹[ ]. Any repayment between issuance and presentation is disclosed as [particulars].
11. That the cheque was issued by [drawer] on an account maintained by [individual / company]. Its signature is [admitted / disputed / to be proved]. Where Section 141 is invoked, the company is arraigned and the specific responsibility of each accused at the relevant time is [facts]; designation alone is not relied on.
12. That the cheque dated [ ] was presented on [ ] within its validity; the bank’s dishonour information was received on [ ]; the written demand for the cheque amount was issued on [ ] within thirty days. The notice, dispatch receipt, tracking and returned envelope are annexed as [ ].
13. That receipt or legally sustainable deemed service occurred on [date and supporting facts]. Fifteen days expired on [ ]; no payment of the cheque amount was received within that period; cause of action arose on [ ]; this complaint is filed on [ ] within one month thereafter. [If late: state the delay and file a supported condonation application under Section 142(1)(b).]
14. That territorial jurisdiction under Section 142(2) rests on [branch where the payee maintains the account, for collection through an account / drawer’s drawee branch if presented otherwise], namely [branch and address], supported by [bank record].
15. That the complainant is [payee / holder in due course], appearing personally or through [authorised representative]. The authorisation and representative’s knowledge of the transaction are [particulars]. Originals and the applicable electronic-record certificate are available as listed in [document index].
16. That [OPTIONAL: retain only after verifying the cited rule and these facts] the drawer’s signature/execution is established by [admission or evidence]. The Section 139 presumption considered in Rangappa supports the pleaded debt; the alleged rebuttal [identify defence] is answered by [transaction record and fact]. The statutory notice, service and limitation requirements are independently established as pleaded.

PRAYER

It is, therefore, respectfully prayed that the accused may kindly be summoned, tried and punished in accordance with law for the offence under Section 138 of the Negotiable Instruments Act, 1881, and the accused may be directed to pay suitable compensation to the complainant [under Section 395 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (Section 357 CrPC)].

LIST OF WITNESSES

1. Complainant [/ authorised representative].
2. Official of [BANK, BRANCH] with summoned record, if required.
3. Any other witness with the permission of the Court.

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above complaint are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.

COMPLAINANT

Note: Evidence may be given on affidavit under Section 145 of the Act. An application for interim compensation under Section 143A may be filed separately.

IN THE COURT OF [JUDICIAL MAGISTRATE FIRST CLASS], [PLACE]

Complaint No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [SESSIONS JUDGE / ADDITIONAL SESSIONS JUDGE], [PLACE] [or: IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH]

Bail Application No. ____ of 20__

Versus

In: [FIR No. __ dated __, under Sections __ of the Bharatiya Nyaya Sanhita, 2023 (or the corresponding IPC sections for offences before 01.07.2024), Police Station __, District __]

APPLICATION UNDER SECTION 483 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 [SECTION 439 CrPC] FOR THE GRANT OF REGULAR BAIL TO THE APPLICANT

Respectfully showeth:

1. That the above-noted FIR was registered on the statement of [COMPLAINANT / INFORMANT] alleging that [BRIEF ALLEGATIONS AS PER FIR, neutrally stated].
2. That the applicant was arrested on [DATE] and has been in judicial custody since [DATE], i.e. for about [__] [days / months].
3. That the applicant has been falsely implicated. [STATE GROUNDS — e.g. role attributed, delay in lodging FIR, nature of evidence, recovery or no recovery, medical evidence, parity with co-accused already granted bail].
4. That the investigation is [complete and the final report under Section 193 BNSS was filed on __ / at the stage of __]. The trial is likely to take considerable time, and no useful purpose will be served by keeping the applicant in custody.
5. That the applicant has [no criminal antecedents / the following cases: __, with their status].
6. That the applicant is a permanent resident of [ADDRESS], has deep roots in society, and there is no likelihood of the applicant absconding or tampering with evidence or influencing witnesses.
7. That [no other bail application has been filed / a bail application was dismissed by __ on __, and the present application is filed on the changed circumstances stated above].
8. That the applicant undertakes to abide by all terms and conditions imposed by this Hon'ble Court, to join the trial, and to furnish adequate bail and surety bonds.
9. That the applicant’s precise alleged role is [FIR and prosecution account], while the material relied on against the applicant is [statements / recovery / medical / digital evidence]. The applicant’s answer, without inviting a full trial at this stage, is [specific supported circumstance].
10. That custody began on [date], the latest remand is dated [ ], investigation is [stage], and the police report was [filed / not filed] on [ ]. The witnesses examined and remaining are [numbers]; the next date and likely impediment to trial are [recorded facts].
11. That any recovery or interrogation still said to be required is [particulars]. Continued detention is opposed because [case-specific reason]; completion of investigation is not treated as a universal entitlement to bail.
12. That antecedents, earlier bail applications and orders, abscondence or proclamation proceedings are fully disclosed in [schedule]. [If parity is sought: identify the co-accused’s order, comparable role and material differences.]
13. That risks of flight, witness influence and repetition can be addressed by [verified residence, attendance undertaking, no-contact condition, passport or other proportionate condition]. Financial circumstances and ability to furnish surety are [particulars].
14. That [no special statutory restriction applies / Section 37 NDPS, Section 45 PMLA, Section 43D(5) UAPA or another restriction applies and is addressed by the following material: ___]. [For default bail: use a distinct time calculation, extension-order analysis and willingness to furnish bail rather than assume merits bail and default bail are identical.]
15. That [OPTIONAL: retain only after verifying the cited rule and these facts] the applicant’s [cooperation, custody duration and antecedent position] is supported by [records]. Applying the discretionary approach in Dataram Singh, the identified risks can be managed by [conditions]; the contrary prosecution material and any special bail restriction are answered by [specific reasons].

PRAYER

It is, therefore, respectfully prayed that the applicant may kindly be released on regular bail in the above-noted FIR, on such terms and conditions as this Hon'ble Court deems fit, in the interest of justice.

Note: Before the High Court, an affidavit, a custody certificate and the list of previous bail applications are usually required. Before a Magistrate, regular bail is sought under Section 480 BNSS [Section 437 CrPC].

IN THE COURT OF [SESSIONS JUDGE / ADDITIONAL SESSIONS JUDGE], [PLACE] [or: IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH]

Bail Application No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [SESSIONS JUDGE / ADDITIONAL SESSIONS JUDGE], [PLACE] [or: IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH]

Anticipatory Bail Application No. ____ of 20__

Versus

In: [FIR No. __ dated __, under Sections __ of the Bharatiya Nyaya Sanhita, 2023 (or the corresponding IPC sections for offences before 01.07.2024), Police Station __, District __] [or: in apprehension of arrest in a non-bailable offence on the basis of complaint dated __]

APPLICATION UNDER SECTION 482 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 [SECTION 438 CrPC] FOR THE GRANT OF ANTICIPATORY BAIL TO THE APPLICANT

Respectfully showeth:

1. That the above-noted FIR has been registered against the applicant alleging that [BRIEF ALLEGATIONS, neutrally stated].
2. That the applicant has reason to believe that he / she may be arrested in the said FIR for a non-bailable offence.
3. That the applicant is innocent and has been falsely implicated. [STATE GROUNDS — e.g. civil / matrimonial dispute given a criminal colour, delay in FIR, nature of allegations, documentary evidence in favour].
4. That no custodial interrogation of the applicant is required, as [the case rests on documentary evidence / nothing is to be recovered from the applicant].
5. That the applicant has [no criminal antecedents / the following cases: __].
6. That the applicant is a permanent resident of [ADDRESS], is not likely to abscond, and undertakes to join the investigation as and when called upon, and to abide by the conditions under Section 482(2) BNSS.
7. That [no other application for anticipatory bail has been filed / an application was dismissed by __ on __].
8. That apprehension of arrest is based on [notice / raid / named accusation / police communication] dated [ ], relating to [identified incident and offence]. The apprehension is specific and supported by [annexure], not a request for protection against unknown future offences.
9. That the prosecution allegation against this applicant is [precise role]; the answer is [documents, chronology and circumstances]. The gravity, alleged injury, financial trail and any delayed accusation are addressed by [facts].
10. That the applicant has joined or offered to join investigation on [dates], supplied [records] and complied with [notice]. Any alleged non-cooperation is answered with [proof].
11. That the alleged need for custodial interrogation or recovery concerns [item / fact]. It can be addressed by [reason and proposed cooperation], subject to the Court’s assessment; absence of recovery alone is not asserted as conclusive.
12. That antecedents, earlier protection applications, warrants and any proclamation are [full particulars]. The applicant’s residence and employment are [verified details]; proposed safeguards are [attendance, no witness contact, travel terms].
13. That the present application is maintainable under [Section 482 BNSS / saved Section 438 CrPC]. All exclusions or special-law restrictions, including the offences excluded by Section 482(4) BNSS if relevant, have been examined and addressed as [particulars].
14. That [OPTIONAL: retain only after verifying the cited rule and these facts] the applicant’s concrete apprehension, role and cooperation are evidenced by [annexures]. Applying Sushila Aggarwal, protection for this identified accusation on [conditions] is sought because [facts]; the asserted custodial need is answered by [specific material], without seeking blanket immunity.

PRAYER

It is, therefore, respectfully prayed that in the event of arrest of the applicant in the above-noted FIR, the applicant may kindly be released on bail on such terms and conditions as this Hon'ble Court deems fit. It is further prayed that interim protection from arrest may be granted during the pendency of this application.

IN THE COURT OF [SESSIONS JUDGE / ADDITIONAL SESSIONS JUDGE], [PLACE] [or: IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH]

Anticipatory Bail Application No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

CRM-M No. ____ of 20__

MEMO OF PARTIES

PETITION UNDER SECTION 528 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 [SECTION 482 CrPC] FOR QUASHING OF [FIR NO. __ DATED __, UNDER SECTIONS __ OF THE BHARATIYA NYAYA SANHITA, 2023 (OR THE CORRESPONDING IPC SECTIONS FOR OFFENCES BEFORE 01.07.2024), POLICE STATION __, DISTRICT __] (ANNEXURE P-1) AND ALL CONSEQUENTIAL PROCEEDINGS ARISING THEREFROM, ON THE BASIS OF THE COMPROMISE DATED [DATE] (ANNEXURE P-2)

Respectfully showeth:

1. That the above-noted FIR was registered at the instance of respondent No. 2 against the petitioner(s), alleging that [BRIEF ALLEGATIONS].
2. That the dispute between the parties is [private / personal / matrimonial / commercial] in nature.
3. That with the intervention of respectable persons and well-wishers, the parties have amicably settled their disputes and entered into a written compromise dated [DATE] (Annexure P-2). The compromise is voluntary and without any coercion, pressure or undue influence.
4. That respondent No. 2 has no objection to the quashing of the FIR and the consequential proceedings, and is ready to appear before this Hon'ble Court or before the trial court to make a statement to that effect.
5. That the proceedings are at the stage of [INVESTIGATION / CHARGE / EVIDENCE] before [COURT]. The case-specific grounds for seeking quashing despite the prosecution material are [STATE SUPPORTED GROUNDS]; the compromise is not treated as an automatic ground for quashing.
6. That the petitioner(s) [have / have not] been declared proclaimed offender(s), and [no other case is pending between the parties / details of other cases: __].
7. That [no earlier petition for the same relief was filed / the earlier petitions, results and material change in circumstances are: ___].
8. That each petitioner’s alleged role, the exact offences, injury and weapons if any are [particulars]. The case is at [investigation / charge / evidence / appeal stage]; the challan, charge order and previous relevant orders are annexed as [ ].
9. That all victims, complainants and accused concerned are identified in [schedule]. The compromise covers [persons and issues]; any person or count not covered, minor victim or third-party/public interest is expressly disclosed as [ ].
10. That the dispute arose from [specific private transaction or relationship]. Its predominantly private character is shown by [facts], while the seriousness and social impact of the alleged offence are addressed by [facts].
11. That the settlement dated [ ] was reached through [process] voluntarily. Consideration or obligations are [terms]; performance is evidenced by [receipts / return of property / statements]. Any remaining obligation is [precise term and deadline].
12. That the reasons for submitting that continuation would be unjust despite the prosecution material are [case-specific reasons]. The Court is not asked to treat the compromise as automatic proof that conviction is impossible.
13. That proclamation status, antecedents, other FIRs, prior quashing petitions and bail conditions are fully disclosed as [ ]. The petitioners and affected persons are available for judicial verification of the settlement as directed.
14. That [OPTIONAL: retain only after verifying the cited rule and these facts] the transaction is predominantly [private category] as evidenced by [records], the compromise is voluntary and covers [persons], and the prosecution stage is [ ]. Applying Gian Singh, continuation would defeat the ends of justice because [specific reason]; seriousness, public impact and any excluded category are addressed by [analysis].

PRAYER

It is, therefore, respectfully prayed that the above-noted FIR (Annexure P-1) and all consequential proceedings arising therefrom may kindly be quashed on the basis of the compromise dated [DATE] (Annexure P-2). [If so directed, the parties may be sent to the trial court / Illaqa Magistrate to record their statements on the genuineness of the compromise.] It is further prayed that further proceedings before the trial court may be stayed during the pendency of this petition.

Note: Annexures usually filed: P-1 FIR, P-2 compromise deed, identity documents of the parties, and any affidavit of respondent No. 2. Follow the High Court's current filing checklist.

IN THE HIGH COURT OF PUNJAB AND HARYANA AT CHANDIGARH

CRM-M No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [PRINCIPAL JUDGE, FAMILY COURT / DISTRICT JUDGE], [PLACE]

HMA Petition No. ____ of 20__

MEMO OF PARTIES

JOINT PETITION UNDER SECTION 13-B OF THE HINDU MARRIAGE ACT, 1955 FOR DISSOLUTION OF MARRIAGE BY A DECREE OF DIVORCE BY MUTUAL CONSENT (FIRST MOTION)

The petitioners respectfully submit as under:

1. That the marriage between the petitioners was solemnised on [DATE] at [PLACE] according to Hindu rites and ceremonies. [The marriage was registered on __ vide registration No. __.] The marriage photographs / certificate are annexed as Annexure P-1.
2. That [no child was born out of the wedlock / the following child(ren) were born: NAME, DATE OF BIRTH, presently in the custody of __].
3. That the petitioners last resided together as husband and wife at [ADDRESS], within the jurisdiction of this Court [Section 19 of the Act].
4. That due to temperamental differences, the petitioners could not live together, and they have been living separately since [DATE], i.e. for a period of more than one year before the presentation of this petition.
5. That all efforts at reconciliation by the families and well-wishers have failed, and there is no possibility of the petitioners living together as husband and wife.
6. That the petitioners have mutually agreed that their marriage should be dissolved. They have settled all their claims regarding [STRIDHAN / DOWRY ARTICLES, MAINTENANCE / PERMANENT ALIMONY of ₹__, payable as __, CUSTODY AND VISITATION, OTHER] in full and final settlement (Annexure P-2).
7. That the consent of neither petitioner has been obtained by force, fraud or undue influence, and there is no collusion between the parties in filing this petition.
8. That [no other litigation is pending between the parties / the following cases are pending: __, and the parties undertake to withdraw / get them disposed of in terms of the settlement].
9. That no previous petition for the same relief has been filed between the parties.
10. That the applicable marriage law and ceremonies are [facts], and jurisdiction under the precise clause of Section 19 rests on [marriage place / last shared residence / respondent residence / wife’s residence where applicable] supported by [record].
11. That the parties have lived separately since [date], have been unable to live together, and have mutually agreed to dissolve the marriage. The statutory separation period under Section 13B(1) is satisfied by [timeline].
12. That the settlement provides ₹[ ] as [alimony], payable [instalment, method and trigger]; stridhan and articles are listed with delivery acknowledgments; liabilities and property terms are [precise provisions]. No ambiguous promise of future settlement is relied on.
13. That children’s custody, school, residence, medical costs, visitation, holidays and communication are agreed as [terms], subject always to their welfare and the Court’s directions; the parents do not purport to waive a child’s independent rights.
14. That each pending case and the competent forum’s proposed disposal are listed as [case number, relief, stage and step]. This petition does not itself withdraw criminal proceedings or guarantee quashing of an FIR.
15. That any proposed waiver of the Section 13B(2) waiting period will be sought by a supported application stating separation duration, reconciliation efforts, completeness of settlement and hardship. Consent must remain voluntary at the second motion.
16. That [OPTIONAL: retain only after verifying the cited rule and these facts] [only if a separate waiver application is being made] separation dates [ ], failed reconciliation [record], settled obligations [proof] and avoidable hardship [facts] support discretionary waiver under Amardeep Singh. This is confined to Section 13B(2); the independent Section 13B(1) requirements remain satisfied.

PRAYER

It is, therefore, respectfully prayed that the statements of the petitioners may kindly be recorded on this first motion, and on the second motion, after the period prescribed under Section 13-B(2) of the Hindu Marriage Act, 1955 [or on its waiver, if permissible and sought], the marriage between the petitioners may be dissolved by a decree of divorce by mutual consent.

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above petition are true and correct to our knowledge, and the last paragraph is the prayer to this Hon'ble Court. Nothing material has been concealed therefrom.

PETITIONER No. 1 PETITIONER No. 2

Note: A separate affidavit is filed by each petitioner, together with identity proofs, photographs and the marriage proof.

IN THE COURT OF [PRINCIPAL JUDGE, FAMILY COURT / DISTRICT JUDGE], [PLACE]

HMA Petition No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [PRINCIPAL JUDGE, FAMILY COURT / JUDICIAL MAGISTRATE FIRST CLASS], [PLACE]

Maintenance Petition No. ____ of 20__

MEMO OF PARTIES

PETITION UNDER SECTION 144 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 [SECTION 125 CrPC] FOR THE GRANT OF MAINTENANCE TO THE PETITIONERS

Respectfully showeth:

1. That petitioner No. 1 was married to the respondent on [DATE] at [PLACE]. [Petitioner No. 2 was born out of the wedlock on __.]
2. That since [DATE], the respondent has neglected and refused to maintain the petitioners. [BRIEF FACTS of the circumstances in which the petitioner is living separately.]
3. That the petitioners’ actual income and resources are [FULL DISCLOSURE], and are insufficient to meet their reasonable needs as particularised below.
4. That the respondent has sufficient means. He is [OCCUPATION] and earns about ₹[__] per month, and owns [PROPERTY / OTHER ASSETS].
5. That this Court has jurisdiction under Section 145 BNSS [Section 126 CrPC], as the petitioners [reside / the respondent resides / the parties last resided together] at [PLACE].
6. That [no other proceedings for maintenance are pending / the following proceedings are pending: __, and the details are disclosed].
7. That the applicant falls within [wife / eligible child / father / mother] under the applicable provision, on the basis of [relationship and eligibility facts]. If living separately, the reasons and supporting incidents are [dates and material]; any statutory disentitlement alleged is answered by [facts].
8. That the applicant’s actual income, assets, liabilities and support received are ₹[ ] and [particulars], disclosed in the prescribed assets-and-liabilities affidavit. [Do not retain the earlier no-income assertion if income exists.]
9. That monthly needs are itemised as housing ₹[ ], food ₹[ ], education ₹[ ], healthcare ₹[ ], transport ₹[ ] and other essential expenditure ₹[ ], supported by [receipts]. The amount requested for each applicant is calculated separately.
10. That the respondent’s known employment, business, assets, earning capacity and dependants are [particulars], supported by [records]. Unavailable records are identified for production by the respondent rather than income being asserted without a stated basis.
11. That all maintenance proceedings, interim/final orders and sums actually received are [case-wise schedule]. Appropriate adjustment of earlier awards is sought, without duplicate recovery.
12. That neglect or refusal occurred on [dates and acts]. Interim maintenance and proceeding expenses of ₹[ ] are required because [immediate unmet needs]; maintenance is sought from the date of the application with the relevant financial disclosures.
13. That [OPTIONAL: retain only after verifying the cited rule and these facts] the disclosures and monthly-expense schedule [annexures] demonstrate an unmet need of ₹[ ]. Applying Rajnesh v. Neha, the earlier maintenance award of ₹[ ] and receipts of ₹[ ] are disclosed for appropriate adjustment, and maintenance is sought from the date of this application.

PRAYER

It is, therefore, respectfully prayed that the respondent may kindly be directed to pay maintenance of ₹[__] per month to petitioner No. 1 and ₹[__] per month to petitioner No. 2, from the date of this petition. It is further prayed that interim maintenance may be granted during the pendency of the petition, as provided in Section 144(1).

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above petition are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.

PETITIONER NO. 1

Note: File an affidavit disclosing assets, income and liabilities in the format in use before the court.

IN THE COURT OF [__], [PLACE]

Maintenance Petition No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [JUDICIAL MAGISTRATE FIRST CLASS], [PLACE]

Complaint / Application No. ____ of 20__

MEMO OF PARTIES

APPLICATION UNDER SECTION 12 OF THE PROTECTION OF WOMEN FROM DOMESTIC VIOLENCE ACT, 2005 FOR RELIEFS UNDER SECTIONS 18, 19, 20, 21 AND 22 OF THE ACT

Respectfully showeth:

1. That the applicant is an aggrieved person within the meaning of Section 2(a) of the Act. She is / was in a domestic relationship with the respondent(s) as [WIFE / DAUGHTER-IN-LAW / OTHER], and lived with them in the shared household at [ADDRESS].
2. That the respondent(s) subjected the applicant to domestic violence within the meaning of Section 3 of the Act, namely [PHYSICAL / SEXUAL / VERBAL AND EMOTIONAL / ECONOMIC ABUSE]. The specific incidents are: (a) on [DATE], [INCIDENT]; (b) on [DATE], [INCIDENT]; (c) [__].
3. That [a Domestic Incident Report was prepared by the Protection Officer on __ / the applicant approached __ on __] (Annexure A-__).
4. That the applicant has [been dispossessed from the shared household on __ / is apprehensive of dispossession], and has no means to maintain herself [and the child(ren)].
5. That this Court has jurisdiction under Section 27 of the Act, as the applicant [permanently or temporarily resides / the respondent resides / the cause of action arose] at [PLACE].
6. That [no other proceedings are pending / the following proceedings are pending between the parties: __].
7. That the domestic relationship and shared household are established by [relationship, periods of co-residence and address], supported by [records]. For each respondent, the relationship and particular acts alleged are separately stated.
8. That the incidents are particularised chronologically: [date, place, respondent, physical / sexual / verbal / emotional / economic abuse, witness or record]. Continuing deprivation, threats or exclusion are [specific current facts].
9. That the applicant’s residence and the cause of action bring the matter within Section 27 because [actual facts]. The Domestic Incident Report is [available and annexed / requested / not received]; its status is disclosed accurately.
10. That protection is sought against [identified conduct] under Section 18, and residence relief under Section 19 concerns [identified household, possession, exclusion and suitable precise direction]. Ownership of the household and competing rights are disclosed as [ ].
11. That monetary relief under Section 20 is itemised as [maintenance, loss of earnings, medical expenses, property loss], with supporting records; compensation under Section 22 rests on [injury and particulars]. Custody/visitation relief under Section 21, if needed, is justified by [child-welfare facts].
12. That the urgency for interim or ex parte relief under Section 23 is [imminent risk, dates and proof]. Where seeking an ex parte order, the affidavit in the prescribed form is separately supplied. Earlier civil, criminal and maintenance orders and payments are [schedule].
13. That [OPTIONAL: retain only after verifying the cited rule and these facts] [for maintenance relief only] earlier awards and sums received are [schedule]. Applying the overlapping-maintenance directions in Rajnesh v. Neha, adjustment is sought as [calculation], without treating that decision as proof of the separately pleaded domestic violence.

PRAYER

It is, therefore, respectfully prayed that this Hon'ble Court may kindly grant: (a) a protection order under Section 18; (b) a residence order under Section 19; (c) monetary relief of ₹[__] per month and [OTHER EXPENSES] under Section 20; (d) temporary custody of the child(ren) under Section 21; (e) compensation of ₹[__] under Section 22; and (f) interim and ex parte orders under Section 23 of the Act, along with any other relief this Hon'ble Court deems fit.

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above application are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.

APPLICANT

IN THE COURT OF [JUDICIAL MAGISTRATE FIRST CLASS], [PLACE]

Complaint / Application No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION, [DISTRICT]

Consumer Complaint No. ____ of 20__

MEMO OF PARTIES

COMPLAINT UNDER SECTION 35 OF THE CONSUMER PROTECTION ACT, 2019

Respectfully showeth:

1. That the complainant [purchased goods / availed services] being [DESCRIPTION] from the opposite party on [DATE] for a consideration of ₹[AMOUNT] vide [INVOICE / RECEIPT No. __] (Annexure C-1), for personal use and not for any commercial purpose. The complainant is a consumer under Section 2(7) of the Act.
2. That [DESCRIBE THE DEFECT / DEFICIENCY IN SERVICE / UNFAIR TRADE PRACTICE, with dates].
3. That the complainant reported the issue on [DATES] vide [COMPLAINT / TICKET Nos. __] (Annexure C-2), but the opposite party failed to resolve it. A legal notice dated [DATE] (Annexure C-3) also went unanswered [or: was replied evasively].
4. That the acts of the opposite party amount to [a defect under Section 2(10) / deficiency in service under Section 2(11) / an unfair trade practice under Section 2(47)] of the Act, causing the complainant financial loss, mental agony and harassment.
5. That this Commission has pecuniary jurisdiction under Section 34(1), as the value of the goods or services paid as consideration is ₹[AMOUNT], and territorial jurisdiction under Section 34(2), as [the complainant resides or personally works for gain / the opposite party carries on business / the cause of action arose] at [PLACE].
6. That the complaint is filed within two years from the date on which the cause of action arose, i.e. [DATE], as required by Section 69 of the Act.
7. That the consideration paid is ₹[ ], on [dates], for [goods / services]. Consumer status under Section 2(7) is established by [purpose and use]; any commercial-purpose objection and livelihood/self-employment exception relied on are addressed by [specific facts].
8. That the opposite party promised [contractual / statutory standard], but supplied or performed [actual defect / deficiency / unfair practice] on [dates]. Each allegation is linked to [invoice, warranty, communication, report or other evidence].
9. That complaints and opportunities to rectify were given on [dates]; the responses were [ ]. Loss is calculated as refund ₹[ ], proved expenditure ₹[ ], other compensable injury ₹[ ] and litigation costs ₹[ ], without double counting.
10. That pecuniary jurisdiction is determined by the value paid as consideration under the currently applicable jurisdiction rules, namely ₹[ ], rather than an inflated total compensation demand. Territorial jurisdiction under Section 34(2) rests on [specific clause and facts].
11. That the cause of action accrued on [date and event]; the complaint is within Section 69’s two-year period on [calculation]. [If beyond time: state the full delay and file a separate sufficient-cause application.] A later representation alone is not treated as extending limitation.
12. That expert evidence or testing, if required, concerns [issue and requested procedure]. Other proceedings and settlements are disclosed. The relief sought under Section 39 is [repair / replacement / refund / compensation / discontinuance of practice], justified by the proved deficiency.

PRAYER

It is, therefore, respectfully prayed that the opposite party(ies) may kindly be directed to: (a) [replace the product / remove the defect / refund ₹__] along with interest at [__]% per annum from [DATE]; (b) pay ₹[__] as compensation for mental agony and harassment; (c) pay ₹[__] as litigation costs; and (d) grant any other relief this Hon'ble Commission deems fit.

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above complaint are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.

COMPLAINANT

Note: Complaints can also be filed online on the e-Daakhil portal. Attach the fee as prescribed for the claim value.

BEFORE THE DISTRICT CONSUMER DISPUTES REDRESSAL COMMISSION, [DISTRICT]

Consumer Complaint No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

BEFORE THE MOTOR ACCIDENT CLAIMS TRIBUNAL, [PLACE]

MACT Case No. ____ of 20__

MEMO OF PARTIES

CLAIM PETITION UNDER SECTION 166 OF THE MOTOR VEHICLES ACT, 1988 FOR COMPENSATION ON ACCOUNT OF [INJURIES SUSTAINED BY __ / DEATH OF __] IN A MOTOR VEHICLE ACCIDENT

Respectfully showeth:

1. Particulars of the injured / deceased: name [__]; age [__]; occupation [__]; monthly income ₹[__]; address [__].
2. Date, time and place of the accident: [DATE], at about [TIME], at [PLACE].
3. FIR: [FIR No. __ dated __, under Sections __ of the Bharatiya Nyaya Sanhita, 2023 (or the corresponding IPC sections for offences before 01.07.2024), Police Station __, District __] (Annexure P-1).
4. Offending vehicle: registration No. [__], driven by respondent No. 1, owned by respondent No. 2, and insured with respondent No. 3 vide policy No. [__], valid from [__] to [__].
5. Brief facts: [DESCRIBE HOW THE ACCIDENT OCCURRED, showing rash and negligent driving by respondent No. 1].
6. Injuries / cause of death: [NATURE OF INJURIES / DISABILITY / POST-MORTEM FINDINGS]; treatment at [HOSPITAL] from [__] to [__] (Annexure P-2).
7. Expenses and loss: medical ₹[__]; transport and attendant ₹[__]; loss of income ₹[__]; [for death: loss of dependency, funeral expenses, loss of estate, consortium and love and affection].
8. Claimants and dependency: [NAMES, AGES AND RELATIONSHIP of the claimants with the deceased / injured].
9. That this Tribunal has jurisdiction under Section 166(2) of the Act, as [the accident occurred / the claimant resides or carries on business / the defendant resides] within its local limits.
10. That the respondents are jointly and severally liable to pay compensation to the claimant(s).
11. That the collision occurred on [date, time and location] when [specific driving act] caused [impact and injury]. The negligence account is supported by [eyewitness, site plan, FIR, CCTV, mechanical inspection]; the criminal allegation is not treated as a concluded finding of civil liability.
12. That the driver, registered owner and insurer at the accident date are [details]. Policy number, period, licence particulars and any insurer’s pleaded defence are [records and response].
13. That the deceased’s age, occupation and proved income are [particulars and evidence]; dependants and legal representatives are separately identified. The death claim calculation sets out income after applicable tax, future prospects, personal-expense deduction, multiplier and conventional heads with the basis for each.
14. That [for injury claims only] treatment, expenditure, income loss during treatment, permanent disability and its actual effect on earning capacity are [medical and vocational evidence]. Medical disability is not automatically treated as the same percentage of economic loss.
15. That the legal basis for territorial jurisdiction and the applicable limitation position, having regard to accident date, amendments, commencement and binding orders, have been examined as [details]. A blanket assertion that every MACT claim has no filing deadline is not relied on.
16. That compensation under each head is ₹[ ] as per the annexed calculation, interest is sought at [rate and justified commencement], and interim sums or other recoveries are disclosed for appropriate adjustment.
17. That [OPTIONAL: retain only after verifying the cited rule and these facts] [for a death claim only] age [ ] and employment category [ ] are proved by [records]. Applying Pranay Sethi’s framework, future prospects of [supported percentage], deduction [ ], multiplier [ ] and conventional heads [ ] yield ₹[ ], as shown in the separate computation; subsequent applicable adjustments are identified as [ ].

PRAYER

It is, therefore, respectfully prayed that an award of ₹[AMOUNT] may kindly be passed in favour of the claimant(s) and against the respondents, jointly and severally, along with interest at such rate as this Hon'ble Tribunal deems fit from the date of filing of the petition till realisation, with costs.

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above claim petition are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.

CLAIMANT(S)

Note: Attach the FIR, the Detailed Accident Report (if filed by the police), medical records and bills, income proof, the driving licence, the RC and insurance particulars, and the post-mortem report (death cases).

BEFORE THE MOTOR ACCIDENT CLAIMS TRIBUNAL, [PLACE]

MACT Case No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [__], [PLACE]

Execution Application No. ____ of 20__

Versus

APPLICATION FOR EXECUTION OF DECREE UNDER ORDER XXI RULE 11(2) READ WITH SECTION 51 OF THE CODE OF CIVIL PROCEDURE, 1908

The decree-holder prays for execution of the decree, the particulars of which are given below:

1. Number of the suit: [CIVIL SUIT No. __ of __], decided by [COURT].
2. Names of the parties: [DECREE-HOLDER] versus [JUDGMENT-DEBTOR].
3. Date of the decree: [DATE] (certified copy annexed).
4. Whether any appeal was preferred against the decree: [No / Yes — APPEAL No. __, decided on __ / pending, with no stay].
5. Whether any payment or adjustment was made: [No / Yes — ₹__ on __].
6. Previous applications for execution, if any, with their dates and results: [None / details].
7. Amount, with interest, due upon the decree, or other relief granted: [PRINCIPAL ₹__ + INTEREST ₹__ up to __ = ₹__ / DESCRIPTION OF RELIEF].
8. Amount of costs, if any, awarded: ₹[__].
9. Name of the person against whom execution is sought: [JUDGMENT-DEBTOR].
10. Mode in which the assistance of the Court is required: [attachment and sale of the movable / immovable property described in the Schedule / arrest and detention in civil prison / delivery of possession / appointment of a receiver / other].
11. That the operative decree directs [quote its exact relief and parties], and the present application seeks only enforcement of that direction. The certified decree and relevant judgment are annexed as [ ].
12. That the decree is executable in this Court because [court which passed it / lawful transfer and transmission particulars]. Any appeal, stay, variation or satisfaction is [full details and orders]. Filing an appeal alone is not pleaded as an automatic stay.
13. That the amount due on [date] comprises decretal principal ₹[ ], interest calculated strictly under the decree ₹[ ], costs ₹[ ], less payments or adjustments ₹[ ]. The calculation and certification of adjustment, where required, are annexed.
14. That execution limitation is calculated under [Article 136 / Article 135 or other applicable provision] from [date decree became enforceable], taking account of [lawful exclusion]. Mandatory-injunction decrees are not assumed to have the same period as every money decree.
15. That the requested mode of execution is [attachment and sale / delivery of possession / other], concerning [identified property, ownership and known exemptions]. If seeking civil detention, the statutory notice, inquiry and Section 51 proviso requirements are addressed by [facts], not merely non-payment.
16. That earlier executions and results are listed as [dates, court, amount realised and orders]. The Order XXI Rule 11 particulars are completed, and any application for asset disclosure is precisely framed.

SCHEDULE OF PROPERTY (if attachment is sought)

[DESCRIPTION OF PROPERTY with boundaries / particulars, and the judgment-debtor's interest in it].

PRAYER

It is, therefore, respectfully prayed that the decree dated [DATE] may kindly be executed in the manner stated above, and the amount due along with costs of execution may be recovered from the judgment-debtor.

VERIFICATION

I, [NAME OF DECREE-HOLDER], the decree-holder, do hereby declare that what is stated above is true to the best of my information and belief. Verified at [PLACE] on [DATE].

DECREE-HOLDER

IN THE COURT OF [__], [PLACE]

Execution Application No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DISTRICT JUDGE / PRINCIPAL JUDGE, FAMILY COURT], [PLACE]

Guardianship Petition No. ____ of 20__

MEMO OF PARTIES

PETITION UNDER SECTIONS 7 AND 10 OF THE GUARDIANS AND WARDS ACT, 1890 FOR APPOINTMENT OF THE PETITIONER AS GUARDIAN OF THE [PERSON / PROPERTY / PERSON AND PROPERTY] OF THE MINOR [NAME OF MINOR]

Respectfully showeth:

1. Name, sex, religion and date of birth of the minor: [__], [__], [__], [DATE OF BIRTH] (birth certificate, Annexure P-1).
2. Ordinary residence of the minor: [ADDRESS], within the jurisdiction of this Court [Section 9 of the Act].
3. [If the minor is a female: whether she is married, and if so, the name and age of her husband: __.]
4. Nature, situation and approximate value of the minor's property, if any: [DESCRIPTION — e.g. share in house No. __ / bank deposit of ₹__].
5. Name and residence of the person having custody or possession of the person or property of the minor: [__].
6. Names and residences of the near relatives of the minor: [__].
7. Whether a guardian of the person or property of the minor has been appointed by any person entitled, or claiming to be entitled, under the law to which the minor is subject: [No / details].
8. Whether an application has at any time been made to this or any other Court for the appointment of a guardian of the person or property of the minor: [No / details].
9. Ground of the application: [e.g. death of the father on __; the minor lives with the petitioner; the guardianship is required for __; it is in the welfare of the minor].
10. That the petitioner is a fit and proper person, has no interest adverse to the minor, and undertakes to act in the best interest and welfare of the minor.
11. That the minor ordinarily resides at [address] since [date], as shown by [school, home and caregiving records]; this jurisdictional fact is distinguished from a temporary visit or one parent’s residence.
12. That every living parent, present custodian and person with a relevant guardianship claim is identified. Existing custody orders, proceedings, passports and cross-border circumstances are [complete particulars].
13. That day-to-day care, schooling, health, emotional ties, sibling relationships and safety are presently [facts]. The proposed arrangement protects continuity and welfare because [evidence], rather than asserting an adult’s superior entitlement alone.
14. That the proposed guardian’s fitness, accommodation, availability, means and willingness are [evidence]. Any adverse allegation, conflict of interest or relevant statutory bar is disclosed and answered as [particulars].
15. That the child’s wishes, if age and understanding permit, may be ascertained in an appropriate manner; no coached statement is asserted as determinative. The proposed contact and holiday plan with the other parent is [terms], subject to welfare and any supported safety concern.
16. That interim custody or access is sought because [current urgency], on [precise schedule and handover safeguards]. Property guardianship, if sought, is separately particularised with inventory, valuation and management proposal.
17. That [OPTIONAL: retain only after verifying the cited rule and these facts] the child’s actual care, schooling, emotional ties and safety are evidenced by [records]. Applying Yashita Sahu, the proposed custody and contact schedule [terms] serves welfare because [specific reasons]; any request to restrict contact is based on [supported exceptional circumstances].

PRAYER

It is, therefore, respectfully prayed that the petitioner may kindly be appointed as guardian of the [person / property / person and property] of the minor [NAME], [with permission to __, subject to Section 29 of the Act where property is to be dealt with], in the interest and welfare of the minor.

VERIFICATION

Verified at [PLACE] on [DATE] that the contents of paragraphs 1 to [__] of the above petition are true and correct to my knowledge, the contents of paragraphs [__] to [__] are based on information received and legal advice, which I believe to be true, and the last paragraph is the prayer to this Hon'ble Court. No part of it is false and nothing material has been concealed therefrom.

PETITIONER

DECLARATION OF WILLINGNESS (Section 10(4))

I, [NAME OF PROPOSED GUARDIAN], declare that I am willing to act as guardian of the [person / property] of the minor [NAME].

[PROPOSED GUARDIAN]

Attested by: 1. [NAME, ADDRESS, SIGNATURE] 2. [NAME, ADDRESS, SIGNATURE]

IN THE COURT OF [__], [PLACE]

Guardianship Petition No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION ON BEHALF OF THE [ACCUSED / PARTY] FOR EXEMPTION FROM PERSONAL APPEARANCE FOR [TODAY / THE DATE __] [UNDER SECTION 228 / 355 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 (SECTION 205 / 317 CrPC)] [or, in a civil matter, UNDER ORDER III RULE 1 READ WITH SECTION 151 CPC]

Respectfully showeth:

1. That the above-noted case is fixed for [today / DATE] for [STAGE OF THE CASE].
2. That the applicant is unable to appear in person on the said date because [REASON — e.g. illness, as per the medical certificate annexed as Annexure A-1 / unavoidable travel / other].
3. That the absence of the applicant is neither intentional nor deliberate. The applicant is being represented by counsel, who is present.
4. [In a criminal matter: That the applicant undertakes not to dispute identity, and has no objection to proceedings, including recording of evidence, taking place in the presence of counsel.]
5. That the applicant undertakes to appear in person on the next date of hearing or whenever directed by this Hon'ble Court.
6. That exemption is sought [for the hearing on date only / as a continuing dispensation], under the provision appropriate to that scope, namely [Section 355 or 228 BNSS / saved Section 317 or 205 CrPC].
7. That inability to attend arises from [specific reason and dates], supported by [medical / travel / other evidence]. The case is fixed for [stage]; any stage at which identity or personal attendance is material is disclosed.
8. That counsel [name] is authorised and will attend. The applicant undertakes not to dispute identity solely because of the dispensation and to attend whenever ordered; the proposed arrangement will not prejudice examination or progress.
9. That prior exemptions, attendance defaults, warrants and bail conditions are [complete particulars]. A pending or existing warrant is addressed by appropriate separate relief rather than presumed cancelled by this application.

PRAYER

It is, therefore, respectfully prayed that the applicant may kindly be exempted from personal appearance for [today / DATE], in the interest of justice.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION FOR ADJOURNMENT OF THE HEARING FIXED FOR [DATE] [UNDER ORDER XVII RULE 1 CPC / SECTION 346 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 (SECTION 309 CrPC)]

Respectfully showeth:

1. That the above-noted case is fixed for [DATE] for [STAGE].
2. That the applicant is unable to proceed on that date because [REASON — e.g. illness of the party / counsel, non-availability of a witness, documents awaited, counsel engaged before another court], with supporting documents annexed.
3. That this is the [first / second] adjournment sought by the applicant at this stage, and it is not sought to delay the proceedings.
4. That the anticipated prejudice to the other side is [SPECIFY] and can be mitigated by [TERMS]. The applicant is ready to bear such costs as this Hon'ble Court may impose.
5. That the case is fixed for [specific task] on [date]; the applicant requests the shortest necessary adjournment until [date or period] because [specific event and date], proved by [annexure].
6. That prior adjournments requested by this party during the hearing were [dates, reasons and orders]. If the usual three-adjournment limit is engaged, the exceptional circumstance beyond control is [facts].
7. That reasonable alternatives considered were [alternate counsel / remote appearance if permitted / production through other witness], which could not address the difficulty because [reason].
8. That prejudice to the other party can be mitigated by [costs, prompt service, fixed next date or undertaking]. The request is not based solely on counsel’s engagement elsewhere.
9. That [OPTIONAL: retain only after verifying the cited rule and these facts] [for a civil hearing] the exceptional impediment beyond control is [event and proof]. Applying Salem Advocate Bar Association (II), the prior adjournments [schedule], alternatives considered [ ] and proposed terms [ ] justify the shortest necessary extension; no adjournment is claimed as a right.

PRAYER

It is, therefore, respectfully prayed that the hearing fixed for [DATE] may kindly be adjourned to a suitable date, in the interest of justice.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION UNDER SECTION 5 OF THE LIMITATION ACT, 1963 FOR CONDONATION OF DELAY OF [__] DAYS IN FILING THE ACCOMPANYING [APPEAL / REVISION / APPLICATION]

Respectfully showeth:

1. That the applicant is filing the accompanying [APPEAL / APPLICATION] against the [JUDGMENT / ORDER] dated [DATE] passed by [COURT].
2. That the period of limitation for filing it expired on [DATE], and there is a delay of [__] days.
3. That the delay occurred for the following reasons: [GIVE A DATE-WISE EXPLANATION — e.g. date of knowledge, date of applying for and receiving the certified copy, illness with medical record, other bona fide reasons].
4. That the delay is neither intentional nor deliberate, and the applicant was prevented by sufficient cause from filing within the period of limitation.
5. That the applicant has a good case on merits, as set out in the accompanying [APPEAL / APPLICATION], and will suffer irreparable loss if the delay is not condoned.
6. That the exact appeal or application sought to be admitted is [instrument and statutory provision], for which the Court has a legally available condonation power under [provision]. Any absolute outer limit or special exclusion of Section 5 has been examined.
7. That the relevant order/event is dated [ ]; limitation began on [ ]; the prescribed period is [ ]; lawful exclusions, including certified-copy time where applicable, are [dates and basis]; the last permissible date was [ ]; filing on [ ] entails [ ] days of delay.
8. That the delay chronology is: [from–to dates, impediment, steps taken and supporting document]. The explanation covers the material period through actual filing and identifies when the impediment ceased.
9. That after becoming able to act on [date], the applicant took [specific steps and dates]. Any gap thereafter and any allegation of negligence or suppression are answered with [record].
10. That the prejudice and requested terms are [particulars]. Merits of the accompanying proceeding are stated briefly as [issue], without treating an arguable case as a substitute for sufficient cause.

PRAYER

It is, therefore, respectfully prayed that the delay of [__] days in filing the accompanying [APPEAL / APPLICATION] may kindly be condoned, and it may be decided on merits, in the interest of justice.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION UNDER ORDER VI RULE 17 READ WITH SECTION 151 CPC FOR AMENDMENT OF THE [PLAINT / WRITTEN STATEMENT]

Respectfully showeth:

1. That the applicant filed the [PLAINT / WRITTEN STATEMENT] on [DATE], and the case is now at the stage of [STAGE].
2. That the applicant seeks to make the following amendments: (a) in paragraph [__], for the words "[EXISTING TEXT]", substitute "[PROPOSED TEXT]"; (b) after paragraph [__], insert a new paragraph [__]: "[PROPOSED TEXT]"; (c) [__]. A copy of the amended [plaint / written statement] is annexed.
3. That the amendment is necessary for determining the real questions in controversy between the parties because [REASON].
4. That the effect on the nature of the [suit / defence], existing admissions and the other party is [SPECIFY]. Any prejudice can be addressed by [TERMS AND OPPORTUNITY], for the reasons stated below.
5. [If trial has commenced: That despite due diligence, the applicant could not have raised the matter before the commencement of trial because [REASON], as required by the proviso to Order VI Rule 17.]
6. That each proposed change is shown in a comparison schedule: existing paragraph [ ], exact deletion [ ], exact insertion [ ], and consequential prayer/valuation change [ ]. The clean amended pleading accompanies this application.
7. That the amendment concerns the real controversy because [specific issue]. It is based on [existing transaction / later event] occurring or discovered on [date], supported by [record].
8. That the trial [has / has not] commenced, with reference to [orders and stage]. If commenced, despite due diligence the matter could not have been raised earlier because [steps, dates and impediment]; a bare inadvertence assertion is not relied on.
9. That the proposed amendment [does / does not] affect an admission, introduce a new claim or alter the nature of the case; the actual effect is [analysis]. Any accrued limitation defence is addressed by [dates and legal basis].
10. That prejudice can be met by [reply, additional issue, evidence opportunity and costs], and the reasons the proposed change is bona fide are [facts].
11. That [OPTIONAL: retain only after verifying the cited rule and these facts] each amendment in [comparison schedule] addresses [real issue]. Applying Revajeetu, necessity, bona fides, limitation, admissions and prejudice are answered by [specific facts]; if trial has commenced, the separate due-diligence requirement is satisfied by [dated steps and impediment].

PRAYER

It is, therefore, respectfully prayed that the applicant may kindly be permitted to amend the [plaint / written statement] as proposed, and the amended pleading may be taken on record.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION UNDER ORDER XXXIX RULES 1 AND 2 READ WITH SECTION 151 CPC FOR THE GRANT OF A TEMPORARY INJUNCTION DURING THE PENDENCY OF THE SUIT

Respectfully showeth:

1. That the plaintiff / applicant has filed the accompanying suit for [RELIEF], the contents of which may be read as part of this application.
2. That the applicant has a prima facie case, as [STATE BRIEFLY — title, possession, documents].
3. That the balance of convenience lies in favour of the applicant, as [REASON].
4. That the applicant will suffer irreparable loss and injury, which cannot be compensated in money, if the defendant is not restrained from [ACT] during the pendency of the suit.
5. That there is urgency, as [the defendant is likely to __ at any time], and the object of granting the injunction would be defeated by delay. [Ground for ex parte ad interim relief, if sought.]
6. That the right requiring protection is [identified right], supported at this stage by [document and facts]. The threatened act is [specific act, date and evidence], concerning [clearly identified property or subject].
7. That the prima facie issue arises from [specific disputed fact or legal right], and the applicant’s existing position on the filing date is [possession or other factual position].
8. That withholding protection would cause [identified imminent harm] which damages would not adequately repair because [reason]. The opposing party’s likely hardship from the proposed restraint is [assessment].
9. That the balance of convenience favours [narrow restraint] because [comparative consequences]. The order sought preserves [subject] and does not effectively grant unsupported final relief.
10. That [if ex parte relief is sought] notice would defeat the object because [specific imminent event]; the applicant undertakes prompt compliance with Order XXXIX Rule 3, including supply of papers and the prescribed affidavit of compliance.
11. That material adverse facts and earlier interim orders are [full particulars]. The proposed restraint is [exact terms and duration], with a return date and service arrangement.
12. That [OPTIONAL: retain only after verifying the cited rule and these facts] the prima facie right [evidence], injury not adequately reparable by damages [facts], and comparative hardship [analysis] satisfy the distinct considerations in Dalpat Kumar. The narrow restraint sought is [terms] and the contrary material is [disclosure and answer].

PRAYER

It is, therefore, respectfully prayed that the defendant, his agents and servants may kindly be restrained by a temporary injunction from [ACT] in respect of [SUIT PROPERTY / SUBJECT MATTER] during the pendency of the suit, and an ex parte ad interim injunction may be granted till the disposal of this application.

Note: If an ex parte injunction is granted, comply with Order XXXIX Rule 3 CPC (deliver or send the papers to the opposite party as directed).

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION UNDER ORDER IX RULE 13 READ WITH SECTION 151 CPC FOR SETTING ASIDE THE EX PARTE DECREE DATED [DATE]

Respectfully showeth:

1. That the above-noted suit was decreed ex parte against the applicant / defendant on [DATE].
2. That [the summons was not duly served on the applicant — STATE FACTS / the applicant was prevented by sufficient cause from appearing when the suit was called on for hearing, because __].
3. That the applicant came to know of the ex parte decree on [DATE], when [__], and this application is filed within thirty days thereof [Article 123 of the Limitation Act, 1963]. [If delayed, file an application under Section 5 of the Limitation Act.]
4. That the applicant has a good defence on merits, as [BRIEFLY STATE], and will suffer irreparable loss if the decree is not set aside.
5. That the decree dated [ ] and preceding ex parte order dated [ ] are annexed. This application invokes Order IX Rule 13 against the decree; an application before decree would require the appropriate different provision.
6. That the service record shows [process, address, report and date]. [If challenging service: identify the defect and absence of timely notice; a mere irregularity is not relied on where actual notice and sufficient time existed.]
7. That [if relying on sufficient cause] on the hearing date [ ] the applicant was prevented from appearing by [specific circumstance], evidenced by [record]. Counsel’s inability and the applicant’s inability are separately explained where necessary.
8. That limitation under Article 123 is calculated from [decree date / legally available knowledge date for non-service], giving a last date of [ ]. Actual knowledge was acquired on [ ] by [event and proof]; if delayed, a separate condonation application explains [period].
9. That any appeal against the decree, its disposal and the effect of the Explanation to Order IX Rule 13 are disclosed as [ ]. Any execution stay requested is separately justified and is not assumed to follow from filing.
10. That [OPTIONAL: retain only after verifying the cited rule and these facts] the hearing-day impediment is proved by [record]. Applying G.P. Srivastava, it constitutes sufficient cause because [specific connection to inability to attend]; service, actual notice, limitation and subsequent diligence are independently addressed as pleaded.

PRAYER

It is, therefore, respectfully prayed that the ex parte decree dated [DATE] may kindly be set aside, the suit restored to its original number, and the applicant allowed to contest it. It is further prayed that execution of the decree may be stayed during the pendency of this application.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION UNDER ORDER IX RULE 9 READ WITH SECTION 151 CPC FOR RESTORATION OF THE SUIT DISMISSED IN DEFAULT ON [DATE]

Respectfully showeth:

1. That the above-noted suit was fixed for [STAGE] on [DATE] and was dismissed in default of appearance of the plaintiff [under Order IX Rule 8 CPC].
2. That the plaintiff and counsel could not appear on that date because [SUFFICIENT CAUSE — e.g. illness with medical record, wrong noting of the date, counsel's genuine reason].
3. That the non-appearance was neither intentional nor deliberate, and the plaintiff has always been diligent in pursuing the suit.
4. That this application is filed within thirty days of the order of dismissal [Article 122 of the Limitation Act, 1963].
5. That dismissal occurred on [date] under [exact rule and terms of order], when [both parties absent / defendant present and plaintiff absent / other situation]. The applicable restoration provision is selected accordingly, rather than assuming every dismissal falls under Order IX Rule 9.
6. That on the hearing date [ ] the applicant and counsel were unable to appear because [separate reasons and times], supported by [contemporary documents].
7. That the dismissal was learned of on [date], and steps thereafter were [dated chronology]. Limitation under the applicable article and any necessary condonation are calculated as [particulars].
8. That previous defaults, costs, compliance and the stage to be restored are [details]. The applicant offers [proportionate terms] and is ready to proceed on [task].

PRAYER

It is, therefore, respectfully prayed that the order dated [DATE] dismissing the suit in default may kindly be set aside, and the suit restored to its original number and stage.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION UNDER ORDER V RULE 20 READ WITH SECTION 151 CPC FOR SERVICE OF THE DEFENDANT / RESPONDENT BY SUBSTITUTED MEANS

Respectfully showeth:

1. That summons / notice was issued to the [DEFENDANT / RESPONDENT No. __] for [DATES] at [LAST KNOWN ADDRESS].
2. That the summons was received back unserved with the report(s) dated [DATE] that [the defendant was not found / the premises were locked / the defendant refused / the defendant is evading service].
3. That the address inquiries and ordinary-service attempts were [DATES, MODES AND RESULTS]. The specific facts supporting avoidance or inability to effect ordinary service are [FACTS], as detailed below.
4. That service by [publication in the newspaper(s) __ / affixation at the last known address / email or WhatsApp at __ / other mode] would be an effective mode of service.
5. That ordinary service was attempted on [dates] by [modes] at [verified addresses], with reports [annexure and exact endorsement]. The verification of the last known address is [record].
6. That the specific facts showing deliberate avoidance or inability to serve in the ordinary way are [events and proof]. One unexplained “unserved” return alone is not asserted as sufficient.
7. That the proposed newspaper is [name], a daily circulating in the locality where the defendant last actually and voluntarily resided, carried on business or personally worked for gain; its circulation basis is [record].
8. That the proposed notice accurately states the case, parties, court and response date. Other court-directed affixation or service measures and sufficient response time are requested as [precise proposal].

PRAYER

It is, therefore, respectfully prayed that the defendant / respondent may kindly be ordered to be served by substituted means, namely [MODE], at the cost of the applicant.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION UNDER [ORDER VII RULE 14(3) / ORDER VIII RULE 1A(3)] READ WITH SECTION 151 CPC FOR LEAVE TO PLACE ON RECORD ADDITIONAL DOCUMENTS

Respectfully showeth:

1. That the case is at the stage of [STAGE].
2. That the applicant seeks to place on record the following documents: (1) [DOCUMENT, DATE]; (2) [DOCUMENT, DATE]; (3) [__].
3. That these documents could not be filed earlier with the [plaint / written statement] because [REASON — e.g. they were not in the applicant's possession / were traced later / came into existence afterwards].
4. That each document is relevant to [IDENTIFIED ISSUE]. Any prejudice arising from its late production can be addressed by [INSPECTION, RESPONSE, EVIDENCE OPPORTUNITY AND COSTS].
5. That the applicant is [plaintiff / defendant], and leave is sought under [Order VII Rule 14(3) / Order VIII Rule 1A(3)] for the following specifically indexed documents: [description, date, source, original/copy and proposition proved].
6. That each document was obtained on [date] from [custodian]. Earlier searches and requests were [dates]; non-production with the original pleading is explained by [document-specific impediment and evidence].
7. That the case stage and evidence already recorded are [details]. Admission on file is distinguished from proof and admissibility; authenticity, original-record production and electronic certification will be addressed by [method].
8. That the proposed documents concern pleaded issues [numbers], and the opponent can respond through [inspection, reply, cross-examination or limited evidence]. Any necessary reopening is sought expressly and justified separately.
9. That if the matter is a commercial suit, the stricter applicable Order XI disclosure and reasonable-cause requirements are addressed as [facts], rather than relying only on the ordinary-suit form.
10. That [OPTIONAL: retain only after verifying the cited rule and these facts] the document-specific steps taken earlier were [dates and records]. Applying Salem Advocate Bar Association (II), late production is justified by [actual impediment], and fair response/proof opportunities are [terms], without seeking a general licence to fill omissions after evidence.

PRAYER

It is, therefore, respectfully prayed that the applicant may kindly be granted leave to produce the above documents, and the same may be taken on record.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION UNDER SECTION [497 / 503] OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 [SECTION 451 / 457 CrPC] FOR RELEASE OF [VEHICLE No. __ / CASE PROPERTY] ON SUPERDARI

Respectfully showeth:

1. That the [VEHICLE No. __, make __, model __, chassis No. __, engine No. __ / ARTICLE] was taken into possession by the police on [DATE] in [FIR No. __ dated __, under Sections __ of the Bharatiya Nyaya Sanhita, 2023 (or the corresponding IPC sections for offences before 01.07.2024), Police Station __, District __].
2. That the applicant is the [registered owner / lawful owner] of the said [vehicle / property], as per [REGISTRATION CERTIFICATE / INVOICE] (Annexure A-1).
3. That the [vehicle / property] is lying at [POLICE STATION] in the open and is deteriorating, and keeping it there serves no useful purpose. It is not required for further investigation [or: the investigation is complete].
4. That the applicant undertakes to produce the [vehicle / property] before the investigating agency or this Court whenever required, not to sell, transfer or alter its identity, and to furnish a superdari bond with surety in such amount as this Court directs.
5. That seizure occurred on [date], under [memo], and custody is [police / court / other]. The property is identified by [registration, chassis, engine, serial number, quantity and photographs].
6. That the applicant’s right to interim possession is established by [registration, invoice, financing or ownership record]; competing claimants and financier/insurer interests are disclosed as [ ].
7. That preservation by continued custody causes [documented deterioration or hardship]. Identification and evidentiary needs can be protected by [inventory, photographs/video, valuation and record] before release.
8. That the applicant undertakes to produce the property as ordered, preserve identifying features, and comply with [bond, security and non-transfer conditions]. Any confiscation proceeding, special-law restriction or rival application is [details].
9. That the applicable procedural power is [Section 497 BNSS / Section 503 BNSS / saved Section 451 or 457 CrPC], selected according to production before Court and the seizure posture; any statutory timetable and special-law regime are addressed.
10. That [OPTIONAL: retain only after verifying the cited rule and these facts] deterioration or hardship is evidenced by [records], ownership/possession claim by [documents], and identity can be preserved by [inventory and photographs]. Applying Sunderbhai Ambalal Desai, interim custody on [bond and security] is sought, subject to [special-law and rival-claim position].

PRAYER

It is, therefore, respectfully prayed that the [vehicle / property] described above may kindly be released to the applicant on superdari, on such terms and conditions as this Hon'ble Court deems fit.

Note: Photographs and a panchnama of the property are usually prepared before release. Annex the RC, insurance and identity proof.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION FOR THE ISSUE OF CERTIFIED COPIES OF [DOCUMENTS / ORDERS] [URGENT / ORDINARY]

Respectfully showeth:

1. That the applicant is [a party to / the counsel for __ in] the above-noted case [or: a non-party with interest, as stated in the accompanying affidavit].
2. That the applicant requires certified copies of the following: (1) [ORDER / JUDGMENT dated __]; (2) [DOCUMENT / DEPOSITION of __ recorded on __]; (3) [__].
3. That the copies are required for [PURPOSE — e.g. filing an appeal / production before another forum].
4. That the requisite copying fee / stamps have been affixed or deposited [and urgent charges, if applicable].
5. That the exact record required is [judgment / order / deposition / exhibit], dated [ ], in case [number, title and court]. Any exhibit or page identifier is [ ].
6. That the applicant’s entitlement as [party / authorised counsel / permitted non-party] rests on [particulars]. Confidential, sealed, juvenile or otherwise restricted records are specifically identified and permission, if required, is sought.
7. That [ordinary / urgent] processing is requested for [purpose and deadline]. Copying fee, folios, identity/authority and delivery arrangements will comply with the applicable copying rules.
8. That for limitation purposes the application date, readiness date and collection date will be recorded from the copying office; this request does not presume an automatic extension of any filing deadline.

PRAYER

It is, therefore, respectfully prayed that certified copies of the documents listed above may kindly be issued to the applicant.

Note: Attach the copying fee as prescribed. An affidavit is usually needed only where the applicant is not a party or the rules require it.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION FOR EARLY HEARING / PREPONEMENT OF THE DATE FIXED IN THE ABOVE-NOTED CASE

Respectfully showeth:

1. That the above-noted case is fixed for [DATE] for [STAGE].
2. That there is urgency because [REASON — e.g. age or ill-health of a party / imminent threat / hardship / time-bound requirement], with supporting documents annexed.
3. That advance notice of this application has been given to the counsel for the other side on [DATE].
4. That the matter was last listed on [ ] and is next fixed for [ ], at the stage of [ ]. Pending pleadings, service, defects and compliance are [accurate status].
5. That the urgency arose on [date] through [specific event], and postponement until the scheduled date risks [concrete prejudice], supported by [medical, time-bound or other record].
6. That the applicant seeks [advancement to a date / early listing of identified application], without assuming a right to bypass every older case. The requested listing period is [ ] because [reason].
7. That the other side has been [served / informed / not informed with reason], and readiness to proceed is [details]. No stay or substantive relief is presumed merely from this listing application.

PRAYER

It is, therefore, respectfully prayed that the date of hearing may kindly be preponed and the case heard at an early date, in the interest of justice.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION FOR WITHDRAWAL OF THE [SUIT / PETITION / COMPLAINT] [UNDER ORDER XXIII RULE 1 CPC / SECTION 280 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 (SECTION 257 CrPC) [verify section]]

Respectfully showeth:

1. That the applicant filed the above-noted [suit / petition / complaint] on [DATE].
2. That [the parties have amicably settled the matter on __ / the applicant does not wish to pursue it for __ reasons].
3. [If liberty is sought: That the [suit] suffers from a formal defect, namely __, or there are sufficient grounds for allowing the applicant to file a fresh suit on the same subject matter, under Order XXIII Rule 1(3) CPC.]
4. That the applicant is making this application voluntarily, without any pressure or coercion.
5. That the proceeding is [civil suit / other identified instrument], and the applicant requests [unconditional withdrawal / withdrawal with liberty to institute afresh]. The selected route and statutory power are [details].
6. That [if fresh-suit liberty is sought] the formal defect or sufficient ground under Order XXIII Rule 1(3) is [specific defect and effect]; the proposed fresh proceeding and limitation position under Rule 2 are disclosed. Liberty does not itself restart limitation.
7. That counterclaims, accrued rights, interim orders, costs and multiple plaintiffs are [particulars]. Consent of other plaintiffs where required and treatment of counterclaims are expressly addressed.
8. That the effect sought is [precise terms]. [For a criminal complaint: do not use the civil withdrawal provision; identify the lawful complaint-withdrawal, compounding, prosecution-withdrawal or quashing route, the competent actor and necessary permission.]

PRAYER

It is, therefore, respectfully prayed that the applicant may kindly be permitted to withdraw the [suit / petition / complaint] [with liberty to file a fresh one on the same cause of action], and the same may be dismissed as withdrawn.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION FOR INSPECTION OF THE JUDICIAL FILE OF THE ABOVE-NOTED CASE

Respectfully showeth:

1. That the applicant is [a party to / counsel for __ in] the above-noted case.
2. That the applicant needs to inspect the judicial file to [PURPOSE — e.g. verify the service report / note the particulars of a document / prepare for arguments].
3. That the requisite inspection fee has been [affixed / deposited], and the inspection will be carried out under the supervision of the court staff, as per the applicable rules.
4. That inspection is requested by [party / duly authorised counsel / permitted non-party], whose authority is [record], in case [number, title, court and pending/disposed status].
5. That the specific records sought are [order sheets, service reports, pleadings, exhibits], for [identified purpose]. Any sealed, confidential or protected portion is disclosed and separate permission sought where necessary.
6. That the applicant will attend at the registry-approved time, pay the applicable fee and comply with supervision, note-taking and record-handling rules; copying or photographing is not presumed authorised by inspection permission.
7. That an urgent request, if made, is based on [deadline and record]. The requested inspection date and contact particulars are [ ].

PRAYER

It is, therefore, respectfully prayed that the applicant / counsel may kindly be permitted to inspect the judicial file on a date and at a time fixed by this Hon'ble Court.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.

Model format for general reference only. Not legal advice. Adapt to the facts and the court's current rules. Source: masterlegalwork.com

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

Next date of hearing: [DATE]

APPLICATION FOR SUBSTITUTION OF SURETY / ACCEPTANCE OF FRESH BAIL BONDS AND DISCHARGE OF THE EARLIER SURETY [SECTION 489 OF THE BHARATIYA NAGARIK SURAKSHA SANHITA, 2023 (SECTION 444 CrPC)]

Respectfully showeth:

1. That the applicant / accused was granted bail vide order dated [DATE] passed by [COURT], and furnished bail bonds with [NAME OF EXISTING SURETY] as surety.
2. That the existing surety [has applied for discharge / is unable to continue as surety because __ / has died on __].
3. That the applicant offers [NAME OF NEW SURETY], [PARTICULARS], as fresh surety, who owns [PROPERTY / FIXED DEPOSIT / VEHICLE — details] and is solvent for the bond amount. The documents are annexed.
4. That the applicant undertakes to appear on every date of hearing and to abide by all the conditions of bail.
5. That bail was granted on [date] with bond amount ₹[ ], surety requirement [ ] and conditions [ ]; the operative order and accepted bond are annexed.
6. That substitution is sought because [existing surety’s reason and supporting record]. The applicant requests release/discharge of the former surety only by the Court’s order and after acceptance of the replacement as required.
7. That the proposed surety is [name, relationship, address and means], with identity and solvency/other documents [ ]. Any restriction in the original order is disclosed and modification, where needed, is sought expressly.
8. That attendance and bail compliance to date are [details]. Any breach or pending discharge request is disclosed, and the proposed transition avoids a lapse in the security required by the Court.
9. That financial hardship or inability to produce a particular local surety is [supported facts]; reasonable alternative security or proportionate modification is requested as [precise terms], subject to applicable law.
10. That [OPTIONAL: retain only after verifying the cited rule and these facts] the applicant’s means and existing security burden are evidenced by [records]. Applying Moti Ram, the proposed security [terms] is proportionate and practicable; discharge of the former surety and acceptance of the replacement remain subject to this Court’s order.

PRAYER

It is, therefore, respectfully prayed that the fresh bail / surety bonds of [NAME OF NEW SURETY] may kindly be accepted, and the earlier surety discharged, in accordance with law.

IN THE COURT OF [DESIGNATION OF THE PRESIDING OFFICER], [PLACE]

[CASE TYPE] No. ____ of 20__

Versus

AFFIDAVIT

Affidavit of [NAME OF DEPONENT], [S/o / D/o / W/o] [NAME], aged about [__] years, resident of [FULL ADDRESS WITH PIN CODE].

I, the above-named deponent, do hereby solemnly affirm and declare as under:

1. That the deponent is competent to swear this affidavit and the accompanying [suit / petition / application] has been drafted by counsel on the deponent’s instructions. Its contents have been read over and explained in [LANGUAGE], understood by the deponent, and are incorporated as part and parcel of this affidavit; the factual statements are true to the deponent’s knowledge or identified records, and legal submissions are based on advice believed to be true.
2. That [no same or similar suit / petition / application on the same cause of action has been filed / the following prior or pending proceedings, outcomes and orders are fully disclosed: ___]. Nothing material has been concealed.

DEPONENT

VERIFICATION

Verified at [PLACE] on [DATE] that paragraphs 1 and 2 above are true and correct to my knowledge and identified records, with legal submissions based on advice believed true. Nothing material has been concealed.

DEPONENT

Note: To be sworn before an Oath Commissioner / Notary Public and stamped as required by the applicable rules.