A Great Know How to write a Restoration Of a Writ Petition?

How to write a Restoration Of a Writ Petition?

Restoration Petition

Every Law Student/ Advocate / Barristers Willing To Practice In High Court Should Go Through Some Sort of Practice of  Writing Skills Relating To Different Types Of Petition Both For Drafting And Conveyancing. Here I am To Serve You With Such Thing as you needed. Well Come!! Try To Write This Way...

In the Supreme Court of Bangladesh

High Court Division

(Special Original Jurisdiction)

Writ petition No. 2061 of 2001.

                                                                  An application for restoration of Writ petition No. 2061 of 2001

                                                                                                                   AND

                                                                                                        In The Matter Of

            Md. Shah Khan Miah, Son of

            of Village A      P.S ..................
            District ....................

                                    ....... Petitioner.

                         -:Versus:-

                                                                        People's Jute Mills Ltd, being represented by

                                                                        The General Manager, Town Khalishpur, Khulna and others.

                                            ….....Respondents.

To       

Mr. Justice Syed J.R. Mudassir Husain, the Chief Justice of Bangladesh and his companion Justices of the said Hon'ble Court.

                                                                                                The humble petition on behalf of the petitioner                                                                                                   named above most respectfully.

SHEWETH:    

1. That the above writ petition was filed challenging the retirement letters dated 10.5.2001 under reference PJM/Adm'/3/25/2750 marked as Annexure-"C". to the writ petition.

2. That it is submitted that the instant writ petition No. 2061 of 2001 came/up in the daily cause list for hearing on 19th February, 2005 in Division Bench comprising with Hon'ble Mr. Justice Tafiq-ul Hakim and Mr. Justice Afzal Hossain Ahmed in Court No. 32 (Annexed Bhaban], as item No. I0 but unfortunately Clerk of the learned Advocate has missed the list on that very day and hence their Lordships were pleased to discharge .the Rule for default,

3. That it is humbly submitted that the learned Advocate as well as the petitioner were ail along vigilant to hear and dispose of the instant writ petition and that there is' no laches or negligence on the part of the petitioner or his learned Advocate and even the learned Advocate on behalf of the petitioner was ail along vigilant to hear and dispose of the instant writ petition.

4. That it is humbly submitted that there is a good chance of success in this writ petition as the concerned authority without applying their judicial mind passed the impugned order and il' this writ petition is hot restored, the petitioner shall have to suffer immense loss and injury and the purpose of filing writ petition will be frustrated and as such the instant writ may kindly be restored to it's original file and number after setting aside the order dated 19th February, 2005 passed by this Hon'ble Court, for the ends of justice.

                                                                               Wherefore, it is most humble prayed that your Lordships                                                                                               may graciously be pleased to restore the writ petition No.                                                                                              2061 of 2001 to it's original file and number after setting                                                                                                aside the order of discharge dated 19th February, 2005                                                                                                passed by this Hon'ble Court and/or pass such other or                                                                                                 further order or orders as to this Hon'ble Court may deem                                                                                             fit and proper.. And for this act of kindness, petitioner as in                                                                                            duly bound shall ever pray.

                   AFFIDAVIT

I, Md. Atiar Rahman, son of late Md. Noor Ail, Room No. 104, Supreme Court Bar Association Bhaban, Dhaka aged about 40 years, by faith- a Muslim, by occupation-business, nationality-Bangladeshi by birth, do hereby solemnly affirm and say as follows:-

1. That I am the Tadbirkar of this case and am acquainted with the facts and circumstances of the case and competent therefore to depose to the' same~

2. That I do hereby declare that I did not tender any such petition for registration of file Hon'ble High Court Division of the Supreme Court of Bangladesh.

3. That the statements made above are true to my knowledge before this Hon'ble Court.

Prepared in my office.                                                                                               Deponent

Advocate                                                                                   The deponent is known to me and identified by me.

                                                                                                                                   Advocate