Written Reply to Application for list of Witnesses

 

Written Reply to Application for list of Witnesses 

This is format of Written Reply to Application for list of Witnesses. 

In the name of ALLAH, the most beneficent, the most merciful

  

IN THE COURT OF MR. ______________, LEARNED CIVIL JUDGE RAWALPINDI

 

___________

Versus

___________

etc.

 

(SUIT FOR SPECIFIC PERFORMANCE OF AGREEMENT AND PERMANENT INJUNCTION)

 

APPLICATION U/O 16 RULE 1 OF CPC FOR PERMISSION TO FILE LIST OF WITNESSES ON BEHALF OF PLAINTIFF

 

WRITTEN REPLY ON BEHALF OF RESPONDENTS NO. 6 TO 9

 

Respectfully Sheweth:

 

PRELIMINARY OBJECTIONS:

 

1.        That the application is contrary to the provisions of Order 16 Rule 1 CPC,  hence merits dismissal.

2.   That no good cause has been shown in the application for omission of the proposed witnesses from the list, therefore, the application is liable to be dismissed.

3.    That the plaintiff has not approached before this Honourable Court with clean hands and has suppressed material facts from this Honourable Court therefore not entitled for any discretionary relief.

ON FACTS:

 

1.               Para No.1 is correct.

2.               Para No.2 is correct.

3.               Para No. 3 is incorrect, hence denied. The issues were settled after impleading the applicants as plaintiffs, after death of their predecessor.

4.               Para No. 4 is correct.

5.               Para No. 5 needs no reply as it is matter of record.

6.               Para No. 6 is incorrect as stated, hence denied.

7.               Para No. 7 is incorrect, hence denied.

8.               Para No. 8 is incorrect, hence denied.

9.               Para No. 9 is denied.

10.         Para No. 10 is  incorrect as stated, hence denied.

11.         Para No. 11 is incorrect, hence denied.

PRAYER:

 

It is therefore respectfully prayed that the application filed by the plaintiff/applicant may graciously be dismissed with costs.

 

Answering respondent

 

Through

 

 

Advocate High Court