Fir Essentials In Pakistan

Here's a simplified template for a plaint for the specific performance of an agreement. You should tailor it to fit the specific details of your case.
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In the Court of [Name of the Court]
Suit No. [Suit Number]
[Plaintiff's Name]
Plaintiff
Versus
[Defendant's Name]
Defendant
Plaint under Section * of the Specific Relief Act, * for Specific Performance of Contract
The Plaintiff respectfully states as follows:
*. Parties:
- The Plaintiff, [Plaintiff's Name], residing at [Plaintiff's Address].
- The Defendant, [Defendant's Name], residing at [Defendant's Address].
*. Jurisdiction:
- This Honorable Court has jurisdiction to entertain and try this suit as the cause of action arose within its jurisdiction.
*. Facts of the Case:
- On [Date], the Plaintiff and Defendant entered into an agreement for [brief description of the agreement, e.g., sale of property, service, etc.].
- The terms of the agreement were that [summarize key terms of the agreement, including the price, timelines, and any conditions].
*. Performance by Plaintiff:
- The Plaintiff has fulfilled all their obligations under the agreement, including [specific actions taken by the Plaintiff, such as payment, delivery of documents, etc.].
*. Breach by Defendant:
- Despite repeated requests, the Defendant has failed to perform their obligations under the agreement, specifically [detail the breaches by the Defendant].
*. Legal Right:
- Under Section * of the Specific Relief Act, *, the Plaintiff is entitled to the specific performance of the agreement as [explain why damages are not an adequate remedy, e.g., unique property, irreplaceable service, etc.].
*. Cause of Action:
- The cause of action arose on [Date], when the Defendant failed to [specific action the Defendant failed to perform].
*. Relief Sought:
- The Plaintiff prays for a decree of specific performance directing the Defendant to [specific action required by the Defendant, e.g., transfer the property, deliver the service, etc.].
- Any other relief that this Honorable Court deems fit and proper in the circumstances of this case.
- Costs of the suit

Sure, here's a simplified template for an application under Order * of the Code of Civil Procedure (CPC) for adjournment:
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In the Court of [Name of the Court]
Suit No. [Suit Number]
[Plaintiff's Name]
Plaintiff
Versus
[Defendant's Name]
Defendant
Application for Adjournment under Order * Rule * of the Code of Civil Procedure, *
The Applicant respectfully states as follows:
*. Parties:
- The Plaintiff, [Plaintiff's Name], residing at [Plaintiff's Address].
- The Defendant, [Defendant's Name], residing at [Defendant's Address].
*. Pending Hearing:
- The next hearing of the above-mentioned suit is scheduled on [Date].
*. Reason for Adjournment:
- Due to [specific reason, e.g., medical emergency, unavailability of a crucial witness, need for additional time to gather evidence], the Applicant is unable to proceed with the case on the scheduled date.
*. Previous Adjournments:
- The Applicant has/has not previously sought adjournments in this matter. [Provide details if any adjournments were previously granted or state that no previous adjournments were sought.]
*. Good Faith:
- This request for adjournment is made in good faith and not for the purpose of causing any undue delay or prejudice to the opposing party.
*. Prayer:
- The Applicant prays that this Honorable Court may graciously grant an adjournment of the hearing scheduled on [Date] to a later date as deemed appropriate by the Court.
*Any other relief that this Honorable Court deems fit and proper in the circumstances of this case.*
Place: [City]
Date: [Date]
[Your Name]
[Your Signature]
[Your Address]
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Would you like more details on any specific part of this application?

Sure, here's a simplified template for an application under Order * Rule * of the Code of Civil Procedure (CPC):
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In the Court of [Name of the Court]
Suit No. [Suit Number]
[Plaintiff's Name]
Plaintiff
Versus
[Defendant's Name]
Defendant
Application under Order * Rule * of the Code of Civil Procedure, *
The Applicant respectfully states as follows:
*. Parties:
- The Plaintiff, [Plaintiff's Name], residing at [Plaintiff's Address].
- The Defendant, [Defendant's Name], residing at [Defendant's Address].
*. Suit Details:
- The above-mentioned suit involves [brief description of the suit, e.g., property dispute, contract enforcement, etc.].
*. Stage of Suit:
- The suit is currently at the stage of [current stage, e.g., evidence, arguments, etc.].
*. Request for Judgment:
- The Applicant prays that this Honorable Court may be pleased to pronounce the judgment in the above-referredsuit as per Order * Rule * of the CPC within the prescribed time.
*. Grounds for Application:
- All necessary proceedings have been completed, and the matter is ripe for judgment.
- There has been no undue delay on the part of the Applicant.
*. Prayer:
- The Applicant prays that this Honorable Court may graciously pronounce the judgment in the above-mentioned suit at the earliest convenience.
Any other relief that this Honorable Court deems fit and proper in the circumstances of this case.
Place: [City]
Date: [Date]
[Your Name]
[Your Signature]
[Your Address]
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Would you like more details on any specific part of this application?