District
: South 24 Parganas.
In
the 5th Court of the Learned Judicial Magistrate, at Alipore, South
24 Parganas.
ACM
Case no. 517 of 2021
In
the matter of :
Mumtaj Begam,
_________Petitioner.
-
Versus
–
Md. Fakruddin,
___________Opposite
Party.
Show
Cause Petition
The humble petition
on behalf of the Opposite Party most respectfully;
Sheweth
as under :
1.
That today
(i.e. 14/12/2022), is fixed for the Show Cause by the Opposite Party, in the
above referred proceeding, before the Learned Court, as the Learned Court did
not find any steps for the opposite party on last occasion.
2.
That on
28/09/2022, due to illness of the Learned Advocate of the Opposite Party, no
steps has been assailed in the case record. The Opposite Party was not in
Kolkata on such occasion, as no leave has been given by the Central Railways
Authority. Thus while the Learned Court did not find any steps and appearance
of the Opposite Party, the Learned Court was pleased to direct the Show Cause
on the Opposite Party.
3.
That the
Opposite Party is much due diligent in conducting the proceeding before the
Learned Court though the illness of the Learned Advocate and non-consideration
of leave by the employer of the Opposite party prevent the opposite party to
appear before the Learned Court on the given occasion in the proceeding.
4.
That the
Opposite Party undertake to take all necessary steps and be present in the
proceeding on each and every occasion fixed up by the Learned Court.
5.
That the Opposite Party is ready with
his Written Objection and Annexure – A – being affidavit of assets and
liabilities, to place in the present proceeding.
6.
That in the
given facts and circumstances, the opposite party seeks the acceptance of cause
shown by him before the Learned Court, in the interest of administration of
Justice.
7.
That unless the Learned Court accept
the cause shown by the opposite party, the opposite party will highly prejudice
and suffer with irreparable loss and injury thereof.
8.
That the balance of convenience and
inconveniences are in favour of the Opposite Party, and the Petitioner will not
prejudice.
9.
That this application is made bonafide
and in the interest of administration of Justice.
It is therefore
prayed that your Honour would graciously be pleased to allow this written
objection of the Opposite Party and to accept the cause shown by the opposite
party, in the interest of administration of justice, and or to pass such other
order or orders as your Honour may, deem, fit, and proper for the end of justice.
And
for this act of kindness, the Petitioner, as in duty bound shall ever pray.
VERIFICATION
I,
being the Opposite Party herein, do hereby solemnly state and declare that the
statements made in the foregoing paragraphs are true to the best of my
knowledge and belief and I sign this verification on this the ______day of
____________’ 2022, at Alipore Criminal Court premises.
Affidavit
I,
Md. Fakruddin, Son of Late Md. Moin, aged about _______years, by faith Muslim,
by Occupation Service, residing at Village – Payalpur, English Pirpaintee,
Bhagalpur, Post Office – Rifayatpur, Police Station – Barahat, District – Ishi,
State – Bihar, India, Works for gain at : Murahara Railway Station, Eastern
Railway, District – Banka, State Bihar, India, works as Gate Keeper, do hereby
solemnly declare and affirm as follows :
- That
I am competent to swear this affidavit, and I am Opposite Party in the
present proceeding, before the Learned Court.
- That
I am conversant and acquainted with the material facts as stated in the
foregoing paragraphs of my Show Cause Petition.
- That
the statements as made by me in the foregoing paragraphs in the Show Cause
Petition, are true to the best of my knowledge and belief.
That
the above statements are true to the best of my knowledge and belief.
DEPONENT
Identified by me,
Advocate.
Prepared
in my Chamber,
Advocate
Date
: __________________2022.
Place
: Alipore Criminal Court
NOTARY
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