IN THE COURT OF _____
IN THE MATTER OF:
Respectfully Showeth:
1- That the present execution petition of the decree holder is not maintainable in the present form because the objector/Judgement have never dealt with the decree Holder ____ hence the amount as involved in the present execution cannot be recovered from the judgement debtor.
2- That the impugned amount of ____ have never become due and payable by the judgement debtor to the decree holder.
3- That ____ had never been ___ of the ____ i.e. _____. Hence the present execution petition is liable to be dismissed.
4- That the present execution petition has been filed by the decree holder against unknown person rather he should have filed the present execution against the actual ____ of the Judgement debtor ____.
Prayer:
It is therefore prayed that execution petition of the Decree Holder may kindly be dismissed issuing directions to the ___ to implead the ____ of the ____ holder may not be read/taken into consideration. It is prayed accordingly.
Dated ____________ Plaintiff.
Through counsel:
____, Advocate, ____