IN THE HONOURABLE LAHORE HIGH COURT
C.M. No. ____________ /2012.
IN
W.P. No. __________ / ________.
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VERSUS
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APPLICATION UNDER SECTION 151 OF THE CIVIL PROCEDURE CODE, 1908 FOR DECIDING
PRELIMINARY ISSUES
Respectfully Sheweth:-
1. That the captioned Writ Petition is pending adjudication before this Court and is now fixed for hearing for ________________
OR no date of hearing has yet been fixed in the matter.
2. (State very briefly the factual matrix of the matter depicting the legal issues which show that the jurisdiction of the Court is barred under law).
3. (State the details of the reasons, on the basis of which the jurisdiction of the Honourable Court is barred, which may be any of the following:-
The petition is barred under a specific law, the petition is barred under Article 184 of the Constitution of the Islamic Republic of Pakistan, 1973, being a dispute between a Provincial Government and the Federal Government etc., the petition is barred under Article 212 of the Constitution of the Islamic Republic of Pakistan, 1973).
4. The Petitioner has an alternative and efficacious remedy available to him which he has not availed nor are there any compelling reasons justifying circumvention of due process of law.
5. (That the question involved in the case at hand goes to the root of the matter, therefore, it is humbly submitted that it would be in the fitness of things if the same is adjudicated upon at the foremost, before the decision of the case on merits.)
In view of the above, it is very humbly prayed that the Preliminary Issue(s) may very graciously be decided before adjudicating the case on merits.
Any other relief which this Honourable Court deems fit and appropriate in the facts and circumstances of the case may also be passed in favour of the Applicant.
Applicant
through
Government Pleader Punjab
through
Government Pleader Punjab