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Administration by Creditor on Behalf of  Himself and All Other Creditors  In the Court of ...................................... KK………………………………………………….  resi ........................................ Plaintiff  against  GM………………………….……………………  resi ……………………….................. Defendant KK………………………………………….…., the above-named plaintiff, states as follows:- 1. KM………………………….…., 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. KM……………………….……., died on or about the day of. ………..... By his last will, dated the ...... day of ……….....he appointed ………….…….KM………………... his executor [or devised his estate in trust, etc., or died intenstate, as the case may be.] 3. The will was proved by KM…………………………………………... [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 KM……………………………………….…..., and has not paid the plaintiff his debt. [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.] 7. The plaintiff claims that an account may be taken of the movable [and immovable] property of KM…………., deceased, and that the same may be administered under the decree of the Court.  Dated :  Plaintiff  Through, Advocate   Download Word Document In English. (Rs.20/-) Download PDF Document In Marathi. (Rs.20/-)

Deficiency Upon a Re-sale [Goods Sold at Auction] In the Court of ...................................... KK……………………………… resi…………………………………….………… ...................... Plaintiff  against  GM……………………………. Resi……………………………………………….…...................... Defendant KK…………………………………………………….………., the above-named plaintiff, states as follows:- 1. On the ............. day of……………...... /……………..., the plaintiff put up at auction sundry [goods], subject to the condition that all goods not paid for and removed by the purchaser within [ten days] after the sale should be re-sold by auction on his account, of which condition the defendant had notice. 2. The defendant purchased [……………………………………] at the auction at the price of...................... rupees. 3. The plaintiff was ready and willing to deliver the goods to the defendant on the date of the sale and for [……………. days] after. 4. The defendant did not take away the goods purchased by him, nor pay for them within [……… days] after the sale, nor afterwards. 5. On the ...... day of ………...... /……………...., the plaintiff re-sold the [……………….], on account of the defendant, by public auction, for.................................... rupees. 6. The expenses attendant upon such re-sale amounted to ……………………..... rupees. 7. The defendant has not paid the deficiency thus arising, amounting to ………………….........rupees. [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 KALYAN this ______________________. Plaintiff  Download Word Document In English. (Rs.20/-) Download PDF Document In Marathi. (Rs.20/-)

Minor or a person of Unsound Mind in a Civil Suit   Important points to remember- Suit for and against a minor or a person of unsound mind are drafted as per Order XXXII of CPC: Rule 1: Every suit by minor is instituted in his name by a person called "next friend".Rule 3: Where a defendant is a minor, the court shall appoint a proper person to be "guardian" for the suit for the minor. An order to appoint a guardian can be obtained upon application by the plaintiff or by the minor in his name or by the minor on his behalf. Only difference between a regular suit and a suit by/against a minor is that the name of the next friend or guardian is specified along with the name of the parties. In the Court of Civil Judge Class - I at Delhi Suit No. ………… / 20…….A. B. s/o B. C.A minor through his next friend X. Y.,123, A B Road, Delhi                 .........................................  Plaintiff Vs. M. N. s/o O. P.A minor through his guardian  O. P.456, A B Road, Delhi                 .........................................  Respondent Suit for XXX The plaintiff respectfully states as follows : - (1) Plaintiff is a Govt. Servant working in Delhi. and so on......(12) Relief Claimed:  The plaintiff prays that the court be pleased to order the respondent to perform his part of the contract by transferring the said plot to the plaintiff.The plaintiff further prays that the respondent be ordered to pay compensation for mental harrasment, loss of wages, and cost of this litigation. Place: ………………….                                                                            (Signature of the next friend on behalf of minor)Date: …………………..                                                                                       YYYAdvocate for Plaintiff Verification   I, ______, do hereby verify that the contents from paras 1 to 12 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 Indore this 4th Day of September 2014. (Signature of next friend) Plaintiff  through Next Friend -------------------------------------------------------------------------------------------------   Format of a Written Statement   Important points to remember- Written Statement is the response given by the defendant/respondent in a Civil Suit.Format of a Written Statement is governed by Order VI (Pleading) and Order VIII (Written Statement) CPC. Heading/Title/Signature/Verification part is all same as in a Plaint.The content/matter of the WS is written in points that correspond to the points mentioned in the Plaint. Each point in WS should accept or refute the allegations given in the same point of the plaint.A WS may also contains new points, objections to jurisdiction, pre-emptory pleas, dialatory pleas, etc.A WS must also raise any set-off or counter-claim if any. In the Court of Civil Judge at Delhi   Suit No. 1234 / 2009.A. B. s/o B. C.123, M G Road,  Delhi                           .........................................  Plaintiff Vs. M. N. s/o O. P.456, M G Road, Delhi                            .........................................  Respondent Written Statement of the Respondent under Order 8 Rule 1 (or Written Statement on behalf of all the Respondents)The respondent(s) respectfully state(s) as follows : - (1) Para no. 1 of the plaint is admitted and needs no reply.(2) Para no. 2 of the plaint is admitted and needs no reply. (Facts constituting cause of action)(3) Para no. 3 of the plaint is admitted and needs no reply.(4) Para no. 4 of the plaint is admitted and needs no reply.(5)  Para no. 5 of the plaint is denied and not admitted because the contract referred to by the plaintiff in Para no. 3 clearly specifies that the balance amount must be paid by 10/10/2008, failing which the agreement shall terminate and the buyer shall forfeit the initial deposit. However, the plaintiff never made the balance payment....(Jurisdiction/Optional)(10) The market value of the plot is more than 5,00,000/- and so this court has no jurisdiction to try this case.(11) The plot is situated in Dewas, MP and so this court has no jurisdiction to try this case. (12) The respondent therefore prays that the suit be dismissed with costs. Place: ………………….                                                                            (Signature of the respondent)Date: …………………..                                                                                                                                                                                                 Advocate for Respondent Verification   I, ______, do hereby verify that the contents from paras 1 to 12 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 Indore this 4th Day of September 2014. (Signature) Respondent Download Word Document In English. (Rs.40/-) Download PDF Document In Marathi. (Rs.40/)

Download Word Document In English. (Rs.35/-) Download PDF Document In Marathi. (Rs.35/-) SUIT BILL OF EXCHANGE OR PROMISSORY NOTE PAYABLE AT A FIXED TIME AFTER DATE Nature of grievance: Suit on a bill of exchange or promissory-note payable at a fixed time after date:  For the recovery of money based on Bill of exchange or Promissory-note, payable at a fixed time after date – A Suit may be filed for the recovery of money, within three years from the date, when the Bill or Note falls due, under Article 31 of the Indian Limitation Act, 1963. Reliefs prayed: (As may be appropriate and applicable to the facts of one’s case) a)     The Defendants be ordered and decreed to pay Rs.______, as per particulars of Claim, annexed to the Plaint (Exhibit “____”); b)     The Defendants 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 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; (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 – 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, pursuant to money lent, or pursuant to any other transaction, business or otherwise, the Defendants executed / accepted a Bill of exchange / Promissory Note, in favour of the Plaintiffs, to be payable at a fixed time, from the date of the said Bill of Exchange / Promissory Note: 2.      The Defendant No.___ had accepted the said Bill of Exchange: 3.      The fact that Notice of dishonour was waived by the Defendant: 4.      The fact showing that the Defendant has failed and neglected to pay the money, on the due date of the said Bill of Exchange / Promissory Note: 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. [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.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.

Format of an application to set aside a decree passed ex parte  Important points to remember- An ex parte decree is a decree that is passed by the court in absence of any response from the defendant as per Order 9 Rule 6 of CPC.As per Order 9 Rule 13, the defendant may apply before the court that passed the decree to set it aside on the following grounds:  If he satisfies the court that the summons was not duly served he was prevented by any other sufficient cause from attending the hearing. For example, bona fide mistake as to the date or hearing, late arrival of train, etc. are sufficient causes for absence of the defendant. Such an application for setting aside may be made within 30 days from the date of decree as per Section 123 of Limitation Act. In the Court of Civil Judge  Delhi    Suit No. 1234 / 2009A. B. s/o B. C.123, A B Road,  Delhi                           .........................................  Plaintiff Vs. M. N. s/o O. P.456, A B Road, Delhi                            .........................................  Respondent/ApplicantApplication under Order IX Rule 13 of CPC, 1908 The respondent/applicant respectfully states as follows : - (1) The Plaintiff filed the above suit which was decreed ex-parte against the applicant on 10/10/2014 (2) The applicant came of know of this fact on 15/10/2014, when a demand notice was served on him by the plaintiff for the decretal amount. (3) The plaintiff obtained the decree by suppression of material facts.  (4) The summons in the said case was not served at all on the respondent/applicant. (4) The respondent/applicant could not enter appearance in the said case by reason on non-service of the summons. (5) Relief Claimed: The applicant accordingly prays that the decree passed ex parte on 10/10/2014 against the applicant in the aforementioned case be set aside and the aforementioned case be tried in presence of the applicant. Place: ………………….                                                                            (Signature of the applicant)Date: …………………..                                                                                                                                                                                                                 YYY                                                                                                                    Advocate for Respondent/Applicant Verification   I, M. N. s/o O. P. , do hereby verify that the contents from paras 1 to 5 are correct and true to the best of my knowledge and the rest of the contents are based on legal advice, which I believe to be true. Affirmed at Indore this 4th Day of September 2014. (Signature) Respondent/Applicant Suit No. 1234 / 2009A. B. s/o B. C.123, A B Road, Indore, MP                            .........................................  Plaintiff Vs. M. N. s/o O. P.456, A B Road, Indore, MP                            .........................................  Respondent/ApplicantApplication under Order IX Rule 13 of CPC, 1908 The respondent/applicant respectfully states as follows : - (1) The Plaintiff filed the above suit which was decreed ex-parte against the applicant on 10/10/2009. (2) The applicant came of know of this fact on 15/10/2009, when a demand notice was served on him by the plaintiff for the decretal amount. (3) The plaintiff obtained the decree by suppression of material facts.  (4) The summons in the said case was not served at all on the respondent/applicant. (4) The respondent/applicant could not enter appearance in the said case by reason on non-service of the summons. (5) Relief Claimed: The applicant accordingly prays that the decree passed ex parte on 10/10/2009 against the applicant in the aforementioned case be set aside and the aforementioned case be tried in presence of the applicant. Place: ………………….                                                                            (Signature of the applicant)Date: …………………..                                                                                                                                                                                                                 YYY                                                                                                                    Advocate for Respondent/Applicant Verification   I, M. N. s/o O. P. , do hereby verify that the contents from paras 1 to 5 are correct and true to the best of my knowledge and the rest of the contents are based on legal advice, which I believe to be true. Affirmed at Indore this 4th Day of September 2009. (Signature)  Respondent/Applicant Download Word Document In English. (Rs.30/-) Download PDF Document In Marathi. (Rs.30/-)

Revision   FORM OF REVISION   In the High Court of Delhi (Under its revisional jurisdiction) Civil Revision No. ________  Name and particulars of party ……….petition/Defendant……….  Vs.  Name and particulars of party ……….Respondent/plaintiff……….  Revision under sec.115 of the code of civil procedure against the impugned order passed by it District,  Judge of ………….. on date ………….. ………….. in suit No. …………..  The petitioner submits as follows :   1. The respondent had instituted suit bearing No. ………….. in the court of District judge, Delhi. The  courts decreed the said suit of the respondent on………….. and order the petitioner to execute the  decree the respondent.   2. the petition being aggrieved by the said decree and judgment prefers this application an the  following among other ground:   a. That the decree and judgment passed by the learned judge is illegal and inoperative.  b. That the learned judge has erred in law by passing the said decree on the grounds of  c. That the Id. Judge erred in law by not appreciating the petitioner's application for producing material  document.   d. That in doing so, the learned. Judge in the exercise of the jurisdiction has acted with an illegality and  a material irregularity.  e. The said judgment and decree is against justice, equity and good conscience; and hence not   sustainable in this court.   3. In the aforesaid circumstances, the applicant submits that the Hon'ble court be pleased to call for  the records of the trial court and revise its judgment and decree its judgment and decree in the  interest of justice.   Dated: Sd/-  Place: advocate for the petitioner.  If a court tries a suit for which it has no jurisdiction to try having regard to its local limit, or the subject matter   thereof, it is an exercise of a jurisdiction not vested in it by law. Like wise, where a court has jurisdiction to  entertain a suit, or to execute a decree, or to review its judgment, but refuses to do so on the ground that it  has no jurisdiction, it is a case of failure to exercise jurisdiction vested in it by law. Similarly, it is an illegality,  or a material irregularity in the exercise of jurisdiction vested in a court, if it passes a decree on order against  a person without hearing him at all.  Download Word Document In English. (Rs.20/-) Download PDF Document In Marathi. (Rs.20/-)

SUIT FOR INTEREST UPON MONEY DUE Nature of grievance: Suit for money payable for interest upon money due from the defendant to the plaintiff: Where there is default in the payment of interest which is payable upon money / debt – A Suit may be filed for the recovery of interest payable, within 3 years from the date when the interest becomes due and payable, under Article 25 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 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 – d)     Interim/ad-interim reliefs in terms of prayer clauses _______ as aforesaid. e)     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 Defendant is / was indebted to the Plaintiffs for certain sum of amounts, and further that the Defendant is also liable to pay interest during the subsistence of said debt: 2.      The facts that Defendant has not paid the agreed interest, and although principal amount is also due, but the principal sum is not due; or the principal amount is paid but agreed interest is not paid: [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 is 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.30/-) Download PDF Document In Marathi. (Rs.30/-)

Download Word Document In English. (Rs.40/-) Download PDF Document In Marathi. (Rs.40/) SUIT FOR COMPENSATION FOR ACTIONS CONTRARY TO LAW Nature of grievance: Suit for compensation for doing or for omitting to do an act alleged to be in pursuance of any enactment in force for the time being in the territories to which this Act extends:  Where the actions of the administrative / statutory authorities, Govt. is patently contrary to law, a Suit for damages / compensation may be filed against the concerned State Govt / Central Govt. for irregular exercise of powers / acts and omissions of Public authorities / Public officials / Private persons, allegedly in the pretence / pretext / colour of provisions of an enactment, or unlawful / illegal acts and omissions under Article 72 of Limitation Act, 1963, within one year from the date of alleged action which is contrary to law. Reliefs prayed: (As may be appropriate and applicable to the facts of one’s case) a)     That the Defendants be be ordered and decreed to pay Rs.______  being the compensation; b)     That the Defendants be further be ordered and decreed to pay interest on the Suit amount, @12% from the date of filing of Suit, till date of judgment; and further interest @6% from the date of judgment till payment; c)     That the defendants be permanently injuncted / restrained from acting contrary to law; d)     The Hon’ble Court be pleased to declare that ___________  (declaration, in the absence of which the rights of the Plaintiff is frustrated); 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”; 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 – g)     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, to hold a scientific, technical, or expert investigation; or to conduct sale of property which is subject to speedy and natural decay and which is in the custody of the Court pending the determination of the suit; or to perform any other ministerial act. h)     Interim/ad-interim reliefs in terms of prayer clauses ________ as aforesaid. i)       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 nature of illegal action: 2.      The provision of law which has a direct nexus with the controversy at hand: 3.      The purport and import of aforesaid provision of law: 4.      The condition precedent, which the law lays down, for the exercise of powers: 5.      The procedure which is contemplated under the law, before the exercise of powers: 6.      The representation, if any, made before the Defendant concerned Authority; and the substance of the said representation, and the reply received, if any: 7.      Demonstrate that the Defendant concerned Authority has completely misread / misunderstood the express mandate of law / law declared in HC / SC Rulings; or demonstrate that relevant judgments of HC / SC, which were cited, were not considered at all. [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.

Download Word Document In English. (Rs.40/-) Download PDF Document In Marathi. (Rs.40/) 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.

Download Word Document In English. (Rs.50/-) Download PDF Document In Marathi. (Rs.50/-) SUIT FOR PERMANENT INJUNCTION IN THE COURT OF SENIOR CIVIL JUDGE (DISTRICT ___________),                   SUIT NO. ____________ OF 20.. IN THE MATTER OF: Sh. Om Veer Singh S/o. ___________-, R/o. Sainik Nagar, New Delhi VERSUS 1. Dr. U. Basu S/o________,R/o Pragati Vihar Society, Delhi - 92 2. Tapan Kumar, S/o ______R/o Pragati Vihar Society, Delhi – 92 SUIT FOR PERMANENT INJUNCTION MOST RESPECTFULLY SHOWETH:      1. That the plaintiff is the permanent resident of the above mentioned address in property bearing no. ________ Uttam Nagar, New Delhi for the last many year and is living with wife and minor children, as a tenant.      2. That the plaintiff is a tenant in respect of the above said property bearing no_____________Uttam Nagar, New Delhi consisting two rooms, latrine and kitchen in the above said premises of Rent Rs. 150/- (Rs. 150/-) p.m. excluding electricity and water charges under the tenancy of late Sh_________ who died on 17.10.2013 and late Sh. _____ used to collect the rent from the plaintiff but late Sh. _____did not issued any rent receipt to the plaintiff even after several demands made by the plaintiff but he always used to postpone the issue of rent receipt.     3. That the plaintiff spent a huge amount on the construction of these two rooms in the above said premises at the request of Late Sh. _____and Sh. _____assured the plaintiff to adjust the said rent (the plaintiff is having the necessary documents/proofs of material for construction of rooms in the above said property). It is also pertinent to mention here that the plaintiff looked after late Sh. ______ many a times, whenever he fell ill.     4. That at present the plaintiff is having the peaceful possassion of premises no. ____________Uttam Nagar, New Delhi and is having the whole necessary documents/record regarding possession (photocopy of Ration Card, School Card is enclosed herewith) but the above said defendants are internded to disturbe the peaceful physical possession of the plaintiff of the above said premises.     5. That the plaintiff is having the whole necessary household goods which are lying/kept in the above said premises and is living peacefully.     6. That the plaintiff has paid the agreed rent @ Rs. 150/- p.m. to late Sh. ______upto Oct. 2013. It is also pertinent to mention hare that the legal hairs of late Sh. ______are not in the knowledge of the plaintiff and at present also the plaintiff is ready to tender the rent before the legal heirs of late Sh. _________.     7. That on dt. 30.1.2015 the above said defendant came to the above said premises of the plaintiff and threatened the plaintiff to vacate the tenanted premises immediately otherwise the plaintiff would have to face dire consequences, when the plaintiff asked about their identity then they did not disclosethe same, instead started throwing household goods forcibly and illegally and started to quarrel with the plaintiff when the local residents/neighbourers intervened in the matter then the defendents left the spot after threatening for dire consequences and to dispossess the plaintiff forcibly and illegally in the near future with the help of local goondas. The defendants openly stated that the staff of police post Matiala dances at their tune and it is very easy job for them to dispossess any person or to grab the property of any one with the help of the police staff.     8. That immediately on the same date the plaintiff rushed to the police post Matiala to lodge his report against the defendants regarding such incident but duty officer did not lodge the report of the plaintiff. The plaintiff was surprised to see that both the defendants were already present at the Police Post Matiala.     9. That on 10.2.2015, the plaintiff sent a Registered Notice to the defendant no. 1 and copy to Chowki Incharge Police Post Matiala by Regd. A.D. (copy of the same is enclosed herewith) but P.P. Matiala staff has not taken any action against the defendants for reasons best known to them.      10. That on 11.2.2015, the defendants along with two unknown persons/ whom the plaintiff can recognise by face, came to the above said premises bearing no. _______ Uttam Nagar, and knocked at the door at odd hours and threatened the plaintiff to come out of the room. The plaintiff saw their faces from gaps of the door and the plaintiff got nervous, and therefore did not come out of two-room apartment. The said persons threatened the plaintiff to vacate the premises immediately. However, then the neighbourers gathered there and they restrained the defendants from dispossessing the plaintiff from the above said premises forcibly and illegally. When the neighbourers threatened them, they left the spot with a threat to come after one or two days with heavy force to dispossess the plaintiff from the above said premises forcibly and illegally.     11. That on de. 12.2.2015, the plaintiff again went to the police post Matiala to lodge the report against the defendants but no Police Officer of P. Post Matiala is ready to listen against the defendants and they advised the plaintiff to approach to the competent court of law to seek his remedy and to get injunction order against the defendants and the P.S. Matiala.     12. That the plaintiff has no other efficatious remedy except to approach to this Hon'ble court for seeking relief of injunction against the defendants from interfering in the peaceful possession of the premises no. __________Uttam Nagar, New Delhi.     13. That the cause of action arose on different date when the defendants threatened the plaintiff to vacate the premises no. __________Uttam Nagar, New Delhi and threatened the plaintiff of dire consequences and further to dispossess him from the above premises bearing no.__________Uttam Nagar, New Delhi forcibly and illegally. The cause of action lastly arose on dt. 11.2.2015 when the defendants again threatened and tried to dispossess the plaintiff from the premises no. ______ Uttam Nagar, New Delhi forcibly and illegally with the connivance of the Local Police. The cause of action still subsists as the threat of the defendants to dispossess the plaintiff and to create disturbance in the peaceful possession of the premises no._______ Uttam Nagar, New Delhi continues. 14. That the parties to the suit for the purpose (s) of court fee and jurisdiction is Rs. 130/- on which the requisite court fee has affixed.      15. This Hon‟ble Court has jurisdiction to entertain this suit because the part of the cause of action arose at Delhi and the suit property is situated within the territorial jurisdiction of this Hon‟ble Court. PRAYER: It is, therefore most respectfully prayed that this Hon‟ble Court may be pleased to :-  pass the decree for Permanent Injunctin in favor of the plaintiff and against the defendants thereby restraining the defendants, their representatives, employees, agents etc. from dispossessing the plaintiff forcibly and illegally from the tenanted premises bearing no. _______ Uttam Nagar, New Delhi and also from interfering in the peaceful possession of the above said premises. award cost of the suit in favour of the Plaintiff and against the Defendants; pass such other and further order(s) as may be deemed fit and proper on the facts and in the circumstances of this case.                                                                          Plaintiff                                                              Through Advocate (b) (c) Place: Date: VERIFICATION:     Verified at Delhi on this 1st day of January 20… that the contents of paras 1 to .. of the plaint are true to my knowledge derived from the records of the Plaintiff maintained in the ordinary course of its business, those of paras .. to … are true on information received and believed to be true and last para is the humble prayer to this Hon‟ble Court. Plaintiff [NOTE : This plaint has to be supported by an affidavit]

WRITTEN STATEMENT — VIS 145 CR. P. C. IN THE COURT OF............................ SDM/MAGISTRATE............................ Case No............................. 2002 In Re: - AB................................................................. First Party versus mCD............................................................ Second Party Written statement by second party.  Most respectfully showeth: - 1. That the orchard being Plot No............................. in question under the proceeding is exclusively in possession and in charge of second party since last ............................ years and the orchard in question had never been in possession of first party. 2. That the continued possession of the orchard in question can never be disturbed by first party and cannot be challenged in the proceeding adopted by First party in an illegal method is a misleading in nature. 3. That First party instead of taking proper recourse to civil court if any can not resort to section 145 Cr. P. C. for possession. 4. That present case is not covered by proviso to Section 145(4) Cr. P. C. for the rightful owner is second party. PRAYER It is most respectfully prayed that the application of First Party under Section 145 Cr. P. C. being misconceived in Law and contrary to actual fact of possession be dismissed and peaceful possession of orchard by second party be maintained. Second party Date: Through Counsel Place:  Download Word Document In English. (Rs.15/-) Download PDF Document In Hindi. (Rs.15/-)