IN THE COURT OF………………..
Suit No………………… of 19………………………………….
C. D…………………………………………………………. Plaintiff
versus
C. F………………………………………………………. Defendant
The applicant most respectfully submits as under: —
1. That a preliminary decree for redemption of the mortgaged property was passed by the Court on……………….. (date) in favour of the plaintiff.
2. That under the said decree the plaintiff was liable to pay Rs………………… to the defendant by……………….. (date).
3. That the plaintiff has not made the payment to the defendant (applicant) by……………….. (date).
PRAYER
It is therefore most respectfully prayed that a final decree be passed declaring that the plaintiff and all persons claiming under him be debarred from all right to redeem the mortgaged property as also the plaintiff be ordered to put the defendant in possession of the mortgaged property.
It is accordingly prayed.
Plaintiff
Through Advocate
Place:………………..
Dated:………………..