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Download Word Document In English. (Rs.40/-) SUIT FOR MONEY RECEIVED BY DEFENDANT FOR PLAINTIFFS USE Nature of grievance: Suit for money payable by the defendant to the plaintiff for money received by the defendant, for the plaintiff's use: Where a person, under a contract or otherwise, receives any money, for and on behalf of another person, under an obligation to use the said money for that another person’s direction or to forward the said money to the said another person, but refuses or neglects to do so – A Suit may be filed for the recovery of said money, within three years from the date when the said money was received, under Article 24 of the Indian Limitation Act, 1963. Reliefs prayed: (As may be appropriate and applicable to the facts of one’s case) a)     The Defendant be ordered and decreed to pay Rs.________, as per particulars of Claim, annexed to the Plaint (Exhibit “____”); b)     The Defendant be further ordered and decreed to pay interest on the Suit amount, @18% from the date of filing of Suit, till date of judgment; and further interest @18 / 12 / 6 % from the date of judgment till payment; c)     The Hon’ble Court be pleased to declare that ___________  (declaration, in the absence of which the rights of the Plaintiff may be frustrated); (as may be applicable to the facts of the case) (Please see the Note below) d)     The Defendant be permanently injuncted from acting (permanently restrained from doing of certain acts), such acts which would otherwise frustrate the rights of the Plaintiffs, or such acts, which would otherwise run contrary to the rights of the plaintiff; (as may be applicable to the facts of the case) (Please see the Note below) e)     The Defendant be ordered and decreed by way of Mandatory Injunction to __________ “perform certain acts”; (as may be applicable to the facts of the case) (Please see the Note below) Interim and Ad-Interim Reliefs: Pending the hearing and final disposal of the Suit, the Hon’ble Court so as to prevent the ends of justice from being defeated, be pleased to Order – f)      The Hon’ble Court, in the due exercise of their powers u/s 94 and O.38 of CPC, 1908, issue a warrant to arrest the defendant and bring him before the Court to show cause why he should not give security for his appearance, and if he fails to comply with any order for security commit him to the civil prison; (as may be applicable to the facts of the case) g)     The Hon’ble Court, in the due exercise of their powers u/s 94 and O.38 of CPC, 1908, direct the defendant to either (i) furnish security to produce any property belonging to him and to place the same at the disposal of the Court or (ii) order the attachment of his property, or, (iii) furnish the bank guarantee for the Suit amount or (iv) deposit the Suit amount in the Court; h)     The Hon’ble Court, in the due exercise of their powers u/s 75 and O.26 of CPC, 1908, be pleased to appoint Court Commissioner, so as to carry out examination of Accounts of the Defendants for the years ______, and file Report before this Hon’ble Court; (as may be applicable to the facts of the case) (Please see the Note below) i)       The Hon’ble Court, in the due exercise of their powers u/s 75 and O.26 of CPC, 1908, be pleased to appoint Court Commissioner, to hold a scientific, technical, or expert investigation; or to perform any other ministerial act; (as may be applicable to the facts of the case) (Please see the Note below) j)       Interim/ad-interim reliefs in terms of prayer clauses _______ as aforesaid. k)     Such further and other reliefs as this Hon’ble Court may deem fit and proper in the circumstances of the case as may be necessary. Note: In Summary Suits, the Reliefs could only be in the nature of Money, i.e. the Principal sum and the interest, if any claimed, and no declaration or injunction of any nature could be asked for. In Summary Suits, even unliquidated compensation or damages cannot be claimed. However, if other Reliefs are also required to be sought, then, preferably, a leave of the Court under O.2 R.2 may be obtained to file a separate Suit for other Reliefs. Nevertheless, a comprehensive regular Suit may be filed claiming all Reliefs, instead of filing two Suits. Further, whereas Summary Suits are not maintainable in every District Court, in such cases, a comprehensive Suit for all the Reliefs may be filed. Also, please take note of this whilst making averments in the body of Plaint. Material facts of the case: The Plaintiffs, most respectfully submit that, having regard to the nature of reliefs prayed for in this Suit, the following facts become germane to the controversy herein; And, the reasonable satisfaction of the existence or the non existence, as the case may be, of these facts, may entitle the Plaintiffs the judgment in their favour. The chronology / chain of events, which has led to the present situation, and has constrained the Plaintiffs to seek certain Reliefs from this Hon’ble Court. [In the chronology / chain of events, the following facts should be set out in clear terms, at appropriate juncture.] 1.      The facts showing that, under a contract between the Plaintiffs and Defendant, or otherwise, the Defendant received certain amount of money, for and on behalf or for the use of the Money for the Plaintiffs: 2.      The facts showing that the Defendant is bound to pay or use the said money received, to the Plaintiffs: 3.      The facts showing that Defendant is neglecting to pay the said amount or use the said Money for Plaintiffs: In Money Claim Suits, to claim interim relief, “of arrest of the Defendant to cause him to furnish security for his appearance, pending the disposal of the Suit”, any one of the facts must be shown to have exist – 1.      Facts and circumstances showing that, with intent to delay the plaintiffs, or to avoid any process of the Court or to obstruct or delay the execution of any decree which may be passed against him, the defendant has absconded or left the local limits of the jurisdiction of the Court: or 2.      Facts and circumstances showing that, with intent to delay the plaintiffs, or to avoid any process of the Court or to obstruct or delay the execution of any decree which may be passed against him, the defendant is about to abscond or leave the local limits of the jurisdiction of the Court: or 3.      Facts and circumstances showing that, with intent to delay the plaintiffs, or to avoid any process of the Court or to obstruct or delay the execution of any decree which may be passed against him, the defendant has disposed of or removed from the local limits of the jurisdiction of the Court his property or any part thereof: or 4.      Facts and circumstances showing that, with intent to delay the plaintiffs, or to avoid any process of the Court or to obstruct or delay the execution of any decree which may be passed against him, the defendant is about to leave India under circumstances affording reasonable probability that the plaintiff will or may thereby be obstructed or delayed in the execution of any decree which may be passed against the defendant in the suit: In Money Claim Suits, to claim interim relief of “directing the Defendant to furnish security for certain sum of money, either by furnishing the bank guarantee or by depositing the said sum of money in the Court”, or to effect the conditional attachment of his immovable property, pending the disposal of the Suit”, any one of the facts must be shown to have existed. 1.      Facts and circumstances showing that, with intent to obstruct or delay the execution of any decree which may be passed against him, the defendant is about to dispose of the whole or any part of his property: or 2.      Facts and circumstances showing that, with intent to obstruct or delay the execution of any decree which may be passed against him, the defendant is about to remove the whole or any part of his property from the local limits of the jurisdiction of the Court: or 3.      Facts and circumstances showing that the Defendants have admittedly committed default in making payment of debt; and the Defendants have not even bothered to respond to the legal notice of demands being issued by the Plaintiffs; and the Defendants have prima facie no defense to the demand made by the Plaintiffs; and if the claim of the Plaintiffs is not secured by passing appropriate order against the Defendants, there would be a paper decree in the hands of the Plaintiffs and such huge claim made by the Plaintiffs would not be recovered. or 4.      Facts and circumstances showing that the Defendant has become incommunicable, i.e. he is not available at the place where he regularly carries on business; and he doesn’t answers the phone calls, nor the Defendant makes any reply to the Notices which are being sent; and therefore there is a reasonable apprehension that the Defendant may dispose of the whole or any part of his property, to the serious prejudice of the Plaintiffs and other creditors of the Defendants: or 5.      Facts and circumstances showing that the Defendant in their letters and emails, in unambiguous terms have admitted the claim of the Plaintiffs; and / or the Defendants, vide their Letters / Emails dated _________ to the Plaintiffs, have stated that the Defendant is facing severe financial crunch; and therefore there is a reasonable apprehension that the Defendant may alienate, encumber, dispose or create third party rights in respect of their immovable properties, to the serious prejudice of the Plaintiffs and other creditors of the Defendant; and there may not be other properties which could have been made available for the purposes of satisfying the decree, if any, passed against the Defendants; and if the claim of the Plaintiffs is not secured by passing appropriate order against the Defendants, there would be a paper decree in the hands of the Plaintiffs and such huge claim made by the Plaintiffs would not be recovered. If an interim Relief is asked for the appointment of Court Commissioner to carry out examination of Accounts of the Defendants, then, facts showing that such examination of Accounts is just and necessary for the complete disposal of the Suit. If an interim Relief is asked for the appointment of Court Commissioner, to hold a scientific, technical, or expert investigation; etc. then facts showing that such investigation, etc. is just and necessary for the complete disposal of the Suit. [To claim any relief in the nature of declaration] The facts showing that the Plaintiff is entitled to some legal position, or to some property, or to some right of any nature whatsoever; and the facts and circumstances showing that the Defendant is doing some act by which the Defendant deny such rights of the Plaintiffs; [To claim any relief in the nature of permanent injunction] The facts showing that the Plaintiff is entitled to some legal position, or to some property, or to some right of any nature whatsoever; and the facts and circumstances showing that the Defendant is doing some act by which the Defendant interferes with such rights of the Plaintiffs; [To claim any relief in the nature of mandatory injunction] The facts showing that the Defendant is under obligation under the law or under the contract, to perform certain acts, which he is neglecting to do, and the Courts can compel performance of such acts, and the performance of such acts are essential pending the final disposal of the Suit, and the failure of performance of such acts may render the Suit infructuous.

Download Word Document In English. (Rs.20/-) SUIT TO RECOVER POSSESSION OF IMMOVABLE PROP. OF TRUST TRANSFERRED BY THE TRUSTEE Nature of grievance: Suit to recover possession of immovable property conveyed or bequeathed in trust and afterwards transferred by the trustee for a valuable consideration:  Where an immovable Property, which is conveyed or bequeathed to a Trust, is transferred by the trustee for a valuable consideration, the possession of the said Property may be recovered, when the transfer becomes known to the plaintiff, by filing Suit under Article 92, within 12 years, from the date of knowledge of the Plaintiff of such transfer. or Suit to recover possession of movable property conveyed or bequeathed in trust and afterwards transferred by the trustee for a valuable consideration: Where a movable Property, which is conveyed or bequeathed to a Trust, is transferred by the trustee for a valuable consideration, the possession of the said movable Property may be recovered, when the transfer becomes known to the plaintiff, by filing Suit under Article 93, within 3 years, from the date of knowledge of the Plaintiff of such transfer. Reliefs prayed: (As may be appropriate and applicable to the facts of one’s case) a)     The Hon’ble Court be pleased to declare that ___________  (declaration, in the absence of which the rights of the Plaintiff is frustrated); b)     The Hon’ble Court be pleased to declare that Plaintiffs are entitled to the Suit property to the extent of the interest (which is asserted and claimed in the Suit); c)     That the defendant be ordered and decreed to handover vacant and peaceful possession of the Suit property (Immovable), specified in the schedule hereunto annexed at Exhibit ___ to the Plaint; d)     That the defendant be ordered and decreed to handover possession of the Suit property (Movable), specified in the schedule hereunto annexed at Exhibit ___ to the Plaint; e)     The Defendants be permanently injuncted from acting (permanently restrained from doing of certain acts), such acts which would otherwise frustrate the rights of the Plaintiffs, or such acts, which would otherwise run contrary to the rights of the plaintiff. f)      The Defendants be ordered and decreed by way of Mandatory Injunction to __________ “perform certain acts”; g)     The Defendants be ordered and decreed to pay mesne profits from the date of occupation of the Suit property, till the date of institution of the Suit; h)     The Defendants be further ordered and decreed to pay mesne profits from the date of institution of the Suit till the handing over of the possession of the Suit property; Interim and Ad-Interim Reliefs pending the hearing and final disposal of the Suit, the Hon’ble Court so as to prevent the ends of justice from being defeated, be pleased – i)       This Hon’ble Court by its Order and Injunction be pleased to restrain the Defendant, their servants, agents or anybody acting through Defendant from dealing with, disposing off, alienating, encumbering, parting with possession or creating third party rights, of any nature whatsoever, in respect of the suit property, more particularly described in the Schedule of properties being Exhibit “___” hereto. j)       That pending the hearing and final disposal of the above suit, that this Hon’ble Court be pleased to appoint Court Receiver, High Court, ______ or some other fit and proper person as Receiver in respect of the suit properties as more particularly described in the Schedule of properties being Exhibit “__” hereto with all the powers under Order 40 Rule 1 of the Code of Civil Procedure, including the power to sell the suit property. k)     That pending the hearing and final disposal of the above suit, the Hon’ble Court, in the dues exercise of powers u/s 75 and O.26 of CPC, 1908, be pleased to appoint Court Commissioner, so as to carry out local investigation of the Suit property described in the Schedule of properties being Exhibit “__” hereto, (for the purpose of elucidating any matter in dispute, or of ascertaining the market-value of any property, or the amount of any mesne profits or damages or annual net profits (as may be applicable), with all the powers under of the Code of Civil Procedure, and file Report before this Hon’ble Court; l)       Interim/ad-interim reliefs in terms of prayer clauses _____ as aforesaid. m)   Such further and other reliefs as this Hon’ble Court may deem fit and proper in the circumstances of the case as may be necessary. Material facts of the case: The Plaintiffs, most respectfully submit that, having regard to the nature of reliefs prayed for in this Suit, the following facts become germane to the controversy herein; And, the reasonable satisfaction of the existence or the non existence, as the case may be, of these facts, may entitle the Plaintiffs the judgment in their favour. The chronology / chain of events, which has led to the present situation, and has constrained the Plaintiffs to seek certain Reliefs from this Hon’ble Court.  [In the chronology / chain of events, the following facts should be set out in clear terms, at appropriate juncture.] 1.      The facts showing that the Suit property is a Property, which was conveyed or bequeathed to a Trust: 2.      The facts showing that the Suit property was transferred by the Trustees of the said Trust: 3.      The facts showing that the Suit property was transferred for a valuable consideration: 4.      The facts showing that the said transfer was otherwise illegal and was against the interest of the said Trust: So as to claim Relief in the nature of staying and preventing the wasting, damaging, alienation, sale, removal or disposition of the Suit property, or to prevent dispossession of the plaintiff, or otherwise to prevent causing injury to the plaintiff in relation to the Suit property, and to seek appointment of the Receiver upon the Suit property, the applicable facts must be shown to exist, that is – 5.       Facts and circumstances showing that the (i) Suit property is in danger of being wasted, damaged or alienated by the Defendant; or that (ii) the Suit property is wrongfully being sold in execution of a decree; or that (iii) the defendant threatens, or intends to remove or dispose of his property with a view to defrauding his creditors; or that (iv) the defendant threatens to dispossess the plaintiff or (v) the defendant otherwise would cause injury to the plaintiff in relation to the Suit property. [To claim any relief in the nature of declaration ] The facts showing that the Plaintiff is entitled to some legal position, or to some property, or to some right of any nature whatsoever; and the facts and circumstances showing that the Defendant is doing some act by which the Defendant deny such rights of the Plaintiffs; [To claim any relief in the nature of permanent injunction]  The facts showing that the Plaintiff is entitled to some legal position, or to some property, or to some right of any nature whatsoever; and the facts and circumstances showing that the Defendant is doing some act by which the Defendant interferes with such rights of the Plaintiffs; [To claim any relief in the nature of mandatory injunction ] The facts showing that the Defendant is under obligation under the law or under the contract, to perform certain acts, which he is neglecting to do, and the Courts can compel performance of such acts, and the performance of such acts are essential pending the final disposal of the Suit, and the failure of performance of such acts may render the Suit infructuous. If an interim Relief is asked for the appointment of Court Commissioner,  to hold a scientific, technical, or expert investigation; or to conduct sale of property, etc. then facts showing that such investigation, etc. is just and necessary for the complete disposal of the Suit.

SUIT FOR SPECIFIC PERFORMANCE Format of Application for Witness . IN THE COURT OF ________________ __________ VS. ____________ Application for summoning the witnesses and Permission to deposit the expenses of Witnesses. Sir, The applicant/plaintiff respectfully submits as under: – 1- That the above noted petition is pending in this hon’ble court and is fixed for ___________. The applicant wants to summon the following witnesses for the date fixed: – (i) _________________________ with the relevant record of cash order /pay order dated _____________ vide No. ___________ Branch Code _________ (ii) _____________________ with the record of Register of attestation of affidavits dated _______ of Shri __________ Son of Shri ___________, resident of ___________________ (iii) Record keeper of record room lower court with the record of case No. ______ of ____________ Year titled as “ _____________ VERSUS ____________ ” decided on ______________  which was decided by Shri _____________________. (iv) Shri _______________, Advocate, ________________. Prayer: It is, therefore, prayed that the above mentioned witnesses may kindly be summoned for the date fixed and the applicant/plaintiff may kindly be allowed to deposit the expenses of the witnesses before this hon’ble court. Dated _______  APPLICANT /PLAINTIFF Through counsel: ________________, Advocate,  ___________________ Download Word Document In English. (Rs.10/-)

Suit for Declaration and in the Consequential Relief of Permanent Injunction By Administrator In the court of ______  In the Matter of: ____ VERSUS _____SUIT FOR DECLARATION AND IN THE Consequential RELIEF OF PERMANENT INJUNCTION APPLICATION UNDER SECTION ____ FOR  STAYING THE SUIT  Sir,The applicant/defendant most respectfully submits as under: -1- That the above noted case is pending before this Hon’ble court and fixed for today for notice. 2- That the plaintiff sold the plot/ house comprised in ____, admeasuring ___ total measuring Sq. yards to the applicant/defendant vide sale Deed bearing its document No. __ dated ____ registered in the office of ____. The photocopy of the sale Deed is enclosed herewith. 3- That the applicant/defendant has filed a Suit for Possession in the consequential relief of Permanent injunction titled as “____ VERSUS ____” in the court of ____, Civil Judge, ____ which is now fixed for ____ for consideration. The Hon’ble court has granted stay in favour of the applicant/defendant and against the plaintiff (defendant in that suit) vide order dated ____. The plaintiff has filed the written statement in that suit. 4- That now the plaintiff intentionally and deliberately to misguide this Hon’ble court has filed. The present suit has been filed by the plaintiff against the defendant with due diligence and full knowledge that the defendant has already filed the suit for possession and permanent Injunction against the plaintiff. In previously instituted case the both parties are similar. The plaintiff has filed the present suit on the same subject matter, same suit property, same title, on the same facts, same grounds hence the suit of the plaintiff is not maintainable and is liable to be dismissed with costs under section of CPC. It is, therefore, prayed that the above noted suit which has been filed by plaintiff against applicant/defendant may kindly be stayed and may be dismissed with special costs Under section __ of CPC in the interest of justice. Dated Applicant/Defendant  ____ S/o ____R/o____ THROUGH COUNSEL  _____ Advocate, _____ Download Word Document In English. (Rs.10/-)

Civil suit for permanent prohibitory injunction...  IN THE COURT OF CIVIL JUDGE AT …………… In Civil Suit No.: ______ of ………… …………………………………………………………………Plaintiff  Versus …………………………………………………………………Defendants  Civil suit for permanent prohibitory injunction for restraining the defendants from interfering in any manner whatsoever particularly ________________________ situated over No. __________No. ______________________ more particularly depicted in rough plan of the sight and photograph excepting in accordance with Law. Respectfully Sheweth:  1. That the plaintiff is resident of ______  2. That the plaintiff is presently working as _______ with the department.  3. That in the month of ____________ the state of ___________ has orally granted the suit land in favour of the plaintiff and allowed the plaintiff to raise construction for his residential house over the same. The plaintiff has spent major portion of his hard earned money for the construction of the said shed house situated over --------------------------------------- No. after getting the ……………………..……..constructed over the suit land by the plaintiff the state government/ department has also recognized the legal possessor status of the plaintiff over the suit land. The plaintiff has also been given …………………..……… from ………………..…………..department and he has also got his ………… on the same address. The name of the plaintiff and other persons of his family members are also figuring in the ………………………………..of the said ward.  4. That till.......................................... nobody has objected to and raised any objection regarding the raising of construction of the house of the plaintiff over the said and the plaintiff lived there peacefully, openly and to the very constant of the owner of the property. The possession of the plaintiff is long standing a one and the same has not been disputed/ disturbed by any one till date. 5. That no show cause notice of any proceedings for the eviction of the plaintiff from the land and from the house raised by the plaintiff over the same has ever been initiated. 6. That on ______ some of the officials from ______ department came on the spot and threatened to dispossess the plaintiff from the suit land and also threatened to dismantle the house/shed of the plaintiff without any legal orders that too illegally and wrongly. As no order of eviction has been passed against the plaintiff till date by any competent authority/Court as such plaintiff has got prima facie a very good case in his favour since he is in possession of land for the last more than _____ years. The balance of convenience is also in favour of the plaintiff and against the dependent and in case the suit of the plaintiff is not decreed the plaintiff will suffer irreparable loss and injury which can't be compensated in terms of money, rather it will lead to multiplicity of litigation between the parties and the plaintiff will come on roads as he has no other residential house except the present one. 7. That there are as many as ________________________ residential house constructed by some other people over the adjoining land of the present plaintiff which is also owned by _______ government/department. That till date no show cause notice has been issued to them nor any proceedings for eviction has been started/initiated against them in the competent Court of law. The wrongful all illegal dispossession/dismantling the house of the plaintiff is arbitrary, malafide, illegal and even discriminatory.  8. Jurisdiction. 9. Cause of action. 10. Limitation. 11. Valuation. ……………… Plaintiff _________ ______  Through, Advocate  Download Word Document In English. (Rs.15/-)

Download Word Document In English. (Rs.70/-) SUIT PERMANENT INJUNCTION  IN THE COURT OF CIVIL JUDGE AT …………………….. Civil Suit No.;…………../…………… Mr/,MRS………………………………………………………………………………………………………Plaintiff  Versus Mr/…MRS…………………………………………………………………………………………………..Defendants  Suit for Permanent Prohibitory Injunction and Mandatory Injunction restraining the defendant from raising any construction over the suit land comprising in ---------- --------------- No. _____, ---------------- No. _____________________ measuring ______________- situated at ___________________________ restraining the defendant from causing any construction over the suit land against the Municipal Corporation Act and Bye-Laws and Town & Country Planning Act and Rules and also directing the defendant to remove illegal and unauthorized construction over the suit land owned and possessed by the plaintiff and also directing the demolition of the construction already raised or raised during the tendency of this suit on the set-back area of the suit land owned by the defendant _____and also with the prayer to direct the defendant to handover the peaceful possession of the suit land already encroached upon by the defendant No. 1.  Respectfully Sheweth:  1. That the plaintiff is owner in possession of land comprising in ------- --------------- No. _____ -------------- No. _____, ------------------ No. _____, ------------------ No. _____ measuring ______ ----------------situated at ________ as per the ------------------ for the year ______. ______The plaintiff has a building raised on the above land duly sanctioned by the appropriate authority. 2. That the defendant is owner of the land comprised in -------------- --------------- No. ________._____....- No. ______ situated at _______ as per the ----------------- for the year _______. 3. That the defendant No. 1 during the month of has started raising further construction in as much as without leaving any set-backs as prescribed by the law and further encroached upon the land of the plaintiff by projecting the ---------- towards the land of the plaintiff and thus obstructing light, air and sun to the building of the plaintiff besides causing nuisance to the plaintiff and his tenants, thereby depriving the plaintiff of his Easementry rights of light, air and sun, which rights were being enjoyed by the plaintiff and his predecessor-in-interest from time immemorial peacefully, openly and hostile to the very knowledge of the defendant or other persons living in the vicinity. The said rights of Easementry have now been infringed by the defendant in the month of ____ by raising the construction in haphazard manner in as much as the defendant ______  4. That the cause of action accrued to the plaintiff on ______  5. That the plaintiff is permanently residing within the jurisdiction of this Hon'ble court and all the correspondence from the defendants were received at his home address and the office of the defendant is located in the territory of this Hon'ble Court, hence this court has each and every jurisdiction to try and entertain this suit. ______ 6. That the value of the suit for the purposes of jurisdiction has been fixed for Rs. 200/- and for the purposes of declaration and correct and authorized court fee stamp of Rs. ________________ has been affixed on the plaint.  7. That no suit has been instituted against the defendants on the same or similar cause of action in any other court including High Court and Supreme Court of India. 8. It is, therefore, most respectfully prayed that a decree for Permanent Prohibitory Injunction and Mandatory Injunction restraining the defendant from raising any construction over the suit land comprising in ---------- ----------------- No. _____, --------------------- No. _____ measuring _____ ----------------- situated in _____ restraining the defendant from causing any construction over the suit land against the Municipal Corporation Act and Bye-Laws and Town & Country Planning Act and Rules and also directing the defendant to remove illegal and unauthorized construction over the suit land owned and possessed by the plaintiff and also directing the demolition of the construction already raised on the set-back area of the suit land owned by the defendant and also with the prayer to direct the defendant to handover the peaceful possession of the suit land already encroached upon by the defendant No. 1, be passed in favour of plaintiff and against the defendants with costs of the suit. Such other reliefs as deemed fit and proper in the facts and circumstances of the case may also be passed in favour of the plaintiff and against the defendants in the interest of justice. AND FOR THIS ACT OF KINDNESS, THE HUMBLE PLAINTIFF AS IN DUTY BOUND SHALL EVER PRAY. ……………………………. Plaintiff ______________  Through, Advocate  Verification: I, ______________________________-, do hereby verify that the contents of the above plaint from paras 1 to _______ are true and correct to the best of my knowledge and belief. Verified at …………… this the _______.  Plaintiff  IN THE COURT OF CIVIL JUDGE AT  …………….. Civil Suit No;…………../…………….. ……………………………………………………………………………………..Plaintiff  Versus ………………………………………………………………………………………….Defendant  Affidavit I, __________________________, do hereby solemnly affirm and declare as under:- 1.______________________________ That the accompanying plaint has been drafted under my instructions. For the sake of brevity, the contents of plaint are not being reproduced hereunder in this affidavit. However, the contents of the plaint may kindly be read as part and parcel of this affidavit. 2. That the contents of paras 1 to ______ of the plaint are correct and true to the best of my knowledge and paras _________ to ________________ are believed to be correct being legal advise given by the counsel. 3. That I further solemnly affirm and declare that the contents of this affidavit of mine are correct and true and no part of it is false and nothing material has been concealed therein. Affirmed here at ………………… this ______. Deponent  IN THE COURT OF CIVIL JUDGE AT …………….. Application No;…………………../……… ………………………………………………………………………………………….Applicant  Versus …………………………………………………………………………………………….Respondent Application under order 39 Rule 1 and 2 of the Civil Procedure Code for Permanent Prohibitory Injunction and Mandatory Injunction restraining the defendant from raising any construction over the suit land comprising in -------------- ------------- No. ________, ----------------- No. measuring _____ ---------------- situated at _______ restraining the defendant from causing any construction over the suit land against the Municipal Corporation Act and Bye-Laws and Town & Country Planning Act and Rules and also directing the defendant to remove illegal and unauthorized construction over the suit land owned and possessed by the plaintiff and also directing the demolition of the construction already raised on the set-back area of the suit land owned by the defendant and also with the prayer to direct the defendant to handover the peaceful possession of the suit land already encroached upon by the defendant No. 1. Respectfully Sheweth: 1. That the applicant/plaintiff has filed a case before this Hon'ble Court hearing where of will take some time. 2. That it is apparent from perusal of grounds and documents attached therewith that the applicant has prima facie a very good case in his favour and the case is likely to succeeds. The balance of convenience is in favour of the applicant. The grounds of the case may be read as part of this application to save the repetition. 3. That the interest of justice demands that the respondent is restrained from . In case the respondents are not restrain that the applicant will suffer irreparable loss and injury which cannot be compensated in terms of money and filing of this case will become infructuous. 4. It is therefore most respectfully prayed that the respondents be restrained from _____ in the interest of justice. Such other orders he also passed in favour of the applicant as deemed fit in facts and circumstances of the case. ………………………………. Applicant _____ …………….., Advocate  IN THE COURT OF CIVIL JUDGE AT ……………………………. Application No: of  / ………………….…………………………………………………………………….Applicant  Versus ………………………………………………………………………………………..Respondent  Affidavit in support of application under order 39 Rule 1 and 2 of the Civil Procedure Code. I, , do hereby solemnly affirm and declare as under:- 1. That the accompanying application has been prepared under my instructions. 2. That the contents of paras 1 to are true and correct to the best of my knowledge. 3. That I further solemnly affirm and declare that the contents of this affidavit of mine are correct and true to the best of my knowledge and no part of it is false and nothing material has been concealed therewith. Affirmed at ……………………… this ______ Deponent  IN THE COURT OF CIVIL JUDGE AT …………………….. ……………….……………V/s……………………………. Suit : for Declaration Name…………………………….   Address……………………………………. In the above noted suit every summons, notice & other order may be served on me on the address given above during the pendency of the suit. Change of Address will be intimated to the Court. Dated : ______ Sd:- Plaintiff/ Petitioner Defendant/ Respondent. Through, Advocate Process Fee  IN THE COURT OF CIVIL JUDGE AT ………………………… ________ Versus ________ Claim : for Declaration Date of Hearing :________ Date ________ By Whom Filed________ Purpose________ Amount ________ Stamp ________ ________ Plaintiff For service of defendants Advocate _______________________________________________ Received on ________ Court-fee stamp of the value of Rs. _____ with ______ copies in case No.;…………./………… in Re. ________ Vs ________ Signature of the Head Notice Writer  Under Order 7 Rule 13 [1] C.P.C. List of Documents Filed By Plaintiff/Defendant IN THE COURT OF CIVIL JUDGE AT ………………………………………………………………. V/s……………………………………..Date of Hearing: __________ Suit for : for Permanent Prohibitory Injunction Date of Production :________  S.No Details, Date What is If Documents If Rejected Documents Intended Filed What is Then the to be the Exh Marked Date of Proved From on it Return of Document Documents Date:……………… Counsel………………… for Plaintiff/Defendant List of Documents Relied Upon  Under Order 7 Rule 14 CPC Filed by :_______ IN THE COURT OF CIVIL JUDGE AT  ……………………........................ …………………………………………….V/S…………………………………  Suit : for Permanent Prohibitory Injunction Date of hearing: 1. Have you produced any …_______________, as per list. documents with the plaint so, what are those document. 2. Do you wish to produce any more ………………………….., if required. documents which are in your possession and custody if so, what are those documents. 3. Do you wish to rely upon any ……………….……………, later on other documents, if so in from the custody whose possession they are and of the defendants. what are those documents. Counsel for  Dated : ______ …………..

Specific Performance (No. 1)  In the Court of ...................................... KK……………………………………………………………….resi……… ...................... Plaintiff  against GM…………………………….……………………………….resi………….) .................... Defendant KK., the above-named plaintiff, states as follows:- 1. By an agreement dated the ………….... day of…………… ...... and signed by the defendant, he contracted to buy of [or sell to] the plaintiff certain immovable property therein described and referred to, for the sum of.......................... rupees. 2. The plaintiff has applied to the defendant specifically to perform the agreement on his part, but the defendant has not done so. 3. The plaintiff has been and still is ready and willing specifically to perform the agreement on his part of which the defendant has had notice. [i. Facts showing when the cause of action arose and that the Court has jurisdiction. ] ii. The value of the subject-matter of the suit for the purpose of jurisdiction is ...........................rupees and for the purpose of court-fees is ............................................rupees.] 4. The plaintiff claims that the Court will order the defendant specifically to perform the agreement and to do all acts necessary to put the plaintiff in full possession of the said property [or to accept a transfer and possession of the said property] and to pay the costs of the suit. Dated : Plaintiff / Defendant Through, Advocate  Verification: I,...................................................., do hereby verify that the contents from paras 1 to ______ are correct and true to the best of my knowledge and personal belief and no part of it is false and nothing material has been concealed therein. Affirmed at …………………………. this ______. Plaintiff / Defendant  Download Word Document In English. (Rs.15/-)

Goods Sold at a Reasonable Price and Delivered.1  In the Court of ………………………...................................... KK……………………………………….. resi………….. ...................... Plaintiff                                                 against GM………………………………………….resi………………………............Defendant KK……………………………………………………., the above-named plaintiff, states as follows:-  1. On the ……........ day of……....... / ……….. , plaintiff sold and delivered to the defendant {sundry articles of house-furniture], but no express agreement was made as to the price. 2. The goods were reasonably worth .... Rupees. 3. The defendant has not paid the money. i. [Facts showing when the cause of action arose and that the Court has jurisdiction. ] ii. The value of the subject-matter of the suit for the purpose of jurisdiction is ......................Rupees and for the purpose of Court-fees is ..............................rupees. and relief claimed. ] Dated : Plaintiff Through, Advocate  Verification: I, ............................... __, do hereby verify that the contents from paras 1 to ______ are correct and true to the best of my knowledge and personal belief and no part of it is false and nothing material has been concealed therein.  Affirmed at ………………. this ______.  Plaintiff  Download Word Document In English. (Rs.5/-)

RELEASE DEED BY THE RETIRING PARTNER OF A FIRM  THIS DEED OF RELEASE is executed on the _______ day of ________ BETWEEN Sh.________________________________________________,  S/o Sh.________________________________________________,  R/o _______________________________________________ of the first part; AND Sh.____________________________________________________,  S/o Sh.__________________________________________________, R/o ___________________________________________________ of the second part; AND Sh._______________________________________________________,  S/o Sh.___________________________________________________,  R/o ___________________________________________________ of the third part; All three hereinafter collectedly referring as parties and individually as the first party, second party and third party respectively, which expression shall be including their related lawful successors, heirs, representatives and assigns.  WHEREAS 1. The first party was doing business of _________ in partnership under deed of partnership dated the ______ day of ______ under the name of firm _________________________ with the second party and third party, respectively.  2. The first party, being partner with the said firm wants to retire and to disassociation with the firm. After it the remaining partners of the firm have decided the outstanding of the first party with dues of first party have been paid to the first party.  NOW THEREFORE THESE PRESENTS WITNESSETH that the first party individually and the second and third party collectedly, does/do hereby release the other of them from all amounts, accounts, proceeding, claims/demands whatever which each of them at any time had or having up to date hereof against others or each of others of them for or due to concerning the partnership heretofore held by the parties. IN WITNESS WHERE OF, the parties to this deed have set their hands in the presence of __________________ Party of the first part  __________________ Party of the second part  __________________ Party of the third part  Witnesses:  1.  2.  Download Word Document In English. (Rs.10/-) Download PDF Document In Marathi. (Rs.10/-)

RELEASE OF PROPERTY FROM MORTGAGE  THIS DEED OF RELEASE is executed on the _______ day of ________ BETWEEN Sh. _________________________________________________________,  S/o Sh. ______________________________________________________,  R/o ________________________________________________________ of the first part; AND Sh. ______________________________________________________________, S/o Sh._________________________________________________________ R/o ______________________________________________________________ of the second part; Both to hereinafter collectedly referring as parties and individually as the "mortgagee" and "mortgagor" respectively, which expression shall be including their related lawful successors, heirs, representatives and assigns.  WHEREAS 1. By a deed of mortgage dated the ________ day of ______________ mortgagor mortgaged to the mortgagee the property as detailed in detail in the Schedule A annexed hereto (hereinafter referred to as the "property") for securing a loan of Rs.________________ with interest to be charged at the rate of __%.  2. At the request of the mortgagor the mortgagee has consented to release the property from his security to the mortgagee the sum of Rs. ____________ in full payment of the debt owing to him on the aforesaid deed of mortgage.  NOW THIS DEED WITNESSES AS FOLLOWS:  1. As Per the said Agreement and in consideration of the sum of Rs._____________ paid to the mortgagee (receipt as acknowledged by the mortgagee and which the mortgagee will credit to the debt payable to him per above deed of mortgage) the mortgagee hereby transfers and relinquishes to the purchaser the property complete free and discharged from the aforesaid deed of mortgage and from all moneys secured thereby and all claims and demands in relating thereto. IN WITNESS WHERE OF, the parties to this deed have scribed their hands on the day and year above stated. Schedule hereinafter referred to  MORTGAGOR  MORTGAGEE  Witnesses:  Download Word Document In English. (Rs.10/-) Download PDF Document In Marathi. (Rs.10/-)

Download Word Document In English. (Rs.5/-) Download PDF Document In Marathi. (Rs.5/-) RELEASE BY CREDITORS TO A DEBTOR, CONDITIONAL ON COMPOSITION OF DEBTS  THIS RELEASE is made on the ________ day of ________ BETWEEN AA. etc., BB, CC. etc. DD. etc., (hereinafter called the Creditors) of the one Part and YZ. etc. (hereinafter called the Debto ) of the other part;  WHEREAS the Debtor is indebted to the Creditors in several sums specified against their respective names in the Schedule hereto;  AND WHEREAS the Creditors have agreed to accept a composition of ________________________ paise in the rupee in full discharge of their said debts.  NOW THIS DEED WITNESSES as follows:  1. The Debtor agrees on or before the ________ day of ________ to pay to each of the Creditors who shall execute this deed before that date the composition of ________ paise in the rupee on his debt specified in the Schedule hereto.  2. Each of the Creditors hereby agrees to accept such composition in full satisfaction of his said debt.  3. If such composition be duly paid each of the Creditors hereby releases the Debtor from his said debt.  4. This release shall be binding and effectual though not executed by all the Creditors and though all or any of the non-executing Creditors may be paid in full.  5. If the said composition shall not be duly paid at the time and in the manner aforesaid or if before the ________ day of ________ the Debtor shall have been adjudged insolvent then this deed shall be void.  IN WITNESS WHEREOF etc.  The Schedule herein referred to.  Creditors name  Amount of debt  Amount of composition

MUTUAL RELEASE BY THREE PARTNERS  ON ENDING OF PARTNERSHIP  THIS RELEASE DEED is executed on the _______ day of ________ BETWEEN Sh.________________________________________,  S/o Sh._____________________________________,  R/o ________________________________________ of the first part; AND Sh.________________________________________,  S/o Sh.____________________________________,  R/o ________________________________________ of the second part; AND Sh.________________________________________,  S/o Sh.____________________________________,  R/o ________________________________________ of the third part; All three hereinafter collectedly referred to as parties and individually as the first party, second party and third party respectively, which expression shall include their related lawful successors, heirs, representatives and assigns.  WHEREAS 1. The aforesaid parties were doing on the business of ______________________ in partnership under the deed of partnership dated the ______ day of ______ under the firm name of _______. 2. The aforesaid parties have, by mutual consent, ended the said partnership, with effect from ______. NOW THEREFORE THESE PRESENTS WITNESSETH that every party individually and every two of them collectedly, does and so release the other of them and each of others of them from all sums of money, accounts, proceeding, claims and demands whatever which each or two of them at any time had or upto date hereto against others/either of others of them due to and concerning the partnership held before hand by the parties.  It is hereby declared that amount or value of the claim hereby disclaimed is Rs. ______. IN WITNESS WHERE OF, the parties to this deed have set their hands in the presence of __________________ Party of the first part  ______________________ Party of the second part  ______________________ Party of the third part  Witnesses:  1.  2.  Download Word Document In English. (Rs.10/-) Download PDF Document In Marathi. (Rs.10/-)