IN THE COURT OF THE………………..
Suit No………………… of 19………………………………….
C. D…………………………………………………………. Plaintiff
versus
C. F………………………………………………………. Defendant
The applicant most respectfully submits as under: —
1. That the suit has been instituted by applicant on the basis of simple mortgage deed dated……………….. relating to the suit property.
2. That the final decree for the sale of the mortgaged property was passed on……………….. (date) for Rs………………… including costs.
3. That the mortgaged property was sold in execution of decree on ……………….. (date) and an amount of Rs………………… was realised by the sale-of the property under the decree.
4. That the sale proceeds amounting to Rs………………… are insufficient to pay the amount of Rs………………… due to the plaintiff-decree holder and a sum of Rs………………… still remains recoverable from the defendant.
5. That the property specified in Annexure ‘A’ to this application is in defendant’s possession.
PRAYER
It is therefore most respectfully prayed that decree for Rs………………… be passed in favour of the applicant.
It is accordingly prayed.
Applicant
Through Advocate
Place:………………..
Dated:………………..