An Ejectment Petition Draft is a legal document prepared by a landlord to seek the removal of a tenant from rented premises through a court of law. This process is governed by the Punjab Rented Premises Act, 2009, which provides a clear legal framework for tenancy relationships, including the rights and duties of both landlords and tenants. Understanding how to draft and file an ejectment petition correctly is crucial for a landlord seeking lawful possession of property in Punjab, Pakistan.
The Punjab Rented Premises Act, 2009 (PRPA) was enacted to regulate the relationship between landlords and tenants in Punjab and to provide an efficient mechanism for resolving disputes related to rent and possession.
According to the Act:
“Ejectment” means the legal process by which a landlord seeks to recover possession of a rented property from a tenant under the provisions of this Act.
The Act allows the landlord to file an ejectment petition before the Rent Tribunal established under Section 24 of the PRPA. The landlord must prove one or more of the statutory grounds mentioned in the Act to obtain an ejectment order.
Under Section 15 of the Punjab Rented Premises Act, 2009, a landlord may seek ejectment of a tenant on the following grounds:
Default in Payment of Rent – If the tenant fails to pay rent within the time specified in the tenancy agreement or as directed by the Rent Tribunal.
Violation of Tenancy Terms – If the tenant uses the property for a purpose other than that agreed upon or sublets it without the landlord’s written permission.
Personal Need of the Landlord – When the landlord genuinely requires the premises for personal use, occupation, or for a family member.
Expiry or Termination of Tenancy – When the tenancy period has expired and the tenant refuses to vacate.
Nuisance or Damage to Property – If the tenant causes substantial damage to the premises or creates nuisance for neighbors.
Reconstruction or Demolition – When the premises are required to be demolished or reconstructed by the landlord.
Each of these grounds must be supported by proper documentary and oral evidence before the Rent Tribunal.
The procedure of filing an Ejectment Petition under the Punjab Rented Premises Act 2009 is relatively straightforward but must be followed carefully to ensure a successful outcome.
The Ejectment Petition Draft must include:
Name and address of the landlord (petitioner)
Name and address of the tenant (respondent)
Description and address of the rented premises
Grounds for ejectment under Section 15 of PRPA
Details of the tenancy agreement and rent amount
Relief sought (possession of premises, arrears of rent, costs, etc.)
The petition should be signed and verified by the landlord or an authorized representative.
After preparing the draft, the landlord must file the petition in the Rent Tribunal having jurisdiction over the location of the rented premises. The Rent Tribunal is a specialized forum established under Section 24 of the Act to handle tenancy disputes expeditiously.
Upon filing, the Tribunal issues notices to the tenant for appearance and submission of a written reply.
The tenant is required to file a written statement (reply) within ten days of receiving notice. The tenant may contest the petition by denying the landlord’s allegations or presenting evidence of compliance with tenancy obligations.
After receiving the tenant’s reply, the Rent Tribunal records evidence from both sides. This includes:
Documentary evidence (tenancy agreement, rent receipts, notices)
Oral testimony of witnesses
Cross-examination of parties
The Tribunal then hears arguments from both parties.
After evaluating all evidence, the Rent Tribunal passes a reasoned judgment. If the landlord successfully proves the grounds for ejectment, the Tribunal issues an Ejectment Order directing the tenant to vacate the premises within a specified period (usually thirty days).
If the tenant fails to vacate within that time, the landlord can apply for execution of the ejectment order through the Tribunal, which may direct the bailiff to take possession.
An aggrieved party may file an appeal before the District Judge within thirty days of the Rent Tribunal’s order under Section 26 of the Act.
Petition No.__________________/20__
__________________ S/O __________________ R/O House No.__, _____________________________________, Lahore.
__________________ S/O __________________ R/O House No.__, _____________________________________, Lahore.
Respectfully Sheweth: –
That the brief facts giving rise to file instant petition are that the petitioner is the landlord of a house measuring 5 Marlas vide Khasra No.___, Khewat No.___, Khatooni No.___, situated at ____________, Tehsil ____, District _____, vide mortgage deed with possession dated 1-1-20__ Copy of mortgage deed is Annexure-A.
That the above-mentioned house was rented out to the respondent through a written rent agreement dated 01-01-20__, in the presence of witnesses, namely Mr. _______ son of _______ and Mr. _______ son of _______. After execution of the tenancy agreement, the respondent took possession and started residing in the said rented premises.
That at the time of the tenancy agreement, it was amicably agreed between the parties that the respondent would pay 20,000/- per month as rent for the above-mentioned premises. The rent was to be paid on or before the fifth day of each calendar month.
That the respondent has failed to pay the monthly rent to the petitioner since May 20__ and has not paid a single penny towards rent to date. Hence, the respondent has willfully defaulted in the payment of rent for the demised premises. A copy of the rent agreement dated 01-01-20__ is annexed herewith as Annexure-B.
That the petitioner repeatedly approached the respondent and requested payment of the outstanding rent arrears and also asked the respondent to vacate the rented premises, as the petitioner requires the same for personal use. However, the respondent flatly refused to comply with these genuine requests. Furthermore, the respondent, along with certain unknown individuals, threatened the petitioner with dire consequences and stated that she would neither pay the rent nor vacate the petitioner’s house.
That the respondent has violated the terms and conditions of the tenancy agreement. Therefore, the petitioner has no adequate or efficacious remedy other than to approach this Honorable Court through the instant petition.
That the cause of action first arose when the respondent took possession of the premises on rent; secondly, in May 20__, when the respondent stopped paying the monthly rent; and thirdly, when the respondent threatened the petitioner instead of complying with her lawful requests. The cause of action is continuous and still subsisting.
That the parties are residing at Lahore and the demised premises is situated at Lahore and the cause of action also accrued at Lahore, hence this honorable court is fully competent to adjudicate upon the matter.
That the requisite court fee has been affixed on the petition.
P R A Y E R: –
In view of the foregoing facts and circumstances, it is most respectfully prayed that this Honorable Court may graciously be pleased to accept the instant petition and pass an order in favour of the petitioner and against the respondent, directing the respondent to vacate the rented premises.
It is further prayed that the respondent may kindly be directed to pay the outstanding arrears of rent to the petitioner, w.e.f. May 20__ till the vacation of the premises.
Any other relief deemed just and proper in the circumstances of the case may also kindly be granted.
……. Petitioner
Through
________________
Dated: 1-1-20__ Advocate High Court
Verification: –
Verified on oath at Lahore this __th day of October 20__ that the contents of the petition are true to the best of my knowledge, belief and information
……. Petitioner
________ ……………… …. Petitioner.
V E R S U S
________ …………… …. Respondent.
(EJECTMENT PETITION)
PETITION UNDER ORDER 39, RULE 1 & 2 READ WITH SECTION 151 C.P.C. FOR GRANT OF INTERIM INJUNTION
Respectfully sheweth:-
That the petitioner has filed the titled suit in this Honourable Court in which no date of hearing is fixed so far.
That the contents of the accompanying suit may very kindly be read as integral part of this petition.
That the petitioner has a prima-facie and arguable case in his favour and there is every likelihood of its success.
That balance of convenience also lies in favour of the petitioner.
That unless the Defendant is restrained by an order of injunction, the Plaintiff shall suffer grave and irreparable loss.
P R A Y E R: –
It is therefore, most respectfully prayed that the respondent or any other person acting on his behalf may kindly be restrained permanently to from alienating, transferring, parting with possession, making any structural changes, mortgage, alienate, transfer the rented premises and also restrained permanently to hand over the possession of rented premises to anyone else except the petitioner till the final disposal of the instant application.
……. Petitioner
__________ V / S ________
(EJECTMENT PETITION)
AFFIDAVIT OF (Name of Petitioner as Witness) s/o __________ r/o _______, ________, Lahore.
I, the above-named deponent do hereby solemnly affirm and declare as under: –
That the brief facts giving rise to file instant petition are that the deponent is the landlord of a house measuring 5 Marlas vide Khasra No.___, Khewat No.___, Khatooni No.___, situated at ____________, Tehsil ____, District _____, vide mortgage deed with possession dated 1-1-20__ Copy of mortgage deed is Annexure-A.
That the above-mentioned house was rented out to the respondent through a written rent agreement dated 01-01-20__, in the presence of witnesses, namely Mr. _______ son of _______ and Mr. _______ son of _______. After execution of the tenancy agreement, the respondent took possession and started residing in the said rented premises.
That at the time of the tenancy agreement, it was amicably agreed between the parties that the respondent would pay 20,000/- per month as rent for the above-mentioned premises. The rent was to be paid on or before the fifth day of each calendar month.
That the respondent has failed to pay the monthly rent to the petitioner since May 20__ and has not paid a single penny towards rent to date. Hence, the respondent has willfully defaulted in the payment of rent for the demised premises. A copy of the rent agreement dated 01-01-20__ is annexed herewith as Annexure-B.
That the deponent repeatedly approached the respondent and requested payment of the outstanding rent arrears and also asked the respondent to vacate the rented premises, as the deponent requires the same for personal use. However, the respondent flatly refused to comply with these genuine requests. Furthermore, the respondent, along with certain unknown individuals, threatened the deponent with dire consequences and stated that he would neither pay the rent nor vacate the petitioner’s house.
That the respondent has violated the terms and conditions of the tenancy agreement. Therefore, the deponent has no adequate or efficacious remedy other than to approach this Honorable Court through the instant petition.
Deponent
Verification:
Verified on oath at Lahore this 1th day of _____ 20__
that the contents of my above affidavit are correct and true to the best of my knowledge and belief and nothing has been concealed therein.
Deponent
__________ V / S ________
(EJECTMENT PETITION)
AFFIDAVIT OF (Name of Witness) s/o __________ r/o _______, ________, Lahore.
I, the above-named deponent do hereby solemnly affirm and declare as under: –
That the brief facts giving rise to file instant petition are that the petitioner is the landlord of a house measuring 5 Marlas vide Khasra No.___, Khewat No.___, Khatooni No.___, situated at ____________, Tehsil ____, District _____, vide mortgage deed with possession dated 1-1-20__ Copy of mortgage deed is Annexure-A.
That the above-mentioned house was rented out to the respondent through a written rent agreement dated 01-01-20__, in the presence of witnesses, namely Mr. _______ son of _______ and Mr. _______ son of _______. After execution of the tenancy agreement, the respondent took possession and started residing in the said rented premises.
That at the time of the tenancy agreement, it was amicably agreed between the parties that the respondent would pay 20,000/- per month as rent for the above-mentioned premises. The rent was to be paid on or before the fifth day of each calendar month.
That the respondent has failed to pay the monthly rent to the petitioner since May 20__ and has not paid a single penny towards rent to date. Hence, the respondent has willfully defaulted in the payment of rent for the demised premises. A copy of the rent agreement dated 01-01-20__ is annexed herewith as Annexure-B.
That the petitioner repeatedly approached the respondent and requested payment of the outstanding rent arrears and also asked the respondent to vacate the rented premises, as the petitioner requires the same for personal use. However, the respondent flatly refused to comply with these genuine requests. Furthermore, the respondent, along with certain unknown individuals, threatened the petitioner with dire consequences and stated that she would neither pay the rent nor vacate the petitioner’s house.
That the respondent has violated the terms and conditions of the tenancy agreement. Therefore, the petitioner has no adequate or efficacious remedy other than to approach this Honorable Court through the instant petition.
Deponent
Verification:
Verified on oath at Lahore this 1th day of _______20__
that the contents of my above affidavit are correct and true to the best of my knowledge and belief and nothing has been concealed therein.
Deponent
Read THE PUNJAB RENTED PREMISES ACT 2009
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