What is this notice and when should you use it?

When you rent a house, flat, shop, or office in Pakistan, the landlord almost always takes a security deposit (also called "advance" or "security") at the start of the tenancy — typically one or two months' rent, sometimes more. This money is not the landlord's income. It is held as security and must be refunded to the tenant when the tenancy ends and the tenant vacates the premises, after adjusting only genuine outstanding dues (unpaid rent, utility bills, or agreed repair costs).

In practice, many tenants discover that once they hand over the keys, the landlord delays, avoids, or outright refuses to return the deposit — offering no receipts, no itemized deductions, and no explanation. A legal notice is the first formal legal step in that situation: a written demand, sent through an advocate, that puts the landlord on record, gives them a final deadline (commonly 15 days) to pay, and warns them of court proceedings if they do not.

Use this notice when:

  • You have vacated the rented premises and handed over vacant possession and the keys to the landlord, but the security deposit has not been refunded.
  • The landlord is delaying, making excuses, refusing to meet, or claiming vague deductions without any written account.
  • You want a formal, documented demand on record before filing a case before the Rent Tribunal (Punjab) / Rent Controller (other provinces) or a civil court.

Do NOT use this notice when:

  • You are still occupying the premises or have not yet handed over the keys — the deposit only becomes refundable on vacation.
  • You still owe rent, utility bills, or maintenance charges that legitimately equal or exceed the deposit — settle the account first; the notice is for the net refundable amount.
  • The landlord has already refunded the deposit, or you have no evidence at all that you paid one (see the checklist below — proof of payment is essential).

A legal notice does not by itself recover your money — but it creates a dated, provable record of your demand, which strengthens any later case, and in many disputes the notice alone is enough to make the landlord settle.

Before you send: gather these documents

A notice is only as strong as the proof behind it. Collect the following before filling in the template:

  1. Proof of the security deposit — the written receipt from the landlord, a bank transfer slip or bank statement entry, or the tenancy agreement clause recording the amount. (This is the single most important item.)
  2. The tenancy agreement — especially any clause about the security deposit and its refund.
  3. Rent receipts or other proof of rent paid up to the date of vacation.
  4. Utility bills (electricity, gas, water) paid up to the date of vacation — to show nothing is outstanding.
  5. Proof of vacation and key handover — any written acknowledgement, text message, WhatsApp chat, or a witness who was present when the keys were handed over.
  6. Record of your refund requests — messages, emails, or call logs showing you asked for the deposit back, and when.
  7. Your CNIC copy, and the landlord's correct full name and address (an address where the notice will actually reach them).

If you do not have a written receipt for the deposit, do not panic — bank records, witnesses, and the agreement itself can still prove payment — but discuss this openly with your advocate, because proof of payment becomes the central issue of the case.

THE LEGAL NOTICE

(Copy the portion between the two divider lines below onto your advocate's letterhead. Fill in every [BRACKETED BLANK]. Delete the italic guidance notes before printing.)

[ADVOCATE'S LETTERHEAD: NAME, DESIGNATION, CHAMBER ADDRESS, PHONE]

Through: [ADVOCATE'S FULL NAME], Advocate [High Court / District Courts [CITY]]

Dated: [DATE OF NOTICE, e.g., 17-10-2026] Place: [CITY], Pakistan

BY REGISTERED POST A.D. / COURIER

From: [ADVOCATE'S FULL NAME], Advocate, for and on behalf of: [TENANT'S FULL NAME], son / daughter / wife of [FATHER'S / HUSBAND'S FULL NAME], CNIC No. [TENANT'S CNIC NUMBER], resident of [TENANT'S PRESENT ADDRESS]. (hereinafter referred to as "my client")

To: [LANDLORD'S FULL NAME], son / daughter / wife of [FATHER'S / HUSBAND'S FULL NAME], resident of [LANDLORD'S COMPLETE ADDRESS].

Subject: LEGAL NOTICE FOR REFUND OF SECURITY DEPOSIT OF RS. [AMOUNT IN FIGURES]/- (RUPEES [AMOUNT IN WORDS] ONLY) IN RESPECT OF [PROPERTY FULL ADDRESS]

Dear Sir / Madam,

Under instructions from and on behalf of my above-named client, I have the instructions to address you as under:

  1. That my client took the premises comprising [DESCRIPTION OF PREMISES, e.g., "a residential house / portion / flat / shop"], situated at [PROPERTY FULL ADDRESS] (hereinafter "the premises"), on tenancy from you for the period from [TENANCY START DATE] to [TENANCY END DATE], at a monthly rent of Rs. [MONTHLY RENT IN FIGURES]/- (Rupees [MONTHLY RENT IN WORDS] only). (Select and keep the applicable version; delete the other:) (a) The tenancy was recorded in a written tenancy agreement dated [AGREEMENT DATE], duly executed between you and my client [and presented before the Rent Registrar as required under Section 5 of the Punjab Rented Premises Act, 2009]. (b) The tenancy was settled on an oral understanding between you and my client, the terms whereof were admitted and acted upon by both parties.

  2. That at the commencement of the tenancy, my client paid to you a sum of Rs. [SECURITY DEPOSIT IN FIGURES]/- (Rupees [SECURITY DEPOSIT IN WORDS] only) as security deposit / advance, the receipt whereof was duly acknowledged by you. (Select and keep the applicable proof; delete the others:) (a) vide your written receipt dated [RECEIPT DATE]; (b) vide bank transfer / pay order No. [TRANSFER REFERENCE NUMBER] dated [TRANSFER DATE]; (c) as recorded in Clause [CLAUSE NUMBER] of the tenancy agreement dated [AGREEMENT DATE]. The said amount was held by you as security for the due performance of the tenancy and was refundable to my client upon vacation of the premises, subject only to adjustment of lawful outstanding dues, if any.

  3. That my client duly vacated the premises on [VACATION DATE] and handed over the keys and peaceful, vacant possession of the premises to you / your authorized representative, [NAME OF PERSON WHO RECEIVED THE KEYS, if known], on [KEY HANDOVER DATE]. (If you hold a written acknowledgement of the key handover, add: "as acknowledged by you in writing dated [DATE]".) At the time of vacation, my client had cleared and paid all rent, utility bills (electricity, gas, water), and maintenance charges up to the date of vacation, and no amount whatsoever was outstanding against my client. The premises were handed over in proper condition, subject only to normal wear and tear.

  4. That since the vacation of the premises, my client has made repeated requests — verbally and in writing — for the refund of the said security deposit, including on [DATE(S) OF REFUND REQUESTS, e.g., "05-09-2026 and 28-09-2026"], but you have failed and neglected to refund the same. You have neither refunded the deposit, nor furnished any written, itemized account of any deduction or adjustment claimed by you, nor offered any lawful justification for withholding my client's money.

  5. That your refusal and omission to refund the security deposit of Rs. [SECURITY DEPOSIT IN FIGURES]/- is unlawful, unjustified, and in breach of the terms of the tenancy and the understanding between the parties. A security deposit is held as security; it is not the landlord's property, and withholding it without a lawful, documented adjustment is a breach of your obligations. My client has suffered financial loss and hardship on account of your conduct, for which my client reserves the right to claim compensation, interest, and costs as admissible under the law.

  6. That I, therefore, under instructions from my client, hereby call upon you, through this legal notice, to pay to my client the sum of Rs. [SECURITY DEPOSIT IN FIGURES]/- (Rupees [SECURITY DEPOSIT IN WORDS] only), being the refundable security deposit, by bank draft / pay order / bank transfer drawn in favour of my client, within [15] (Fifteen) days of the receipt of this notice, positively.

  7. That in the event of your failure to make the said payment within the stipulated period, my client shall be constrained, without any further notice to you, to initiate appropriate legal proceedings against you — including an application before the learned Rent Tribunal under the Punjab Rented Premises Act, 2009 (which has exclusive jurisdiction over disputes between landlord and tenant, and whose final orders expressly cover the adjustment of security, advance rent, arrears of rent, compensation and costs) — or a civil suit for recovery before the competent court of law, for recovery of the said amount together with interest, damages, and costs of proceedings, entirely at your risk as to costs and consequences.

  8. That this notice is issued without prejudice to any other rights and remedies available to my client under the law, all of which are expressly reserved. A copy of this notice is retained in my office for record.

Yours faithfully,

 

 

[ADVOCATE'S FULL NAME] Advocate [High Court / District Courts [CITY]] for and on behalf of [TENANT'S FULL NAME] Chamber: [ADVOCATE'S CHAMBER ADDRESS] Contact: [ADVOCATE'S PHONE NUMBER]

Copy retained for record.

(END OF NOTICE — delete this line before printing.)

How to use this notice: step by step

Step 1 — Fill in every blank carefully. Amounts must appear both in figures and in words (e.g., Rs. 100,000/- (Rupees One Hundred Thousand only)) — this prevents tampering and is standard legal practice. Dates should be exact, taken from your receipts and agreement. Where a paragraph offers options (a)/(b)/(c), keep only the one that is factually true and delete the rest; never leave two contradictory versions in the final notice. Have your advocate read the filled draft before it goes out — a wrong date or amount can weaken your case.

Step 2 — Print it on your advocate's letterhead. A legal notice carries far more weight when issued "through" an advocate: it signals that a lawyer is already engaged and that court proceedings are a genuine next step. The advocate should sign it in ink and stamp it. (A tenant may send a demand personally, but an advocate's notice is the professional standard and is what landlords — and courts — take seriously.)

Step 3 — Send it by Registered Post A.D. and keep every receipt. "A.D." means Acknowledgement Due: the postman obtains the recipient's signature on an acknowledgement card that is mailed back to you — this is your proof of delivery. Procedure: - Post two copies: one by Pakistan Post Registered Post A.D., and one by a reputable courier (TCS, Leopards, etc.) for speed and tracking. - Keep the postal receipt (counterfoil), the courier booking receipt with tracking number, and the returned AD card when it arrives. Staple them to your office copy of the notice. - Optionally, also send a scanned copy by WhatsApp and email to the landlord and keep screenshots — useful supplementary evidence, but not a substitute for registered post.

Step 4 — If the landlord refuses to accept the notice. If the postman reports refusal, keep the postal endorsement ("refused") — a notice properly addressed and posted is generally treated as served even if refused. Your advocate can also arrange service through a process server. Do not let a refusal stop you; document it.

Step 5 — Wait out the 15 days, and keep any negotiation in writing. Many landlords settle after receiving a notice rather than face court. If the landlord offers a settlement (for example, a partial deduction for genuine repairs), get any agreement in writing and signed before accepting less than the full amount.

Step 6 — If the 15 days expire without payment, go to the Rent Tribunal. Your advocate will file an application before the Rent Tribunal of the district where the premises is situated (under Sections 16 and 19 of the Punjab Rented Premises Act, 2009; Section 12(3) further empowers the Tribunal to direct a landlord to fulfil obligations under the Act or the tenancy agreement). Attach to the application: a copy of this legal notice, the postal and courier receipts, the tenancy agreement, the deposit receipt or bank proof, rent and utility-bill receipts, and proof of key handover. The Tribunal's order is executable like a court decree, and the losing side can be burdened with costs — point this out to the landlord, because it raises the price of non-compliance. - One caution: under Section 9 of the Act, if the tenancy was never brought into conformity with the Act (for example, no written agreement presented before the Rent Registrar), the Tribunal will not entertain the tenant's application unless a fine equal to 5% of the annual rent is deposited in the Government treasury. Your advocate will advise whether this applies to you. - Act without unnecessary delay: ask your advocate about the time limit for filing, and do not let months pass after the notice expires.

Step 7 — The alternative route: a civil suit for recovery. Where the Rent Tribunal route is not available (for example, premises outside the Act's scope, or a dispute that is purely about money after the tenancy relationship has fully ended), your advocate may instead file a civil suit for recovery of the deposit before the civil court. The legal notice and its postal proof are filed as the first exhibits — they prove you demanded the money before suing.

Step 8 — Keep a complete file. From the day you send the notice, maintain one folder (physical and scanned) containing: the signed notice, postal and courier receipts, the AD card, the tenancy agreement, the deposit receipt, bank statements, rent and utility receipts, key-handover proof, and all messages with the landlord. Cases are won on documents.

The law behind this notice

Punjab — the Punjab Rented Premises Act, 2009 (Act VII of 2009). This is the governing law for landlord–tenant relations in Punjab. Three provisions matter most for security deposits:

  • Section 6(1)(g): a tenancy agreement must record the "amount of advance rent, security or pagri, if any" — the deposit is a recognized, regulated part of the tenancy, not an informal side payment.
  • Section 5: tenancies must be created by a written tenancy agreement presented before the Rent Registrar — one more reason to insist on written agreements and written receipts.
  • Sections 2(b), 12(3), 16 and 19: disputes between landlord and tenant go before the Rent Tribunal (headed by a Special Judge (Rent)), which has exclusive jurisdiction over cases under the Act; a tenant may apply to the Tribunal for an order directing the landlord to fulfil an obligation; and the Tribunal's "final order" is defined to expressly include orders "in respect of adjustment of pagri, advance rent, security, arrears of rent, compensation or costs." In short, recovery of a withheld security deposit is exactly the kind of dispute the Rent Tribunal exists to decide.

A note on terminology: the Act calls the forum the "Rent Tribunal." In everyday language — and under the rent laws of other provinces — the same forum is often called the "Rent Controller." If your advocate or court clerk uses either term, they mean the rent-dispute forum of your province.

Other provinces (province-neutral note): rent law is provincial. Outside Punjab, the equivalent laws and forums are:

  • Sindh: the Sindh Rented Premises Ordinance, 1979 — applications go before the Rent Controller;
  • Khyber Pakhtunkhwa: the Khyber Pakhtunkhwa Urban Rent Restriction Act, 1950 — before the Rent Controller;
  • Balochistan: the Balochistan Urban Rent Restriction Ordinance, 1959 — before the Rent Controller;
  • Islamabad Capital Territory: the Islamabad Capital Territory Rent Restriction Ordinance, 2014 — before the Rent Controller.

The notice template above works in every province — only the forum named in paragraph 7 (Rent Tribunal vs. Rent Controller) and the statute cited need to be adapted by your advocate to your province.

Common questions

What if there was no written tenancy agreement? You can still send this notice and still claim the deposit — many tenancies in Pakistan run on oral agreements. But your proof of payment (receipt, bank transfer, witnesses) becomes critical, and in Punjab, Section 9 of the 2009 Act requires a non-conforming tenant to deposit a fine of 5% of the annual rent before the Rent Tribunal will hear the case. Discuss this frankly with your advocate.

What if the landlord claims deductions for damage or unpaid bills? A landlord may adjust only genuine, documented dues — actual unpaid rent or utility bills, or repair costs beyond normal wear and tear. Vague claims ("the paint is old", "cleaning charges") without bills or photographs are not lawful deductions. Ask in writing for an itemized account with supporting bills; the landlord's silence strengthens your case.

Can I claim interest on the withheld deposit? You can ask for it, and tribunals and courts have discretion to award interest, compensation, and costs — the notice reserves these rights in paragraphs 5 and 7. Whether interest is granted depends on the facts and the forum.

What if the deposit was paid in cash with no receipt? It is harder, but not hopeless: bank withdrawal slips matching the amount and date, witnesses present at payment, the landlord's own messages acknowledging the deposit, or the agreement's security clause can all serve as evidence. Tell your advocate exactly what proof exists before the notice is finalized.

This template is provided for general legal information and educational purposes only. It is not a substitute for advice from a qualified advocate. Tenancy law is provincial and procedures vary; always have an advocate review and adapt this notice to the facts of your case and the law of your province before sending it.