IN THE COURT OF _____ RENT CONTROLLER KARACHI

CENTRAL
M R C NO ____ of 2021

Mohammad Mirza
S/o __________
Muslim adult, Tenant of
_____________ Federal-B area Karachi --- Applicant

Versus

Shahzad Mohammad
S/o _____________
Muslim adult, landlord of
_______________Federal-B area Karachi
And resident of______________ Karachi --- Opponent

APPLICATION UNDER SECTION 10(3) of SINDH RENTED

PREMESIS ORDINANCE 1970

The applicant most respectfully submitted as under;

1. That the applicant is the tenant of the opponent in respect of the ABC
place Federal-B area Karachi, hereinafter referred to as the rented
premises and now the monthly rent of the place is Rs_______. The
applicant is the tenant of the opponent since from _____ till now and the
original agreement of the tenancy is in possession of the landlord/tenant. It
is also submitted that all previous rents of the place have been paid to the
opponent regularly without any delay and default. That the advance of Rs
__________ has been deposited to the opponent.

2. That the monthly rent has always been paid under initial of the opponent
within due date as is evident from the record maintained by the applicant
and the opponent issued/not issued receipt of the rent payment at his
convenience. The rent of the previous month (months up till now) i.e
August/July was paid on ___ date of 2021, which date is well within the
due dates as stipulated in the rent agreement.
3. That the applicant (tenant) tendered rent for the month of _____ through
Money Order which he sent on __/__/2021, under receipt No. 0000 but the
opponent/landlord refused to receive the said Money Order and returned to
the applicant by postal authorities.

4. That the applicant/tenant made every effort to pay the rent to the
opponent/landlord through direct cash payment and through Money order
which the landlord willfully declined in order to succeed in his malafide
intention for the eviction of the tenant illegally.

5. That the office of the Senior Post Master Federal-B Area F-B.P. O Karachi
issued certificate on __/__/2021. Copies of Money Order token and its
returned receipts certificate are enclosed marked as Annexure- A-1 and A-
2.

6. That the refusal on the part of the opponent is deliberate and intentional as
the opponent/landlord intends to seek eviction of the applicant/tenant
malafidely, unjustly and illegally.

7. That in the view of facts and circumstances stated above and refusal of
the landlord to receive the monthly rent gives reasonable apprehension to
the applicant to file a miscellaneous rent case and start deposit the rent to
the court in order to avoid himself from the opponent/landlord’s malafide
intention of eviction through technical means.

8. That the cause of action accrued to the applicant against the action of the
opponent firstly on __/__/2021 when the opponent refused to receive the
rent of the rented premises for the month of ______, 2021 and when the
opponent refused same through Money Order and thereafter continued till
today.
9. That this Honorable court has ample jurisdiction as the rented premises
situated in the Police Station Federal-B area Karachi.

10. That the proper court fee has been affixed on the memo of this
application.

PRAYER

Under the circumstance this Hon’ble court may be pleased to allow the
Applicant to deposit the rent of the rented premises in this Hon’ble court in
the above said matter at the rate of Rs______per month and the future rent at
the same rate.

Karachi
Dated: __/__/2021 APPLICANT
ADVOCATE FOR THE
APPLICANT