Derivative Action by Member

IN THE COURT OF THE LEARNED court_judge court_name, city Or BEFORE THE SECURITIES AND EXCHANGE COMMISSION OF PAKISTAN Islamabad

PETITION FOR LEAVE TO COMMENCE DERIVATIVE ACTION UNDER SECTION 290 OF THE COMPANIES ACT 2017

The undersigned member hereby petitions for leave to commence a derivative action on behalf of company_name against the Directors and other parties for the wrongs committed against the Company.

1. PETITIONER AND COMPANY: The Petitioner, petitioner_name, is a shareholder of company_name, a company incorporated under the Companies Act 2017 with CRN crn, having its registered office at company_address. The Company is engaged in company_business.

2. SHAREHOLDING: The Petitioner holds petitioner_shares ordinary shares of face value Rs. share_face_value/- each, representing petitioner_percentage% of the Company's issued capital. The Petitioner has maintained this shareholding for the past shareholding_years years and is a registered member of the Company.

3. THE WRONG COMMITTED: A serious wrong has been committed against the Company by wrong_perpetrators. The nature of the wrong is as follows: wrong_description.

4. DETAILS OF THE WRONG: detailed_wrong_account. These actions constitute a breach of fiduciary duty, fraud, and/or misappropriation of Company assets.

5. FINANCIAL LOSS TO COMPANY: As a result of the above wrong, the Company has suffered a loss of approximately Rs. company_loss_amount/- (Rupees loss_words only). This loss directly prejudices the value of shareholder investments and impairs the Company's financial position.

6. DEMAND MADE ON BOARD: The Petitioner formally demanded that the Board of Directors commence proceedings against the wrongdoers and recover the loss. This demand was made by letter dated demand_date, addressed to the Company Secretary and all Directors. A copy of this letter is attached as Annexure A.

7. REJECTION OF DEMAND: demand_rejection_details. The Board has either refused the demand, failed to respond within a reasonable time, or made no effort to pursue recovery of the loss. This refusal or inaction is unreasonable and unjustified.

8. GROUNDS FOR DERIVATIVE ACTION: derivative_action_grounds. The Petitioner has a clear and credible claim that a wrong has been committed against the Company and that the Company has suffered loss.

9. ADEQUACY AND PROPRIETY: A derivative action is the appropriate remedy in this case. The Petitioner undertakes to prosecute the action in good faith and with diligence. The Petitioner shall indemnify the Company against costs and give such security as may be directed by the Court or Commission.

10. EVIDENCE: The Petitioner has attached the following supporting documents: (a) evidence_one (dated evidence_date_1) (b) evidence_two (dated evidence_date_2) (c) evidence_three (dated evidence_date_3) (d) evidence_four (dated evidence_date_4) (e) evidence_five (dated evidence_date_5)

11. RELIEF SOUGHT: Under Section 290 of the Companies Act 2017, the Petitioner seeks leave to commence and conduct proceedings on behalf of company_name for recovery of the loss suffered by the Company. The Petitioner further seeks such consequential relief as may be appropriate.

12. VERIFICATION: I, petitioner_name, do solemnly affirm that the contents of this petition are true and correct to the best of my knowledge and belief.

_____________________________ petitioner_name Member/Petitioner CNIC No. petitioner_cnic Contact: petitioner_phone Date: _______________ COUNSEL: _____________________________ Name: counsel_name Roll No: counsel_rollno Bar Council: bar_council Court: court_name Date: _______________