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SUIT AGAINST A COMMON CARRIER FOR DAMAGES DUE TO DELAY CAUSED IN DELIVERY OF THE GOODS SENT THROUGH HIM IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. That the Plaintiff sent on.................... 19............ the goods, detailed in the Schedule hereto annexed, through the Defendant..................... who are common-carriers from.................... to.................... be delivered on orders of the plaintiff. 2. The defendant unduly delayed for two-months in delivering the said goods at.................... on order of the plaintiff as agreed per voucher dated.................... 19 .................... the terms and conditions noted at the back whereof, and thus caused damage of Rs..................... to the plaintiff. 3. That the plaintiff asked for payment of said damages from the defendant through a registered notice which the defendant received on.................... 19 ..................... but the defendant has denied his liability for damages through his reply dated.................... 19.................... received by the plaintiff, on.................... 19 4. That cause of action arose on.................... 19.................... when the defendant received notice of demand for damages from the plaintiff, and secondly on.................... when the plaintiff received the reply of the defendant, and this Court has jurisdiction to decide the suit. 5. That the suit is valued at Rs...................... the amount of damages, and court-fee is paid on the said amount. RELIEF CLAIMED: The plaintiff claims payment of Rs...................... as damages from the defendant and interest on the amount from the date of the suit till payment thereof. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of..................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/-)

SUIT FOR CANCELLATION OF DEED OF GIFT OBTAINED BY UNDUE-INFLUENCE OR DUE TO THE INSANITY OF THE DONOR IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. That..................... the father of the plaintiff is aged.................... years and has been in very sick health due to old age, and asthma and due to irritation having been caused from the side of the younger brothers of the plaintiff who are leading a life out of way in drinking and other bad habits of gambling etc. The father of the plaintiff is in great mental distress, and he has been allured by the defendant .................... wrongfully to make a gift in his favour of the house No..................... situate at..................... in consideration of which.................... has promised him to maintain for the remaining of his life. Or That E. F. defendant is the mother of the plaintiff, she is aged about 60 years. She has got the house No..................... situate at.................... in inheritance from the father of the plaintiff by way of a will dated.................... left by the deceased father. Now the mother has been in undue influence of XY, sister of the plaintiff and XQ the brother-in-law of the plaintiff and they have got a gift deed of the house registered under their influence in favour of their minor son, on.................... 19.................... 2. That the plaintiff’s father/mother aforesaid had not been insane body and mind and was in great mental distress at the time of executing the said gift, and he/ she had not independent advice, and was induced by the insane mind/the undue influence aforesaid to execute the said gift. 3. That the plaintiff is a minor and is a co-sharer in the properties left by his father, and as such and also due to the reasons aforesaid the gift is void and liable to be cancelled by this Court. 4. That the cause of action arose on.................... 19.................... when the said gift was executed, within the jurisdiction of this Court. 5. That the suit is valued at Rs..................... the price of the house, thirty times of the house tax paid thereon, and court fee is paid accordingly to the reliefs claimed. RELIEF CLAIMED: The plaintiff claims to have the said deed of gift adjudged void and cancelled. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/-)

SUIT FOR CLAIM FOR SETTLED OR CUSTOMARY INTEREST IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. That the plaintiff sold printed books to the defendant on.................... 19.................... on credit worth Rs..................... on condition printed in the Bill itself handed over after getting it countersigned by the defendant to the defendant, that if payment of the bill is not made within fifteen days, interest at the rate of 18 per cent per annum will be charged on the price of the books aforesaid after expiry of fifteen days. Or That the plaintiff supplied grain of Rs..................... on credit to the defendant on.................... 19.................... and according to the custom of the Galla Mandi of ................ city, interest at the rate of............. per cent is charges if the money of the grain is not paid within a Pakhwara after taking delivery of the goods on credit. 2. That fifteen days after.................... 19.................... have expired and the defendant has not paid the price of the goods supplied to him on credit. 3. That cause of action arose on.................... 19.................... when fifteen days expired and this Court has jurisdiction to decide the matter. 4. That the suit is valued at Rs..................... which includes the price of the goods supplied on credit and interest Rs..................... upto the date of filing the suit and court fee is paid thereon. RELIEF CLAIMED: The plaintiff claims payment of Rs..................... price of the goods sold and Rs..................... interest thereon upto the date of filing the suit and interest thereafter till payment thereof. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/-)

SUIT FOR ACCOUNT AGAINST CO-SHARERS IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. That Late.................... was the grand father of the plaintiff and father of the defendants. He owned the houses and shops detailed at the foot of the plaint in the Schedule annexed thereto. 2. That said.................... executed a will dated.................... which he gave specific four shops detailed in the Second Schedule Annexed hereto, to the plaintiff and the remaining properties left by him were distributed equally among the defendants. 3. That Shri.................... aforesaid died on.................... but the defendants concealed the will and the plaintiff who was living separately from his grand father and uncles, since the life-time of his late father Shri..................... could not know about the will, and the defendants had been collecting rents from the tenants of all the shops including those four shops bequeathed to the plaintiff by the deceased grand father aforesaid without the consent of the plaintiff. 4. That when the plaintiff came to know of the will aforesaid, requested the defendant to execute the will and to render to him an account of all the money realised by them as rent of the said four shops from.................... upto date. 5. That the plaintiff is not aware of the exact amount of rents realised by the defendants from the tenants. 6. That the rent of the four shops aforesaid is Rs..................... /- per month and the amount upto this date is Rs..................... (........................................ ) from the tenants, and the suit is accordingly valued at Rs..................... /- and court fee is paid thereon according to the reliefs claimed. 7. That the cause of action arose within the jurisdiction of this Court on .................... when the defendant refused to pay anything to the plaintiff as rents realised by them from the tenants. RELIEFS CLAIMED: The reliefs claimed by way of this suit, are: (1) that the defendants be called for to give a full and true account of the rents realised by them of the shops aforesaid. (2) that the money realised by the defendants from the tenants be got paid from the defendants to the plaintiff. (3) that interest @.................... per cent per annum on the money found due to the plaintiff may be awarded by way of damages from.................... upto date. .................... Schedule—I .................... Schedule—II Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/-)

SUIT FOR ACCOUNT AGAINST AN EX-GUARDIAN IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. That the plaintiff had been a minor upto..................... and the defendant had been a guardian of the property of the plaintiff, per order of appointment as guardian, of the District Judge, Dated.................... 2. That during the period of his guardianship, the defendant had been in exclusive possession of the plaintiffs property, and had been realising the income thereof. The plaintiff requested the defendant on.................... through a registered letter to give account of the income aforesaid. But the defendant did not heed to the demand. He did not reply even to the letter of demand sent by the defendant as aforesaid. 3. That the plaintiff is not aware of the income actually realised by the defendant or of the expenditure rendered by him on behalf of the plaintiff. 4. That the cause of action arose on..................... the date of service of letter of demand on the defendant, within the jurisdiction of this Court. 5. That the suit is valued at Rs..................... (........................................), the approximate amount of net income of the property of the plaintiff in the hands of the defendant. RELIEFS CLAIMED: The plaintiff claims the following reliefs: (1) The defendant be ordered to give full and correct account of the income realised and expenditure incurred by the defendant in Court, in respect of the plaintiffs property during the period of guardianship of the defendant. (2) The defendant be ordered to pay the net income of the plaintiff’s property during his guardianship, to the plaintiff. (3) Interest on the net income at the rate of ................. % per annum, or as may be deemed fit may be awarded to the plaintiff. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/-)

SUIT FOR FORECLOSURE OF SALE IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. The plaintiff is the mortgagee of lands belonging to the defendant. 2. The following are the particulars of the mortgage: — (a) (date; (b) (names of mortgagor and mortgagee); (c) (sum secured); (d) (rate of interest); (e) (property subject to mortgage); (f) (amount now due); (g) (if the plaintiffs title is derivative, state shortly the transfers or devolution under which he claims). (if the plaintiff is mortgagee in possession, add). 3. The plaintiff took possession of the mortgaged property on the .................... day of.................... and is ready to account as mortgagee in possession from that time. 4. Cause of action arose on.................... 19.................... when the defendant failed to restore the money of mortgage with interest at the notice of the plaintiff received by the defendant on.................... 19.................... 5. The suit is valued at Rs..................... which is the market value of the property and court fee is paid accordingly to the nature of the reliefs claimed. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/-)

SUIT FOR ADMINISTRATION BY SPECIFIC LEGATEE IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1...................... late of.................... died on or about the.................... day of..................... By his last will, dated the.................... day of.................... he appointed..................... his executor, and bequeathed to the plaintiff (here state the specific legacy). 2. The will was proved by.................... (or letters of administration were granted, etc). 3. The defendant is in possession of the movable property of.................... and amongst other things, of the said (here name the subject of the specific bequest). 4. The cause of action arose within the jurisdiction of the Court on .................... when.................... died. 5. The suit is valued at Rs..................... and court fee is paid according to the nature of the relief claimed. RELIEF CLAIMED: The plaintiff claims that the defendant may be ordered to deliver to him the said (here name the subject of the specific bequest), or that, etc. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/-)

SUIT FOR CANCELLATION OF WILL EXECUTED WHILE THE EXECUTANT WAS NOT SANE IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1..................... father of the plaintiff owned a Pakka House, No..................... situate in.................... and.................... Bighas of Bhumidhari Khata, No............... in village.................... of.................... district. 2. The defendant is the nephew of.................... and.................... had been acutely suffering from dysentry and fever for the last two months before his death occurred on.................... at his house. He was not in proper senses and unable to make any proper decision as to devolution of his properties by will. Just before three days of his death on.................... 19.................... the defendant.................... got executed a will from the deceased of his properties aforesaid in his favour by fraud, when the deceased was unable to understand the nature of deed he executed and could not form any rational judgment relating thereto. 3. The said.................... never executed any will. But the plaintiff has come to know the fact of the alleged will on.................... 19.................... when the defendant has applied for mutation of his name before the Tahsildar for mutation of his name in revenue records in the Bhumidhari Khata aforesaid. 4. The will was never executed by.................... and if executed at all it was executed in his gross insanity when he could not make a rational decision, nor could understand the nature of thing he was doing, and as such is void and ineffective. 5. The cause of action arose within the jurisdiction of this Court on.................... 19.................... when the plaintiff came to know of the void will. 6. The suit is valued at Rs...................... the valuation of the properties which are subject-matter of the said will, andRs..................... for court fees purpose, and court fee is paid according to the nature of the reliefs claimed. RELIEF CLAIMED: The Plaintiff claims that the will aforesaid be adjudged void and cancelled, or in the alternative— It may be declared that the said will was never executed by aforesaid. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.10/-) Download PDF Document In Hindi. (Rs.10/-)

SUIT FOR CANCELLATION OF A SALE-DEED OBTAINED BY FRAUD WITHOUT PLAINTIFF’S CONSENT IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. That the plaintiff’s husband.................... died in.................... leaving behind him the plaintiff, his married daughter..................... and his minor son .................... The plaintiff feeling herself helpless in that plight requested her daughter aforesaid and her son-in-law XY to reside with her till her minor son becomes major and begins to take the responsibility of the properties left by her deceased husband upon him. Accordingly the daughter and son-in-law aforesaid began to live with the plaintiff in her house and began to manage the affairs on her behalf. 2. That on.................... 19.................... XY aforesaid son-in-law of the plaintiff, misrepresented before the plaintiff that a general power of attorney is essential for the management of the affairs of the properties of her, got her thumb-marks on some stamp-papers scribed in English, which language the plaintiff does not know, and in confidence and influence of XY, she put her signatures in Hindi on the document taking it to be the General Power of Attorney, and got it registered before the Sub-Registrar of the town. But, however, the Sub-Registrar did not disclose as to the nature of the document while getting it registered. 3. That later on when on................... 19.................... when notice from the Nagar Mahapalika came in the absence of her son-in-law aforesaid to her about the mutation of name of her son-in-law over the properties of her, she came to know of the fraud played by him. 4. That the defendant well knew that the said representation was false and he made the same fraudulently with a view to induce the plaintiff to put her signatures on it, and admit the execution of the said deed before the Sub-Registrar. 5. The plaintiff apprehends that if the said deed remains outstanding she and her son would be deprived of the properties of theirs, and would be turned out some day from the house itself. 6. That the gift deed aforesaid is void and inoperative, and liable to be cancelled as such. 7. That the cause of action arose within the jurisdiction of this Court on .................... 19.................... when the defendant got the said gift deed executed by fraud, and lastly on.................... 19.................... when the plaintiff came to know that the said deed was not a deed of general power of attorney but it was a gift deed. 8. That the plaintiff is in possession of the properties which are the subject-matter of the aforesaid forged gift-deed. 9. That the suit is valued at Rs..................... for the purpose of valuation of the properties, which are subject-matter of the said gift-deed, and Rs..................... for the purpose of court fee according to the relief sought. RELIEF CLAIMED: The plaintiff claims to have the said gift deed adjudged void and cancelled. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.10/-) Download PDF Document In Hindi. (Rs.10/-)

SUIT FOR DAMAGES FOR OBSTRUCTING WAY AND FOR NJUNCTION TO DEMOLISH THE OBSTRUCTION IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. The plaintiff is, and at the time hereinafter mentioned was possessed of (a house in the village of................. of the District of................. ) 2. He was entitled to a right of way from the house over a certain field to a public highway and back again from the highway over the field to the house of himself and his servants with vehicles, or on foot at all times of the year. 3. On the................. day of................. 19.................. defendant wrongfully obstructed the said way, so that the plaintiff could not pass with vehicles, or on foot or in any manner along the way and has ever since wrongfully obstructed the same. 4. The plaintiff has suffered damages of Rs.................. due to wrongfully obstruction caused by the defendant. 5. Cause of action arose on................. 19................. when defendant obstructed the defendant for the first time from using his right of way. This court has jurisdiction to try the suit. 6. The suit is valued at................. rupees and court-fees is paid thereon, and court-fee on the second relief for demolition of the unauthorised construction of the defendant is also paid on the same valuation, at its one fifth amount, i. e. on Rs. ................. only. RELIEF CLAIMED: The plaintiff claims: (i) payment of Rs.................. as damages from the defendant for the wrongful obstruction. (ii) demolition of the constructions of the defendant obstructing wrongfully the way of the plaintiff by issuing a permanent injunction. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.10/-)

SUIT FOR ENFORCEMENT OF A CHARGE IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. That the plaintiff is the father of defendants.................... and he transferred his property equally among them by way of an oral family settlement, with a condition that both of them will pay Rs..................... /- each to the plaintiff for his maintenance throughout the remainder of his life. 2. That the defendants for the first six months paid regularly the aforesaid charge, but later on have ceased to pay anything to the plaintiff for the last three months, and have now flatly refused to pay anything to him. 3. That the defendants have been in possession of the settled shares of the properties of the plaintiff allotted to them as mentioned at the foot of the plaint. 4. That cause of action arose on.................... 19.................... when the defendants refused to pay the aforesaid charge on the properties transferred to them by way of family settlement aforesaid, and this Court has jurisdiction to decide the suit. 5. That the suit is valued at.................... rupees, the valuation of the yearly charge on the properties, and.................... rupees for obtaining possession of the properties from the defendants in the alternative, and court fee is paid according to the nature of the reliefs claimed. RELIEFS CLAIMED: The plaintiff claims: (1) payment of Rs..................... /- the amount of the charge on the properties for one year from both the defendants in equal shares of Rs..................... each in the alternative — (2) possession of the properties in the hands of the defendants with the charge for three months due, i.e., Rs..................... /-. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/- )

SUIT FOR DAMAGES ON AN INDEMNITY BOND IN THE COURT OF THE.................... Suit No..................... of 19.................... C. D.................................................................... Plaintiff versus C. F................................................................. Defendant The abovenamed plaintiff most respectfully submits as under: — 1. That the plaintiff purchased the Bhumidhari Land of Khata No.............. situate at village.................... of Tahsil.................... District.................... of .................... on.................... 19.................... from E. F. for Rs..................... through a registered sale deed executed on.................... 19.................... 2. That while purchasing the land aforesaid, the defendant executed an indemnity bond to the effect that the land aforesaid is free from any encumbrance, and if anything is found due to the land, the defendant would satisfy the damages so caused to the plaintiff. 3. That after purchase of the aforesaid land, the plaintiff was demanded Rs. .................... as arrears of electricity consumed for the tubewell, and the amount of Rs..................... on account of a simple mortgage of the same land executed on .................... 19.................... in favour of XY. The plaintiff had to pay the electricity charges aforesaid as land revenue to the Electricity Board, and Rs..................... to XY for the satisfaction of the simple mortgage mentioned above. 4. That cause of action arose on.................... 19..................... when the plaintiff had to pay the electricity charges, arrears and on.................... 19 .................... when the plaintiff had to pay Rs..................... in satisfaction of the mortgage aforesaid, and this Court has jurisdiction to decide the suit. 5. That the suit is valued at Rs..................... the amount of the electricity charges plus the amount paid in satisfaction of the mortgage aforesaid, and court fee is paid on the said amount. RELIEF CLAIMED: The plaintiff claims Rs..................... from the defendant as damages on account of payment of electricity charges and the amount of the said mortgage and interest from the date of filing the suit till payment thereof. Plaintiff Through Advocate VERIFICATION I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true. Verified on this................. day of.................... 19.................... at.................... Plaintiff Download Word Document In English. (Rs.5/-) Download PDF Document In Hindi. (Rs.5/-)