Appeal against Family Court Decree

IN THE appellate_court, district

Appeal No. _____ of year Against judgment and decree dated decree_date passed in Family Suit No. suit_number of suit_year

appellant_name, appellant_description, resident of appellant_address, holding CNIC No. appellant_cnic ... Appellant

VERSUS

respondent_name, respondent_description, resident of respondent_address, holding CNIC No. respondent_cnic ... Respondent

APPEAL AGAINST DECREE OF FAMILY COURT

Respectfully sheweth:

1. That the Appellant is aggrieved by the judgment and decree passed on decree_date by the Learned Judge of the Family Court, family_court_district, in Family Suit No. suit_number of suit_year.

2. That a certified copy of the impugned decree is annexed as Annexure 'A'.

3. That the Appellant filed the aforesaid family suit suit_type.

4. That the learned Judge passed the decree decree_findings, which decision is erroneous in law and against the evidence on record.

5. That the grounds of appeal are as follows:

appeal_grounds

6. That the impugned decree has caused irreparable harm to the Appellant and necessitates immediate interference by this Honourable Court.

7. That the present appeal has been filed within the prescribed period of limitation under Section 14 of the West Pakistan Family Courts Act 1964.

8. That no appeal against the same decree has been filed before this or any other forum.

That the present appeal is filed within the period of limitation prescribed by law, computed from the date of communication of the impugned order to the Appellant. The certified copy of the impugned order has been duly obtained and is annexed.

That the impugned order suffers from material illegality, irregularity, perversity, and is not sustainable in fact or in law. The findings recorded by the learned forum below are contrary to the record and the applicable legal principles.

That the impugned order suffers from material illegality, irregularity, and is contrary to the record. The findings of the learned forum below are perverse, contrary to evidence, and are not sustainable in fact or in law.

That the present appeal is filed within the prescribed period of limitation computed from the date of communication of the impugned order to the Appellant. The certified copy of the impugned order has been duly obtained and is annexed.

That the Appellant has not previously preferred any appeal, revision, or review against the same impugned order before any other forum, and is approaching this Honourable Court with clean hands.

PRAYER

It is, therefore, most respectfully prayed that this Honourable Court may be pleased to:

(a) Allow the present appeal and set aside the impugned decree dated decree_date;

(b) alternate_relief

(c) Award costs of the appeal; and

(d) Grant such other relief as deemed just and equitable.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of the above memorandum of appeal are true and correct to the best of my knowledge and belief.

_____________________________ appellant_name Appellant Through: _____________________________ counsel_name Advocate