In the court of Hon’ble ____
Application Under Order _____ Rule _____Read with Section _____ of CPC.
The applicants/plaintiffs submit as under:
1- That the appellants/plaintiffs have filed the above noted appeal _____ before Hon’ble court the contents of which be read as part and parcel of this application for the sake of brevity and avoidance repetition.
2- That the defendants /respondent by taking the benefit of dismissal order of the Learned lower court are bent upon to take the _____ from the _____ for which the respondent/defendant _____, title and interest. In case the defendant/respondents will succeed in their illegal designs then the appellant/plaintiffs will suffer an irreparable loss and injuries, which cannot be compensated in any manner whatsoever.
3- That there is a very good prima-facie case in favour of the appellants/plaintiffs and the balance of convenience also lies in their favour.
4- That the purpose for filing the present appeal will be defeated if the relief sought for is not granted to the appellants.
It is, therefore, prayed that during the pendency of the present appeal the operation of the Judgement and dismissal Order of the suit of dated _____ passed by the Learned Lower court may kindly be stayed in the interest of justice.
_____, Advocate, _____