APPLICATION U/S 15 OF THE SINDH RENTED PREMISES ORDINANCE 1979



APPLICATION U/S 15 OF THE SINDH RENTED PREMISES ORDINANCE 1979 SAMPLE


IN THE COURT OF VIth RENT CONTROLLER AT KARACHI (EAST) 
R. C. No. /2009 
Anis Bukhari s/o Bilal Bukhari, Muslim, Adult, r/o Flat No. E-114, 
Noor Centre, Shah Faisal Colony, Karachi. --------------------------------- APPLICANT 
v. 
Sikandar Humayun s/o Hafeez Humayun Muslim, Adult, carrying business under 
the name and style of Sidra Studios, Shop No. 15, Office-cum-Residential 
“T” shape, situated at Shaukat Market, on Plot No. 140-Z, 
Block-X, Shah Faisal Colony, Karachi. ------------------------------------- OPPONENT 

APPLICATION U/S 15 OF THE SINDH RENTED PREMISES ORDINANCE 1979 

The Applicant respectfully prays as under: 

1. That the Applicant is the owner/landlord of property bearing Plot No. 140*Z, with construction thereon, admeasuring 500 square yards, building known as “Shaukat Market”, situated at Block-X, Shah Faisal Colony, Karachi, having eleven shops on the ground floor and residential portion on the first floor with a room on the top. 

2. That the Opponent is a tenant of the Applicant at the rate of Rs. 6, 000/- (Rupees Six Thousand Two Hundred Only) in respect of Shop No. 15, Shaukat Market, at Plot No. 140-Z, Block-X, Shah Faisal Colony, Karachi, hereinafter referred to as the “said premises”. It is submitted that the monthly rent is payable in advance on or before the 10th day of every English calendar month. 
                (Photocopy of the rent agreement is attached herewith and marked as Annexure “A1”

3. It is submitted that according to clause 3 of the rent agreement, it is the responsibility of the Opponent to pay the utility bills of the said premises. However, the Opponent has failed and neglected to pay the electricity bills for the last six months, as such, the outstanding amount stands to Rs. 30, 000/- (Rupees Thirty Thousand Only). It is submitted that the electricity connection to the said premises has, therefore, been disconnected. 
                (Photocopy of the arrears of electric bills is annexed herewith and marked as Annexure “A-2”) 

4. That the Opponent is also a habitual and wilful defaulter in payment of monthly rent, as such, the last rent was paid by him for the month of April, 2009. Even otherwise, he is a habitual and wilful defaulter in payment of rent for the months of January-March, 2009. The Opponent is in arrears of rent of Rs. 18, 000/- (Rupees Eighteen Thousand Only). It is submitted that the Applicant has continuously demanded the arrears of rent, but the Opponent has failed and neglected to pay the same on one pretext or the other. 
            (Photocopy of the last rent receipt is annexed herewith and marked as Annexure “A3”) 

5. That the Applicant intends to run a mobile phones business, as such, he requires the said premises for his personal, bonafide use and in good faith. 

HOW TO WRITE AN APPLICATION U/S 15 OF THE SINDH RENTED PREMISES ORDINANCE 1979?

6. That the Opponent being a wilful and habitual defaulter in the payment of monthly rent as well the electricity charges of the said premises and that the said premises is required by the Applicant to establish a mobile phones business has rendered the Opponent liable to be ejected from the said premises. 

7. That the cause of action finally arose to the Applicant, when the Opponent failed to pay his rent as well as the electricity charges and thereafter it is a continuous cause of action. 

8. That for the purposes of Court fee and jurisdiction, the proper court fee is affixed thereon. The premises being within P. S. ______________________, this Hon’ble Court has the jurisdiction to entertain this Application. 

PRAYER 


The Applicant respectfully prays that this Hon’ble Court may be pleased to: 

a. Pass an order directing the Opponent to hand over peaceful and vacant possession of the said premises to the Applicant; 

b. Grant any other further and/or better relief that this Hon’ble Court may deem fit and proper, under the prevalent circumstances.

c. Costs of the Application. 

Karachi                                                                                         APPLICANT

Dated: 10/12/2009                                                  ADVOCATE FOR THE APPLICANT

VERIFICATION 

I, Anis Bukhari s/o Bilal Bukhari, Muslim, Adult, r/o Flat No. E-114, Noor Centre, Shah Faisal Colony, Karachi, holding CNIC No. 42156-6985201-8, do hereby verify on oath that whatever is mentioned above is true and correct to the best of my knowledge and belief. 

                                                                                                        DEPONENT 
                                                        Identified by me.

  • Document(s) filed: Annexure ‘A-1 to A-3’ 
  • Document(s) relied upon: Annexure ‘A-1 to A-3’and all other documents that are necessary and relevant to the subject matter. 
  • Address for service: As mentioned in the Title. 
  • Address for the Applicant’s counsel: As mentioned in the Vakalatnama 
Drafted by me
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