Intra-Court Appeal (ICA)

IN THE HIGH COURT OF province AT principal_seat (DIVISION BENCH)

Intra-Court Appeal (ICA) No. _____ of year Under Section 3 of the Law Reforms Ordinance 1972 In the matter of: W.P. / Civil Suit / Cr. Misc. No. single_judge_case_number of single_judge_year Decided by the learned Single Judge on single_judge_judgment_date

appellant_name, son / daughter of appellant_father, holder of CNIC / CUIN No. appellant_id, having registered office / residence at appellant_address ... Appellant

VERSUS

respondent_name, respondent_description, having registered office / residence at respondent_address ... Respondent

INTRA-COURT APPEAL UNDER SECTION 3 OF THE LAW REFORMS ORDINANCE 1972 AGAINST THE JUDGMENT / ORDER DATED single_judge_judgment_date PASSED BY THE LEARNED SINGLE JUDGE

Respectfully sheweth:

1. That the Appellant was the appellant_role_below (petitioner / plaintiff / respondent) before the learned Single Judge of this Honourable Court in the captioned proceedings, which were instituted on below_filing_date and decided by the impugned judgment / order dated single_judge_judgment_date.

2. That the brief facts of the case are as follows: brief_facts. The matter before the learned Single Judge raised, inter alia, the following questions: questions_below.

3. That the learned Single Judge, by the impugned judgment / order, has single_judge_decision (dismissed the petition / decreed the suit in favour of the Respondent / dismissed the suit / passed the impugned interim order), the operative portion of which reads as follows: single_judge_operative_part.

4. That the impugned judgment / order is appealable to this Honourable Division Bench by way of an intra-court appeal under Section 3 of the Law Reforms Ordinance 1972, the proceedings before the learned Single Judge having been on the original side / under Article 199 of the Constitution / under any other jurisdiction expressly attracting the said remedy.

5. That, aggrieved by the impugned judgment / order, the Appellant prefers this intra-court appeal on, inter alia, the following grounds:

GROUNDS OF APPEAL

(a) That the impugned judgment / order suffers from a misappreciation of the facts on record, particulars whereof are: factual_grounds.

(b) That the learned Single Judge has erred in law in legal_grounds, contrary to the binding precedents of the Supreme Court / Honourable Division Benches in relevant_precedents.

(c) That the impugned judgment / order does not address material submissions made by the Appellant before the learned Single Judge, including: omitted_submissions.

(d) That the impugned judgment / order is contrary to the established principles of legal_principle (statutory construction / natural justice / due process / proportionality).

(e) That the impugned judgment / order is bad in law on the additional grounds set out at: additional_grounds.

6. That the present appeal is filed within the period of limitation prescribed for intra-court appeals under the High Court Rules and Orders / the Limitation Act 1908. The certified copy of the impugned judgment / order was applied for on copy_application_date and made available on copy_received_date, and the present appeal is filed within days_within_limitation days of the said date.

7. That the Appellant has, alongside this appeal, moved an application seeking interim relief / stay of operation of the impugned judgment / order, as the operation of the said judgment / order is causing irreparable prejudice to the Appellant, particulars whereof are detailed in the said application.

PRAYER

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

(a) Set aside the impugned judgment / order dated single_judge_judgment_date passed by the learned Single Judge in single_judge_case_number of single_judge_year;

(b) Allow the present intra-court appeal in favour of the Appellant;

(c) Restore / reinstate the relief originally sought by the Appellant before the learned Single Judge / grant the alternative relief set out at: alternative_relief;

(d) Stay the operation of the impugned judgment / order pending the disposal of the present appeal;

(e) Award costs of the appeal in favour of the Appellant; and

(f) Pass any other order which this Honourable Court may deem just and proper.

VERIFICATION

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

_____________________________ appellant_name Appellant Through: _____________________________ counsel_name Advocate, Hon'ble High Court