A broad approach to drafting of any Application / Petition / Complaint may be undertaken in three chronological “Heads” – 1. Reliefs prayed for / claimed; 2. Grounds for Reliefs prayed for / claimed; (both factual and legal); 3. Narration of facts substantiating the said grounds. Further, there may be narration of such facts in the beginning of the draft, which would lay foundation for “material facts of the case”. Materiality of facts would always mean those “facts which are very material to the relief claimed”. Grounds for Reliefs prayed for / claimed implies (a) the essence / conclusion of material facts or proposition of facts; and (b) other legal provisions which supports the reliefs prayed for / claimed. 1. AND, in every case before the Court, it is of utmost importance to “fence the case” in four cor...