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A broad approach to drafting of any Application / Petition / Complaint may be undertaken in three chronological “Heads” – 1. Reliefs prayed for / claimed; 2. Grounds for Reliefs prayed for / claimed; (both factual and legal); 3. Narration of facts substantiating the said grounds. Further, there may be narration of such facts in the beginning of the draft, which would lay foundation for “material facts of the case”. Grounds for Reliefs prayed for / claimed implies (a) the essence / conclusion of material facts; and (b) other legal provisions which supports the reliefs prayed for / claimed. IN THE METROPOLITANS MAGISTRATES _____COURT AT ESPLANADE, MUMBAI C.C. No. ________/ SS / 2015 ______________________ ...
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