Sample Rent Constitution Petition

IN THE HIGH COURT OF SINDH AT KARACHI

Constitution Petition. No. Of 2024

[PETITIONER NAME]

S/o [FATHER NAME]

Muslim, Adult, R/o Flat No.C-13

Mohalla Ishaqabad Sir Shah

Suleiman Road [AREA REDACTED] Block-1

Karachi……………………………………….......... Petitioner

Vs

Learned IV Additional District Judge,

Karachi Central.

[INSTITUTION NAME]

[AREA REDACTED], [AREA REDACTED], Karachi.

Through its authorized person

[AUTHORIZED PERSON NAME] S/o [AUTHORIZED PERSON FATHER NAME],

Muslim, Adult R/o H. no 43/22 [AREA REDACTED],

Liaquatabad, Karachi…………………………… Respondent

CONSTITUTIONAL PETTITION UNDER

ARTICLE 199 OF THE CONSTITUTION, 1973.

Being partly aggrieved and dissatisfied with the judgment dated _____________ (Certified Copy received on dated: __________), passed by the learned IVth Additional District Judge, Karachi Central in FRA 118/2024, (Jama Masjid Qadria Trust Vs. [PETITIONER NAME]) the petitioner prefer this petition, before this Hon’ble Court on the following facts and grounds amongst others, viz: -

Certified true copy of the Judgment dated ___________ passed by IVth ADJ Central is filed and marked herewith as annexure P-1.

F A C T S

Facts leading to this petition are as follows: -

That the Respondent No.2 i.e. [INSTITUTION NAME] Trust is the owner of the Shop no.12 situated at [AREA REDACTED] [AREA REDACTED], Karachi. (Hereinafter referred to as rented premises). That the Respondent no.2 vide tenancy agreement dated: 04-02-1970, let out the subject premises on rent to [FATHER NAME], father of the petitioner, against the monthly rent of Rs. 40/-. Subsequent to the death of his father, the petitioner became the tenant of the Respondent no.2 in the subject premises. The shop was originally let out on a monthly rent of Rs.40/- per month under the tenancy agreement executed between the parties. Subsequently, rent was enhanced from time to time and at present the rate of rent is Rs.1800/- (Rupees One Thousand and Eight Hundred Only) exclusive of the utility charges which has been regularly paid by the petitioner.

(A copy of the Tenancy Agreement dated 04-02-1970 is filed as Annexure “P-2”.)

That the petitioner has paid rent for the