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.
Framing of
Revision Petition
Short title of the Suit
Index
Proforma (Roznama)
Synopsis of the case –
Chronology of
events (date wise; and where the time is of relevance, time-wise) that has led
to the present situation of grievance. You need to mention in very brief as
what has happened on each of relevant dates; i.e. state bare facts, and do not
state your “views” on the facts. If you are relying on any document, the
substance of the document may be stated herein.
Main points to be urged:
The grounds for the Reliefs prayed
may be set out as points to be urged.
Acts (Statutes) and authorities (judgments) relied upon
Full Cause title –
APPLICATION FOR REVISION OF
ORDER DATED _______
MAY IT PLEASE MY LORDS;
1. In brief the chronology of events that transpired during the
conclusion of Order / Judgment which is sought to be Revised.
Hereto annexed and marled as Exhibit “A” the copy
of impugned Order which is sought to be Revised.
2. BEING AGGRIEVED AND DISSATISFIED by the Judgment and Order
dated ______, the Petitioner herein has filed this Petition / Application on
the following amongst other grounds which are without prejudice to and in the
alternative to one another.
3.
GROUNDS
a) That
the Court below have exercised a jurisdiction not vested in it by law, or
b) That
the Court below have failed to exercise a jurisdiction so vested, or
c) That
the Court below have acted in the exercise of its jurisdiction illegally or
with material irregularity,
4. The Petitioner states that in light of the aforesaid facts
and circumstances and upon the grounds stated hereinabove, it is just and
reasonable, and it would be in the interest of justice that the said Order be
Revised.
5. The
Petitioner states that in the present case, no appeal lies either to the High
Court or to any Court subordinate thereto, to the impugned Order.
6. The Petitioner craves leave to add, amend, alter and/or
delete any of the aforesaid grounds if required.
7. The Petitioner states that except this, no other petition,
appeal, application or review of the said Order is filed or pending either in
this Hon’ble High Court or in the Hon’ble Supreme Court of India.
8. The Petitioner submits that the present Revision Petition is
filed within limitation period. The impugned Order was passed on ______. The
Petitioner applied for certified copy on ______. However, till the date of
filing this Application, the certified copy is not made available.
9. The Petitioner pays the applicable Court fees.
10. The Petitioner therefore prays:
(a) The Hon’ble
Court may pleased to call for the record of the case
(b)
(c) Such other and further relief as this Hon’ble Court may deem
fit and proper in the circumstances of the present case be granted.
Verification clause (O.6 R.15)
The person verifying the Plaint shall in the Verification Clause,
specify, by reference to the numbered paragraphs of the pleading, what he
verifies from his own knowledge and what he verifies upon information received
and believed to be true. [(O.6 R.15)]
Vakalatnama
Memorandum of Regd address of the Plaintiff / Advocate on
record
List of Documents relied upon
Exhibits / documents annexed in the Plaint
Among other documents, Advocate’s Certificate to be annexed.
Docket
Substantive law
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