Petition for Leave to Appeal to the Supreme Court

IN THE SUPREME COURT OF PAKISTAN (APPELLATE JURISDICTION)

Leave to Appeal (Civil) No. _____ of year

petitioner_name, petitioner_party_status, petitioner_address ... Petitioner

VERSUS

respondent_name, respondent_party_status, respondent_address ... Respondent

PETITION FOR LEAVE TO APPEAL UNDER ARTICLE 185(3) OF THE CONSTITUTION OF PAKISTAN 1973

Respectfully submitted:

1. That the Petitioner seeks leave to appeal to this Honourable Court against the judgment and decree dated impugned_judgment_date passed by the impugning_court in impugned_case_number. A certified copy of the impugned judgment is annexed as Annexure 'A'.

2. That the Petitioner is aggrieved by the impugned judgment on the grounds that the impugning_court has misinterpreted and wrongly applied the law, resulting in a judgment that is manifestly unjust and contrary to the principles of natural justice.

3. That the impugned judgment involves substantial questions of law of public importance as well as law which ought to be settled or clarified by this Honourable Court. Specifically, the judgment raises the following questions of law: questions_of_law.

4. That the impugned judgment is based on a perverse reading of the evidence and the applicable law. The impugning_court has overlooked and ignored material evidence that would have led to a different conclusion.

5. That the decision of the impugning_court is in direct conflict with the judgment(s) delivered by this Honourable Court or the High Courts in conflicting_judgments. This creates uncertainty in the law and necessitates intervention by this Honourable Court.

6. That the Petitioner has suffered substantial loss and irreparable harm as a result of the impugned judgment. substantive_grounds.

7. That this is not a case of mere re-appreciation of evidence or minor error in judgment. The errors are of such magnitude and consequence that they render the judgment liable to be set aside or modified by this Honourable Court.

8. That the Petitioner filed the present Petition for Leave to Appeal within the prescribed time limit. The Petition is supported by substantial grounds and raises questions of law which this Honourable Court is entitled to consider.

9. That the case law is well-settled that this Honourable Court grants leave to appeal when questions of public importance or legal significance are raised. See precedent_cases.

GROUNDS FOR LEAVE TO APPEAL

(a) That the impugned judgment is based on a misinterpretation and wrong application of statute_misapplied;

(b) That the impugning_court has wrongly held that wrongly_held_proposition;

(c) That material evidence has been overlooked and ignored by the impugning_court;

(d) That the impugned judgment is in conflict with the principles established in conflicting_authority;

(e) That the impugned judgment involves a substantial question of law of public importance;

(f) That the impugned judgment has caused grave injustice to the Petitioner and requires interference.

LIMITATION: The present appeal is filed within the period of limitation prescribed by the parent statute, computed from the date of communication of the impugned order to the appellant. The certified copy of the impugned order has been obtained and is annexed.

PRAYER

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

(a) Grant leave to appeal against the impugned judgment dated impugned_judgment_date;

(b) Accept the appeal and set aside the impugned judgment;

(c) Pass such order and judgment as this Honourable Court deems just and equitable in the circumstances of the case;

(d) Award costs and such other relief as may be deemed appropriate.

VERIFICATION

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

_____________________________ petitioner_name Petitioner Through: _____________________________ counsel_name Advocate