Application for Summoning of Witnesses

IN THE COURT OF THE LEARNED court_designation, district

Civil Suit No. suit_number of year

plaintiff_name, son/daughter of plaintiff_father, resident of plaintiff_address, holding CNIC No. plaintiff_cnic ... Plaintiff

VERSUS

defendant_name, son/daughter of defendant_father, resident of defendant_address, holding CNIC No. defendant_cnic ... Defendant

APPLICATION FOR ISSUANCE OF SUMMONS TO WITNESSES UNDER ORDER XVI RULE 1 OF THE CODE OF CIVIL PROCEDURE 1908

Respectfully sheweth:

1. That in the course of the trial of the present suit, the Plaintiff seeks to produce evidence through examination of witnesses in order to establish the allegations in the plaint.

2. That the following witnesses are proposed to be summoned for examination before this Honourable Court: witness_list.

3. The details of the proposed witnesses are as follows:

witness_details

4. That the proposed witnesses are essential to the case and their oral testimony is necessary to establish key_facts_to_be_established.

5. That each of the proposed witnesses has direct knowledge of the facts nature_of_their_knowledge.

6. That the Plaintiff has prepared a list of questions to be put to each witness in order to establish the allegations in the plaint. The relevant documents and records are relevant_documents_description.

7. That the proposed witnesses are resident of witness_locations and can be easily summoned by this Honourable Court. The necessary summons can be issued in accordance with the procedure laid down in the Code of Civil Procedure 1908.

8. That the examination of the proposed witnesses will not cause undue delay or prejudice to the Defendant, as the Defendant will have full opportunity to cross-examine each witness and to challenge the evidence presented.

9. That the Plaintiff is prepared to bear witness_expenses incurred in the summoning and examination of the witnesses.

PRAYER

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

(a) Issue summons to the witnesses named herein;

(b) Direct the witnesses to appear in Court on such date as may be fixed for their examination;

(c) Direct the production of the documents mentioned above;

(d) Allow examination, cross-examination, and re-examination of the witnesses as per the procedure laid down in the Code of Civil Procedure 1908; and

(e) Grant any other relief deemed just and proper in the circumstances.

VERIFICATION

Verified on solemn affirmation at verification_place on this _____ day of _____, year, that the contents of the above application are true and correct to the best of my knowledge and belief and nothing material has been concealed therefrom.

_____________________________ plaintiff_name Plaintiff Through: _____________________________ counsel_name Advocate