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VERSUS
MR. P … RESPONDENT
RESPECTFULLY SHOWETH:
5. That the Appellant/ Applicant came to know about the passing of the Decree
against him only after passing of 25 days from the date of Decree because of the
lax attitude of the Counsel. In the meanwhile, the health of the parents of the
Appellant/ Applicant deteriorated further and both the parents were required to
be admitted in hospital. It was impossible for the Appellant/ Applicant to find a
new counsel to handle the matter or to go to the Court himself and file the appeal
within time.
6. That the Appellant/ Applicant was able to file an Appeal only on 16-07-2019,
i.e. 14 days after the expiration of the period of Limitation. The parents of the
Appellant/ Applicant were discharged on 12-07-2019 and he appointed a new
Advocate on 13-07-2019. The next two days were a weekend and the next day
when the Court opened was 16-07-2019 [Monday].
7. That the delay in filing the accompanying Appeal was neither
intentional nor deliberate but the same was only due to the aforesaid
facts and circumstances and bonafide reasons.
PRAYER
1. Condone the delay, if any, in filing the accompanying Appeal and the
same may kindly be heard and decided on merits, in the interest of
Justice.
2. Pass such or further Orders as this Hon’ble Court may deem fit and
proper in the facts and circumstances of the case be also passed in
favour of the Appellant/ Applicant and against the Respondent to meet the ends
of Justice.
It is prayed accordingly!
Dated: through:
(Signatures)
Advocates