Recovery suit under the Financial Institutions (Recovery of Finances) Ordinance 2001 with the statutory statement of account and finance particulars.
When to use this draft
Use where a financial institution seeks recovery of a finance facility, or a customer sues under the same Ordinance.
Essential contents
- Statement of account certified under the Ordinance
- Finance agreement and security documents
- Default particulars with dates
- Statutory notice where required
- Prayer for decree and sale of mortgaged property
Drafting notes
- The statement of account must comply with the Ordinance or the suit is exposed at the leave-to-defend stage.
- Leave to defend applications are decided strictly - plead every fact needed at the outset.
Adapt before filing
This is a structural template, not advice on your matter. Facts, dates, valuation, jurisdiction and the prayer must be settled by a lawyer licensed to practise in Pakistan.