Sample Affidavit of Evidence Rent Eviction Petition in Islamabad

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IN THE COURT OF MR. [RENT CONTROLLER NAME]
LEARNED RENT CONTROLLER, ISLAMABAD (WEST)

[Landlord Name]
Versus
[Tenant Name]

EVICTION PETITION U/S 17 OF ISLAMABAD RENT RESTRICTION ORDINANCE 2001 (IRRO 2001)
FOR EVICTION FROM SHOP NO. [NUMBER] ALONG WITH BASEMENT, FRUIT AND VEGETABLE MARKET, SECTOR I-11/4, ISLAMABAD

AFFIDAVIT FOR EVIDENCE ON BEHALF OF PETITIONER

I, [Deponent Name] (Attorney Holder) son of [Father’s Name], resident of [Complete Address – Hidden], do hereby solemnly affirm and declare on oath as under:

  1. That the petitioner is the lawful owner/landlord of Shop No. [Shop Number] along with the basement in the Fruit and Vegetable Market, Sector I-11/4, Islamabad, which was rented out to the respondent for a period of three (03) years from [Start Date] to [End Date] at a monthly rent of Rs. 47,000/-. A lease agreement was duly executed between the parties on [Agreement Date] (hereinafter referred to as the “Rented Premises”).
  2. That under the lease agreement, it was mutually agreed that the respondent would pay rent quarterly in advance before the 5th of the running month.
  3. That an amount of Rs. 141,000/- was received by the petitioner as three months’ advance rent, and Rs. 100,000/- as refundable security deposit, subject to deduction for any necessary minor or major repairs at the time of vacating the premises.
  4. That it was also agreed the respondent shall not cause damage to the rented premises; however, the respondent has violated this term of the agreement.
  5. That from the start of the tenancy, the respondent was irregular in rent payments and continuously breached the agreement. The last rent payment was made for November 2014. Since then, the respondent has committed default.
  6. That despite several verbal requests made by the petitioner to comply with the terms of the lease and pay due rent, the respondent failed to comply. Furthermore, the petitioner learned that the respondent intended to sublet the premises without consent.
  7. That several requests were made to the respondent to vacate the premises due to default, violation of lease terms, and the petitioner’s bonafide personal requirement, but the respondent refused.
  8. That the respondent remains in possession of the rented premises and continues its use despite the expiration of the lease and repeated requests to vacate.
  9. That the grounds for eviction include but are not limited to:
  • Default: Non-payment of rent since December 2014. Total outstanding dues amount to Rs. 1,551,000/-.
  • Personal Need: The petitioner requires the premises for personal bonafide use.
  • Expiry of Lease: The lease has already expired.
  • Violation: Breach of multiple terms of the lease.
  • Damage: The respondent has caused damage to the property.
  1. That due to the respondent’s refusal to vacate or settle dues, the petitioner has no other remedy except to seek legal relief from this Hon’ble Court.
  2. That the petitioner prays for the acceptance of this eviction petition and decree in favour of the petitioner.

Deponent
The contents of this affidavit are true and correct to the best of my knowledge and belief, and nothing has been concealed.

Dated: [Date]

Deponent: __________________
Name: [Deponent Name]
CNIC: [Redacted]