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  • SUIT FOR ADMINISTRATION BY CREDITOR ON BEHALF OF HIMSELF AND ALL OTHER CREDITORS

    SUIT FOR ADMINISTRATION BY CREDITOR ON BEHALF OF HIMSELF AND ALL OTHER CREDITORS 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..................... was at the time of his death, and his estate still is indebted to the plaintiff in the sum of.................... (here insert nature of debt and security, if any). 2...................... died on or about the.................... day of.................... By his last Will dated the.................... day of.................... he appointed.................... his executor (or devised his estate in trust, etc., or died intestate, as the case may be). 3. The Will was proved by.................... (or letters of administration were granted etc. ). 4. The defendant has possessed himself of the movable (and immovable, or the proceeds of the immovable) property of..................... and has not paid the plaintiff his debt. 5. The cause of action arose on.................... the date of demise of .................... and this Court has jurisdiction to try the suit. 6. 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 an account may be taken of the movable and immovable property of.................... deceased, and that the same may be administered under the decree of the court. 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.15/-) Download PDF Document In Hindi. (Rs.15/-)

  • SUIT FOR DAMAGES AND INJUNCTION FOR OBSTRUCTING A RIGHT TO USE WATER FOR IRRIGATION

    SUIT FOR DAMAGES AND INJUNCTION FOR OBSTRUCTING A RIGHT TO USE WATER FOR IRRIGATION 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 was at the time hereinafter mentioned, possessed of certain lands situate, etc., and entitled to take and use a portion of the water of a certain stream for irrigating the said lands. 2. On the.................... day of.................... 19..................... the defendant prevented the plaintiff from taking and obstructing and diverting the said stream. 3. The plaintiff verbally requested the defendant not to do so and also gave a registered notice dated.................... received by the defendant on.................... 19..................... requesting him to restrain himself from doing any further the wrongful act aforesaid, and also to tender Rs..................... as damages for his wrongful act already committed and damage caused to the plaintiff. The reply of the defendant denying his liability was received by the plaintiff on............. 19.............. 4. The defendant is liable to be restrained by issue of a permanent prohibitory injunction and to pay damages to the plaintiff for the wrongful act already committed and damage caused to the plaintiff as aforementioned. 5. The cause of action arose on.................... 19.................... within jurisdiction of this Court when the defendant first committed the wrongful act, secondly on.................... 19.................... when the defendant received the notice of the plaintiff and lastly on.................... 19.................... when the plaintiff received the reply of the defendant denying his liability. 6. The suit is valued at Rs...................... the amount of damages claimed and Rs..................... for the purposes of issuing injunction, and Court, fee is paid on both the reliefs accordingly. RELIEFS CLAIMED: The Plaintiff claims the following reliefs: (i) The Defendant be restrained by issuing a permanent injunction restraining the defendant from interfering into the right of the plaintiff by preventing the plaintiff in any way from taking and using the said portion of the said water. (ii) Payment of Rs..................... as damages for the wrongful act of the defendant already done and damage caused 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.15/-) Download PDF Document In Hindi. (Rs.15/-)

  • SUIT AGAINST A COMMON CARRIER FOR DAMAGES DUE TO DELAY CAUSED IN DELIVERY OF THE GOODS SENT THROUGH HIM

    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.15/-) Download PDF Document In Hindi. (Rs.15/-)

  • SUIT FOR CANCELLATION OF A GIFT DEED OBTAINED BY UNDUE INFLUENCE

    SUIT FOR CANCELLATION OF A GIFT DEED OBTAINED BY UNDUE INFLUENCE 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 prosecuted in Cr. Cases S. T. No..................... of.................... 19.................................. versus ................. under Section 395 of the Indian Penal Code and had been bailed out by the Defendant.................... his counsel in that case. 2. That the defendant had won the complete faith of the plaintiff as to his honesty and sincerity, and accordingly the defendant induced the plaintiff to make a gift deed in his favour of his house No............... situated in Mohalla .................... in.................... city under the make belief that the defendant would himself get the gift deed cancelled when the defendant fulfils his obligation of furnishing a security for the construction loan for his new house at.................... The defendant has now completed all his constructions of the said house, but despite requests he is not prepared to get the gift deed cancelled. 3. That the assent to gift away his house was obtained by the defendant from the plaintiff under the undue influence being the counsel of the plaintiff. The gift deed executed by the plaintiff in favour of the defendant is void and liable to be cancelled as such. 4. That the plaintiff apprehends that the defendant might sell the house to somebody else and make easy money of that and create further troubles to the plaintiff. 5. That the plaintiff had given a registered notice to the defendant to surrender the gift deed and get it cancelled himself, but he has refused to do so vide his reply received by the plaintiff on.................... 19.................... 6. That the cause of action arose on.................... 19.................... when the plaintiff received reply of refusal of the defendant, within the jurisdiction of this Court. 7. That the market price of the house is Rs..................... and as such the suit is valued at Rs..................... and court-fee is paid thereon. RELIEF CLAIMED: The relief claimed by this suit is to cancel the gift deed executed by the plaintiff on.................... 19.................... in favour of the defendant its registration Number being No..................... and costs of the suit 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.20/-) Download PDF Document In Hindi. (Rs.20/-)

  • SUIT FOR ACCOUNT AGAINST CO-SHARERS

    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.15/-) Download PDF Document In Hindi. (Rs.15/-)

  • SUIT FOR ACCOUNT AGAINST AN EX-GUARDIAN

    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.15/-) Download PDF Document In Hindi. (Rs.15/-)

  • SUIT FOR FORECLOSURE OF SALE

    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.15/-) Download PDF Document In Hindi. (Rs.15/-)

  • SUIT FOR ADMINISTRATION BY SPECIFIC LEGATEE

    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.15/-) Download PDF Document In Hindi. (Rs.15/-)

  • SUIT FOR CANCELLATION OF A SALE-DEED OBTAINED BY FRAUD WITHOUT PLAINTIFF’S CONSENT

    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.20/-) Download PDF Document In Hindi. (Rs.20/-)

  • SUIT FOR ENFORCEMENT OF A CHARGE

    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.15/-) Download PDF Document In Hindi. (Rs.15/-) )

  • SUIT FOR DAMAGES ON AN INDEMNITY BOND

    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.15/-) Download PDF Document In Hindi. (Rs.15/-)

  • SUIT BASED ON A FOREIGN JUDGMENT

    SUIT BASED ON A FOREIGN JUDGMENT 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. On the.................... day of.................... 19.................... at..................... the State (or Kingdom) of.................... the.................... Court of that State (or Kingdom), in a suit therein pending between the plaintiff and the defendant duly adjudged that that the defendant should pay to the plaintiff.................... rupees with interest from the said date. 2. The defendant has not paid the money. 3. The cause of action arose on.................... 19.................... when the defendant refused to pay the money, and this Court has jurisdiction to try the suit. 5. The valuation of the suit for the purpose of jurisdiction and payment of court fee is.................... rupees and court fee is paid thereon. RELIEF CLAIMED: The relief claimed by way of this suit is that the suit be decreed for Rs..................... with interest at the rate.................... % per annum upto the date of the suit. 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.15/-) Download PDF Document In Hindi. (Rs.15/-)

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