IN THE COURT OF THE………………..
Civil Misc. Application No………………… of 19………………..
Under S. 22, C. P. C.
A. B…………………………………….. Applicant (Defendant)
versus
C. D…………………………………….. Respondent (Plaintiff)
Sir,
The applicant abovenamed most respectfully submits as under: 1. 1. That the Respondent has filed suit No………………… of 19…. in the court of……………….. at……………….. claiming therein a mandatory injunction against the applicant restraining him from running his business of……………….. in the town of……………….. on the basis of a dissolved partnership under the name of ……………….. (Firm now extinct).
2. That the Firm carried on business in the whole of the……………….. its registered office was at……………….. and other offices were at……………….. and ……………….. and as such the courts at……………….. and……………….. have concurrent jurisdiction to entertain a suit in the matter, as the properties in disputes also are situate in both the districts.
3. That the respondent has filed the suit at……………….. simply to harass the applicant who has to incur great expenses to attend the court at……………….. and for the attendance of his witnesses in the matter.
4. That the respondent has his office at……………….. as well and it would be convenient for him as well to prosecute the suit at that place.
5. That in the interests of justice it is expedient that the suit aforementioned may be transferred to the Court of……………….. at………………..
6. That notice of this application has been given to the defendant on ……………….. 19 through registered post, which has been duly served on him.
PRAYER
It is, therefore, most respectfully prayed that your Honour may be pleased to transfer the suit No………………… of 19……………….. pending in the Court of ……………….. at……………….. may be transferred to the court of……………….. at
Dated……………….. 19……………….. Applicant
Through Counsel