IN THE COURT OF SENIOR CIVIL JUDGE WITH THE POWERS OF RENT CONTROLLER, LAHORE

Ejectment Petition No. ______/24

[Petitioner Name Hidden],
Residing at [Address Hidden], Lahore
…Petitioner

Versus

[Respondent Entity Hidden], through its Chief Manager,
Branch Office at [Address Hidden], Lahore
…Respondent

EJECTMENT PETITION

Under Section 13 read with other enabling provisions of the Punjab Urban Rent Restriction Ordinance, 1959

Respectfully Sheweth:

1. That the petitioner is the lawful and sole owner of a property located at [Property Address Hidden], Lahore (“the premises”), which is the only property available to her.

2. That the petitioner rented out a portion of the said premises, measuring approximately [Area Hidden] sq. ft. (“the demised premises”), to the respondent on a monthly rent of Rs. [Amount Hidden] under a written lease agreement.

3. That the lease was initially for a limited period and included a clause allowing termination by either party upon prior notice. It also provided for a fixed percentage increase in rent upon renewal.

4. That the petitioner did not wish to renew the lease and accordingly served eviction notices to the respondent. Copies of these notices are attached.

5. That the respondent confirmed termination of the lease multiple times, including through a letter assuring vacation of the premises by a specific date. However, the respondent failed to vacate as promised.

6. That the respondent has frequently delayed rental payments, prompting the petitioner to serve a notice. The respondent replied with an apology, acknowledging a delay in payment.

7. That the respondent has violated the terms of the lease, including unauthorized extensions and modifications to the structure, and has been using portions of the premises not covered under the original lease.

8. That the lease has expired, and the petitioner is legally entitled to reclaim possession on the following grounds:

   • I. Breach of lease agreement and legal obligations by the respondent.

   • II. Respondent's failure to vacate despite confirmed termination.

   • III. Unauthorized structural changes made without consent.

   • IV. Encroachment upon areas beyond the demised premises.

   • V. Estoppel due to written commitment by the respondent to vacate.

   • VI. Occupation without consent after lease expiry.

   • VII. Petitioner stands to suffer irreparable harm if relief is denied.

9. That the cause of action arose upon the expiry of the lease and continues as the respondent remains in unlawful possession.

10. That this Honourable Court has jurisdiction as the property is situated within its territorial limits.

11. That the requisite court fee has been duly affixed.

PRAYER

It is therefore respectfully prayed that this Honourable Court may kindly be pleased to:

i. Pass a decree of eviction against the respondent;
ii. Direct the respondent to vacate and deliver vacant possession of the premises forthwith;
iii. Direct the respondent to pay arrears of rent with applicable increase for continued possession after lease expiry;
iv. Grant costs of these proceedings;
v. Award any other relief deemed just and proper.

Petitioner
Through Counsel
[Counsel Names & Firm Info Hidden]

VERIFICATION

Verified on oath at Lahore this ___ day of ______ 20__ that the contents of paragraphs 1 to 8 (including the grounds) are true and correct to the best of my knowledge and those of paragraphs 9 to 11 are true and correct to the best of my knowledge and belief.

Petitioner