Sample Fra Objections

IN THE COURT OF IVth ADDITIONAL DISTRICT & SESSIONS JUDGE AT KARACHI (CENTRAL)

FRA NO. 118/2024

[INSTITUTION NAME]

[AREA REDACTED], [AREA REDACTED], Karachi.

Through its authorized person

[AUTHORIZED PERSON NAME] S/o [FATHER NAME],

Muslim, Adult R/o H. no 43/22 [AREA REDACTED],

Liaquatabad, Karachi…………………………………………. Appellant

Vs

[RESPONDENT NAME]

S/o [FATHER NAME]

Muslim, Adult, Tenant of [SHOP NUMBER REDACTED],

[INSTITUTION NAME]

[AREA REDACTED], Liaquatabad, Karachi………………………………… Respondent

OBJECTIONS TO FIRST RENT APPEAL UNDER SECTION 21 OF SINDH RENTED PREMISES ORDINANCE 1979

It is respectfully submitted that the instant appeal is liable to be dismissed on the following preliminary legal objections.

That the appellant has approached this Hon’ble Court with malafide intentions and in order to frustrate the very purpose of law therefore, the above appeal is liable to be dismissed.

That the above appeal is based on concealment of facts therefore, the same may be dismissed with special cost.

That the above appeal is the result of malafide and ill-will of the appellant and therefore, the same may be dismissed.

Without prejudice to the above preliminary objections the para-wise reply to the instant appeal are as follows:-

That the contents of para no.1 are admitted.

That the contents of para no. 2 are partly admitted to the extent that the monthly rent of the subject premises is 1800/-, which is exclusive of the utility bills charges and is liable to be paid in the advance and that despite of the demise of the father of the opponent, the rent receipts are still getting issued in his name and the rest of the contents are vehemently denied and the appellant is put to strict proof thereof.

That the contents of para 3 are vehemently denied and the appellant is put to strict proof thereof. It is pertinent to mention here that the respondent had been regularly paying the rent to the appellant punctually on monthly basis excluding amenities charges against the issuance of the proper rent receipt up to the month of December 2022. However the appellant refused to issue the rent receipt of the month of December to the respondent. Furth