Presuming a hypothetical case now let us draft on petition for revision in Marathi

Presuming a hypothetical case now let us draft on petition for revision.  

In the High Court of judicature al Allahabad civil Revision No. …………..  

Name and particulars …………..………….. petition/plaintiff 

Vs 

Name and particulars …………..………….. Respondent/Defendant 

Civil Revision petition under sec.115 C.P.C. against the impugned order dt. …………….assed by shri  ……………. civil judge sr. Division …………….when by the application of dismissed, for setting aside the  impugned order and for allowing the aforesaid application of the petitioner and for acceptance of revision  petition.  

The grounds of revision petition are submitted as under: -  

1) That briefly stating the facts of the case are that present petitioner has filed a suit for  …………….against the respondent! defendant before the Hon'ble trial court on the basis of  

The defendant, on his appearance has filed written statement wherein he has denied the facts.  When the suit was fixed for framing of issues before the Id. Trial court the it revealed to plaintiff and plaintiff  wants to file an application the plaintiff applied but the Id. Trial court disallowed the application vide  impugned order dt- against the petition against which the present revision petition is being filed.  

2) That the impugned order is wholly wrong, unjust against law, against facts and the same  deserves to be set aside.  

3) On the perusal of the aforesaid facts, it is clear that the plaintiff did not act any malafide  manner.  

4) That the learned trial court has erred in not judiciously and properly appreciating the  controversy involved in the case and thereby it has caused grave miscarriage of justice with the  petitioner. 

5) That the Id. Trial court has erred on ignoring the settled principles of law with regard to and  which are enunciated repeatedly by this Hon'ble court as well as Hon'ble Apex court in various  judgments that the law is very liberal. It has been repeatedly held that pleadings in the trial  courts are to be liberally interpreted.  

6) The application was filed without any inordinate delay and the evidence of the parties was  not yet started. Thus the stage of the suit is not belated one.  

7) That in the wake of above narrated facts and circumstances, the impugned order passed by  Id. Trial court denseness to be set aside.  

8) That the present petition is being filed within limitation and is properly stamped.  

It is therefore most respectfully prayed that impugned order dt …………….passed by shri …………….Civil  Judge Sr. Division …………….may kindly be set aside and the application of the plaintiff may kindly be  allowed and the revision petition may kindly be accepted.  

Dated : ……………. Counsel for the petition  

Place ……………. _______ 

FORM OF APPEAL 

In the High Court …………….……………. 

Civil Appeal No. …………….……………. 

Particulars of party's ……………. Appellant/Defendant 

V 

Particulars of party's ……………. Respondent/plaintiff 

Appeal under sec. 96 C.P.C. against the impugned judgment and decree dt. …………. passed by ………….  civil judge vide which the suit of the plaintiff has been decreed with costs, for setting aside the impugned  judgment and decree and for dismissal of the suit of the plaintiff and for allowing the present appeal with  costs.  

The grounds of appeal are submitted as under:  

1) That the impugned judgment and decree dt. Passed by shri …………. civil judge is wrong, illegal,  against the law and thus, the same are liable to be set aside.  

Certified copies of judgment and decree are attached herewith.  

2) That the impugned judgment and decree are wholly arbitrary, unjust, lacking reasoning and are  based on surmises and conjectures.  

3) That the learned trial court has not properly appreciated the evidence and material available on  record. It has erred in passing the impugned judgment and decree against the appellant by wholly misreading the evidence of the plaintiff which is going to· a material prejudice to the appellant.  

4) that the learned trial court as erred in deciding issue No. 1 against the appellant That the learned  trial court did not consider the martial contradictions in the statement of the plaintiff and the  impugned document which makes their statements unreliable.