In the Court of Hon’ble ___________________, Judicial Magistrate, 1st Class,

________________
______________________________
Versus
______________________________

Application on behalf of the respondent

_______________ and _________________ for taking up
file today and request for vacating the order of attachment
of the property which was passed on
_________________.
Sir,
It is submitted as under:-
1. That the above noted case is pending in the Hon’ble court and the same is
fixed for ____________ for arguments on the application for attachment of
the property of the respondent _____________ situated on
___________________________________. The Hon’ble court earlier passed
order dated ___________ and ordered for the attachment of the aforesaid
property till the final decision of the final application.
2. That the applicant _____________ filed the aforesaid application for
attachment of the property of the Respondent only in order to harass the
Respondent and his family members by concealment of material facts from
the Hon’ble court.
3. That the property in question is jointly owned by the respondent alongwith his
brother _____________ and sister ___________.
4. That due to the order of attachment of the property in question the respondent
alongwith his brother and sister are now unable to execute the sale deed/
conveyance deed in favour of the prospective buyer and the date for the
execution of the sale deed which was fixed as __________ has already passed.
5. That due to the passing of the order dated ________ the respondent his brother
and sister are suffering from grave mention tension, agony, botheration,
harassment, humiliation and also suffering from huge financial loss and as
such the aforesaid order dated _______ is liable to be vacated immediately.
6. That in case the aforesaid order dated _______ is not vacated the respondent
his brother and sister shall suffer irreparable loss which cannot be
compensated later on. An affidavit is attached.
It is, therefore, prayed that the application may kindly be accepted;
file may kindly be taken up today and the aforesaid order dated ______ may kindly
be vacated with immediate effect in the interest of justice.

Dated : _____________ Submitted by :-

___________________
Respondents
Through Counsel :-