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The tenant approaches the court to request permission and move an application for deposit rent in court when the landlord refuses to accept it. In such a situation, the tenant seeks to avoid being held in default due to the landlord’s refusal. To resolve this, the tenant files an application in the court of Civil Judge having jurisdiction over rental matters, or in the rent court, to ensure that the unpaid rent, which the landlord has declined to accept, does not result in a default on the tenant’s part.
____________ son of Muhammad _______, resident of _________, Lahore.
…..Applicant
____________ wife of _______ resident of _________, Defence Housing Authority, Lahore.
……Respondent
The applicant is a tenant under the landlordship of the respondent in respect of a shop and a flat situated in defence housing authority Lahore, pursuant to an agreement in the year 20__, the original agreement of the tenancy is in the possession of the respondent.
That the applicant/tenant has been regularly paying the monthly rent, without any delay and default, the respondent duly executed a receipt in favour of the applicant/tenant for the same as evident from the record maintained by the appellant, the respondent personally received all the rent until March 20__.
That the applicant/tenant approached the respondent for the payment of the monthly rent i.e. Rs. 50,000/- on 1-01-20__, which was straight-forwardly refused by the respondent. which constrained the applicant/tenant to send the same through money order but the respondent refused to receive the monthly rent through postal measure.
The applicant/tenant made every reasonable effort to pay the rent, both through direct cash payments and via money order. The respondent willfully refused to accept these payments, likely in furtherance of his ulterior motive to unlawfully evict the tenant.
That the applicant/tenant is willing and ready to pay the monthly rent to the respondent but upon the refusal of the respondent constrained to deposit the same in the court in favour of the respondent as the applicant/tenant left no other alternate but to invoke the jurisdiction of this Honourable Court.
That it would be in the interest of justice that the applicant/tenant may kindly be allowed to deposit the monthly rent in the court in favour of the respondent.
That the cause of action accrued in favour of the applicant/tenant when the respondent refused to receive the monthly rent through money order, and thereafter continue till today.
That the parties reside and property in dispute situated within the territorial jurisdiction of this Honourable Court, therefore, this Honourable Court has ample jurisdiction to adjudicate upon the matter.
That the prescribed court fee has been affixed on the petition.
In light of the above submissions, it is respectfully requested that the applicant/tenant be permitted to deposit the monthly rent at the rate of Rs. 50,000/- per month, starting from 1 January 20__ onwards, in the interest of justice and fairness.
Through
______________
Advocate High Court
Verified on oath at Lahore on this 1 day of Jan, 20__ that the contents of the above paras are correct to the best of my knowledge, information and belief.
