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Criminal complaint u/s 138 of the Negotiable Instruments act & section 420 of the Indian penal code IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS, (COURT NO. 2), MUMBAI AT MUMBAI Criminal Complaint No. /2010.. Shri .... S .... T .... D ...., ) age 35 years, occupation - business, )         Complainant resident of 1111 Goregaon, ) MUMBAI 400 011. )Versus Shri .. I .. S .. D ) age 30 years, occupation - business, )        Accused resident of 1050 Goregaon, ) MUMBAI 411 01l. ) A COMPLAINT U/S    138 OF THE NEGOTIABLE INSTRUMENTS ACT & SECTION 420   OF THE INDIAN PENAL CODE The complainant abovenamed submits this complaint, praying to state as follows: 1. That the complainant is a resident of the within mentioned address, and he has been running his business of hardware in the name and style as M/s STD Sales Corporation, MUMBAI. 2. That the accused had been a customer of the complainant for the last ten years purchasing goods from time to time. 3. That since there has been business relationship between the complainant and the accused and also that the complainant could repose faith in the accused, he used to accept the cheques issued by the   accused against the purchased by the accused. 4. That during the recent past, there have been various transactions between the complainant and the accused as detailed below: 5. That the complainant submits and says that the above mentioned cheques were issued by the accused at the time of delivery of goods and materials supplied to him by the complainant, with an implied promise on the part of the accused that on the presentment of these cheques, they will be honoured. 6. That, however, all these cheques, have been dishonoured by the bankers of the complainant, and the same have been returned to the complainant with endorsement "Insufficiency of Funds in the Account of the Drawer". 7. That the complainant says that had the complainant known that the cheques issued by the accused would be dishonoured, the complainant would never have delivered the materials and goods to the accused. 8. That the complainant does hereby reiterate that the cheques which were issued by the accused in discharge of his liability have been dishonoured for the reason of insufficiency of funds in his account. 9. That the complainant    is also surprised that since the date of dishonour of cheques, he has been making serious and sincere efforts to contact the accused personally, but unfortunately the accused has been at large and not being available, and his whereabouts are also not known to the complainant. 10. That taking into consideration such a typical position created by the accused, the complainant has come to a tacit conclusion and also inferred that the accused took the delivery of goods by deceiving and cheating the complainant when he issued the cheques knowing it fully well that he had neither sufficient balance in his bank account, nor had he made any alternative arrangements for crediting the necessary amount against the same. 11. That from the total behaviour on the part of the accused,  it is apparent that he is not only liable civilly but also guilty of the criminal offences under the provisions of criminal laws particularly under section 420 of the Indian Penal Code 1860 and under section 138 of the Negotiable Instruments Act 1881. 12. That the cheques were presented to the bankers of the complainant on…. the same were returned to the complainant on......for....insufficiency of funds in his account. 13. That the complainant has accordingly served a notice, dated…….on the accused, demanding payment of the said amount of Rs. 80,000/-, but the accused did not do so, and hence, this complaint. 14. That the cause of action for this complaint first arose on….. and hence, this complaint filed today is well within limitation. 15. That the offence has been committed within the local limits of the jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to try and decide this complaint. 16. That the necessary court-fee is paid herewith. 17. That the complainant, therefore, prays that - (A)The accused be charged with and tried for the offence punishable u/s 138 of the Negotiable Instruments Act and also u/s 420 of the Indian Penal Code and punished according to law; (B)This  complainant be awarded from the accused the  said amount of Rs. 80,000/- along with interest @ 18% p.a. from the date of the issue of the said cheques till the date of payment; and (C) Any other orders in the interest of justice be kindly passed.MUMBAI, Sd/- STD COMPLAINANT Dated:…………….. Sd/- xX x ADVOCATE FOR COMPLAINANT  VERIFICATION I, Shri STD, the present complainant, do hereby state on solemn affirmation that the contents of this complaint in paras 1 to 17 are true and correct to the best of my knowledge and belief, and so I have signed hereunder. Sd/- DMK COMPLAINANT Download Word Document In English. (Rs.30/-)

PETITION U/S 320 CR. P. C. Session Judge IN THE COURT OF............................ /MM............................ In re: AB & other............................... Complainant/applicant versus  CD & other...................................................... Accused FIR No. U/S............................ Application u/s 320 Cr. P. C.  Most respectfully showeth: - 1. That accused is facing trial before this Hon’ble court under Section 379 for having stolen the scooter belonging to AB............................. 2. That case was initiated on FIR of the said — AB (S/o, R/o). 3. That on intervention of Local guardian/Sarpanch/elders the accused who is persuing secondary school have been pardoned by the complainant and he is prepared to compromise the case with the accused. 4. That the compromise would not only save the career of the accused but also would promote good relationship with the complainant who is also a resident of the locality of the accused. 5. That the application is being moved jointly by AB, the owner of Scooter, and the accused. Affidavit of compromise between accused & AB is enclosed). 6. That it is a fit case where this Hon’ble Court may please be graciously grant permission to compromise u/s 320 Cr. P. C. or to compound the case. PRAYER It is requested that compromise be recorded on record and accused be acquitted in the interest of social justice. Complainant Date:  Through : Counsel Place Download Word Document In English. (Rs.15/-) Download PDF Document In Hindi. (Rs.15/-)

Bail Petition In the Court of the Sub-Divisional Judicial Magistrate at..................... The State .....................APPLICANT      …………………………versus AB, CD, EF & GH........RESPONDENT                                                                                                                                                                Case under section 188, IPC; section 116, Cr PC; section 29, Police Act; section 151, Cr PC The humble petition of the accused persons named-above MOST RESPECTFULLY SHEWETH: 1. That your petitioners were arrested by ..................... Police under section 151, Cr PC on 5th May 2010 at 3 P.M. and were kept in the lock up in the police station and the bail offered by your petitioners was refused by the police. 2. That your petitioners have been produced before Your Honour this day and they have been charged under section 188, IPC. 3. That the offences mentioned in the paragraph 2 above are all bailable. 4. Under the circumstances, your petitioners pray that they be released on bail pending the disposal of the case. 5. And your petitioners, as in duty bound, shall ever pray. Advocate..................... AB, CD, EF & GH Verification 1. We, AB, CD, EF and GH, sons of MN, by occupation business, residents of....................., do hereby solemnly affirm and say as follows: 2. We are the petitioners above-named and know the facts and circumstances of the case. 3. The statements made in paragraphs 1, 2 and 3 of the foregoing petition are true to our knowledge and belief. 4. We sign this verification on 15th May 2010. Solemnly affirmed by AB, CD, EF.....................AB and GH on 15th May 2010 at the.....................CD Court House at..........................................EF GH Before me Notary/Magistrate Download Word Document In English. (Rs.20/-) Download PDF Document In Hindi. (Rs.20/-)

FORM NO. 7 ORDER OF ATTACHMENT TO COMPEL THE APPEARANCE OF A PERSON ACCUSED ( See  Section 83) To, (name and designation of the person or persons who is or are to execute the warrant). Whereas complaint has been made before me that (name, description and address) has committed (or is suspected to have committed) the offence of ..............punishable under section .................... of the Indian Penal Code, and it has been returned to a warrant of arrest thereupon issued that the said (name) cannot be found; and whereas it has been shown to my satisfaction that the said (name) has absconded (or is concealing himself to avoid the service of the said warrant) and thereupon a Proclamation has been or is being duly issued and published requiring the said .................. to appear to answer the said charge within ............. days ; and whereas the said ................. is possessed of the following property, other than land paying revenue to Government, in the village (or town), of ...................., in the District of ......................, viz, ......................., and an order has been made for the attachment thereof; You are hereby required to attach the said property in the manner specified in clause (a), or clause (c) or both,* of sub-section (2) of Section 83, and to hold the same under attachment pending further order of this Court, and to return this warrant with an endorsement certifying the manner of its execution. Dated, this....................day of................,20...  (Signature) (Seal of the Court)                                                                                                                                                                                                                               * Strike out the one which is not applicable, depending on the nature of the property to be attached. Download Word Document In English. (Rs.15/-) Download PDF Document In Hindi. (Rs.15/-)

Obstructing a Right to Use Water for Irrigation  In the Court of ...................................... KK…………………………………………………… resi…………………………… ...................... Plaintiff  against GM………………………………………..……….. resi……………………………... .................... Defendant KK……………………………………………..., the above-named plaintiff, states as follows:- 1. 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……………..... /………………... , the defendant prevented the plaintiff from taking and using the said portion of the said water as aforesaid, by wrongfully obstructing and diverting the said stream. [i. Facts showing when the cause of action arose and that the Court has jurisdiction. ] ii. The value of the subject-matter of the suit for the purpose of jurisdiction is .....................rupees and for the purpose of court-fees is ..................................rupees, and Relief claimed.] Dated : Plaintiff Through, Advocate  Verification: I, …………………………………………….. do hereby verify that the contents from paras 1 to _____________ are correct and true to the best of my knowledge and personal belief and no part of it is false and nothing material has been concealed therein.  Affirmed at ………………………..this ______.  Plaintiff  Download Word Document In English. (Rs.20/-) Download PDF Document In Marathi. (Rs.20/-)

APPLICATION U/S 356 CR. P. C. To be made after released from Jail IN THE COURT OF SH............................. MM/ASJ. In re: - State.................................................................... versus ............................................................................ FIR U/S PS Notification of Address of convict —  Most respectfully showeth: - 1. That petitioner was sentenced by the Hon’ble Court to undergo RI two years imprisonment with a fine of Rs. 200/- in default of payment of fine to undergo one month simple imprisonment for the offence under Section stated above. 2. That petitioner has come out on bail granted by Hon’ble High Court on 2002 vide criminal appeal No............................. 2002. 3. That petitioner has given original address in the above case H. No. 3656 papad gali New Delhi after the release from the Jail on............................ 2002. 4. That petitioner is now residing at the address given below, photostat Copy of Ration card and election card issued by Local Authorities is enclosed for perusal. Name............................ H. No............................. Village............................. P. S............................. Pin. Code etc............................. PRAYER It is most respectfully prayed that the above address be recorded in the case record and concerned authorities be informed including Hon’ble High Court. It is prayed accordingly. Applicant Date:  Through Counsel Place:  Download Word Document In English. (Rs.15/-)

IN THE COURT OF CIVIL JUDGE  ( Senior Division),  ……….  OR IN THE JUDICATURE OF HIGH COURT ……… Original Jurisdiction Before the heading of the plaint proper space should be left for affixing court-fee stamp. Just below the name of the court, a space should left for the number of the suit. It is as such Suit No. ………….. of ………(Year) Thereafter the names of the parties to the suit with all necessary particulars should be given. For ex.: AB s/o CD aged…………yrs, Resident of.............................................. Plaintiff VersusPQ s/o RS aged ……….Yrs, Resident of ………………………………… Defendant If there are more plaintiff or defendant than the names of all plaintiffs/and defendant should be given in plaint as plaintiff No. 1/defendant No.1 and so on. After the names of the parties the title of the suit should be given for ex.  “Suit for specific performance and damages” Or “Suit for Recovery of money” Or “Suit for damages for malicious prosecution” Or “Petition for Judicial Separation u/s 9 of the Hindu Marriage Act, 1955” Where the plaintiff or defendant is a minor or a person of unsound mind, the fact should be mentioned in the cause-title. At the same time the name and description to the person through whom such person sues or sued should also be given in the cause-title.   The forms given at No. 2 in Appendix A to the First Schedule of C.P.C. would be of special assistance in framing cause-titles in particular cases. For example, if plaintiff or defendant is:  1) Individual person  - AB S/o………Aged….. Res. of…………..  2) Proprietary concern -  AB S/o………Aged….. Res. of…………..proprietor of MIs XYZ and carrying on business at ………….  3) Partnership firm  – M/s XYZ, a partnership firm registered under the Indian partnership Act, 1932 with its principal place of business at ………….  4) A company -  M/s XYZ, Pvt. Ltd.  A company incorporated under the companies Act having its registered office at………….  5) Company in Liquidation  - M/s XYZ Ltd. In liquidation through liquidator Mr. ABC having office at ………….  6) Statutory Corporation  - The Life Insurance Corporation of India established and constituted under the Life Insurance Act, having its registered office at ………….  7) Municipality –  Municipal Corporation of Delhi through its Chairman, Town Hall, Delhi.  8) Minor - AB S/o………Aged….. a minor through his father and natural guardian S/o………Aged…..  Res. of…………..  2. Body of the Plaint: Then follows the body of the suit/plaint. The plaintiff acquaints the court and defendant with the case. The statement of facts is divided into paragraphs numbered consecutively. As far as convenient a paragraph should contain only one allegation. Dates, time and numbers should be expressed in figures as well as in words.  The body of plaint usually begins thus:  ‘The above named plaintiff states as follows:  1. That ………………………. Mogha in ‘The Law of Pleadin in India has divided the body of the plaint into two parts  (1) Substantive portion and  (2) Formal portion.  (1) Substantive portion of the body of plaint is devoted to  (i) statement of all facts constituting thecause of action and  (ii) the facts showing the defendant’s interest and liability. But, as already noted, often it is desirable to start the plaint with certain introductory statements, called ‘matters of inducement’.  (2) Formal portion of the plaint shall state the following essential particulars: (i) Date when the cause of action arose;  (ii) Statement of facts pertaining to jurisdiction;  (iii) Statement as to valuation of the suit for the purpose of jurisdiction and court fees and it should be stated that the necessary court fee has been affixed;  (iv) Statement as to minority or insanity of a party or if he is representing some other body then statement as to plaintiff’s representative character;  (v) When a suit is filed after the expiry the period of limitation a statement showing the ground or grounds on which he has claimed exemption from Limitation Law;  (vi) Every relief sought for by the plaintiff should be accurately worded. Rule 7 says that every plaint shall state specifically the relief which the plaintiff claims either simply or in the alternative, and it shall not be necessary to ask for general or other relief which may always be given as the Court may think just to the same extent as if it had been asked for. And the same rule shall apply to any relief claimed by the defendant in his written statement. The plaintiff can claim more than one relief, in the suit. He can seek reliefs alternatively. A plaintiff is entitled to claim more than one relief in respect of the same cause of action should sue for all of them because he is debarred from bringing a fresh suit in respect to the omitted relieves except when the omission in the first suit was with the permission of the court [ Order 2. Rule 2 (3) of C.P.C.];  (vii) Signature and Verification: The plaint must be signed by the plaintiff through advocate. But if the plaintiff is, by reason of absence or for other good cause, unable to sign the plaint, it must be signed by any person duly authorized by him to sign the same.  The verification is done by the plaintiff himself.  Verification  I…….. (Name), S/o Sri................... (Father’s name), the aforesaid plaintiff/defendant do hereby verify that the contents of paragraphs …… to …. of the above plaint are true and correct within my personal knowledge and that the contents of paras………..to ……. (mention the paras by their number in the pleading) I believed to be true on information received. Signed and verified this at ……….(Place) on this ………….. (Date) day of month/years.  Sd/-  (Plaintiff/Defendant)  Affidavit should also be enclosed with plaint as provided under Order 6 Rule 15 (4) CPC, 1908. All documents on which the plaintiff relies for his claim should be enclosed with a separate List of Documents according to Order 7 Rule 14 (1) CPC, 1908. Download Word Document In English. 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Against a Fraudulent Purchaser and His Transferee with Notice    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 defendant …………………….…GM…………………………………………………., for the purpose of including the plaintiff to sell him certain goods, represented to the plaintiff that [he was solvent, and worth ……………………..... rupees over all his liabilities]. 2. The plaintiff was thereby induced to sell and deliver to GM……………………………….….. […………. boxes of ………], the estimated value of which is ...... rupees. ……………………………….3. The said representations were false, and were then known by……………………..…. GM……………………... to be so [or at the time of making the said representations,……………………….…. GM…………………………… was insolvent, and knew himself to be so]. 4. GM……………………….…………. afterwards transferred the said goods to the defendant…………………….. KM…………………………………... without consideration [or who had notice of the falsity of the representation]. [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. 5. The plaintiff claims- (1) delivery of the said goods, or.......................................... rupees, in case delivery cannot be had; (2) ……………………………..... rupees compensation for the detention thereof. 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/-)

APPLICATION U/S 205 CR. P. C. IN THE COURT OF SHRI............................ MM............................ In re: Sanjay Kumar................................................ Petitioner versus  Reshma Begum and other........................ Respondents FIR No. U/s: 307/354 IPC PS:................................ Date of Hearing......................... Application u/s 205 Cr. P. C. seeking exemption from personal appearance. Most respectfully showeth: - 1. That the above case is pending before this Hon’ble Court and date fixed for........................... . 2. That applicant is a muslim lady and according to Muslim Law she has to be under Purdha. 3. That applicant is represented by Sh. XYZ advocate whose powers of attorney is in the record of this Hon’ble court. 4. That applicant undertakes to appear whenever necessity arise/to present herself before the court whenever personal attendance is necessary. Prayer It is most respectfully prayed that applicant may kindly be exempted from personal appearance in the court and may be allowed to appear through her counsel Sh. XYZ. Applicant Date:  Through Counsel Place:  Download Word Document In English. (Rs.15/-)

Execution of Trusts In the Court of ...................................... kk………………………………..………….. resi…………………………… ...................... Plaintiff  against GM…………………………..…………….. resi………………………………. .................... Defendant KK………………………………………………………………..…..., the above-named plaintiff, states as follows:- 1. He is one of the trustees under an instrument of settlement bearing date on or about the ……...... day of………………..... made upon the marriage of ……..….KM………………... and HH…………..……..., the father and mother of the defendant [or an instrument of transfer of the estate and effects of KM……………... for the benefit of ………. the defendant, and the other creditors of……………………….…. KM………………………….…..].2. KK…………………..……... has taken upon himself the burden of the said trust, and is in possession of [or of the proceeds of] the movable and immovable property transferred by the said instrument. 3. GM…………………………………... claims to be entitled to a beneficial interest under the instrument. [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.] 6. The plaintiff is desirous to account for all the rents and profits of the said immovable property [and the proceeds of the sale of the said, or of the part of the said, immovable property, or movable, or the proceeds of the sale of, or of part of, the said movable property, or the profits accruing to the plaintiff as such trustee in the execution of the said trust]; and he prays that the Court will take the accounts of the said trust, and also that the whole of the said trust estate may be administered in the Court for the benefit of GM………………………..……..., the defendant, and all other persons who may be interested in such administration……………….. ….GM…… ……………………and such other persons so interested as the Court may direct, or that…………………….. GM……………... may show good cause to the contrary. [N.B.-Where the suit is by a beneficiary, the plaint may be modelled mutatis mutandis on the plaint by a legatee.] 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 THANE this ______. Plaintiff  Download Word Document In English. (Rs.20/-) Download PDF Document In Marathi. (Rs.20/-)

Criminal complaint u/s 494 r/w sec. 34 of the Indian penal code IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS, (ANTI-CORRUPTION COURT), MUMBAI AT MUMBAI Criminal Complaint No. Smt. .... D .... A .... S...., ) age 25 years, occupation - service, )        Complainant resident of C/o.Shri DAD, 175 Grant Road, ) MUMBAI 400 029. )Versus 1. Shri .... D .... A .... M ...., ) ■ age 30 years, occupation - business, ) 2. Smt. .... D .... A .... B ...., )        Accusedage 55 years, occupation - household, ) 3. Smt. .... D .... A R , ) age 20 years, occupation - education, ) all residents of 320 Fort, ) MUMBAI 400 004. ) A complaint u/s 494 r/w sec. 34 of the Indian penal code The complainant above-named submits this complaint, praying to state as follows: 1. That the complainant is the legally wedded wife of the accused No. 1, while the accused No. 2 is the mother and the accused No. 3 is the second wife of the accused No. 1. 2. That the complainant was married to the accused No. 1 at MUMBAI on according to the Hindu religion, vaidic rites and ceremonies. 3. That before the marriage, the complainant was known by her maiden  name as Kumari Jaya, and likewise, the accused No. 3, before this second marriage, was also' known by her maiden name as Pata.  4. That after the marriage, the complainant and the accused No.  1 cohabited together for about three years.    However, during the existence of their marriage, this complainant could not beget a child, and hence, on that count, the accused Nos. 1 and 2 were nervous and unnecessarily offended for no fault on the part of this complainant. 5. That this complainant submits that last year, in the month of June, the accused No. 1 told this complainant that she should better go to her parents', at least, for a few days for a medical check-up, and under that pretext, she was sent to stay with her parents. 6. That, thereafter, the complainant No. 1 did not either come to take back for cohabitation, nor allow her to do so, and thus, the accused No. 1 has deserted this complainant. 7. That this complainant learnt from very reliable sources that the accused No. 1 is going to contract marriage on with the accused No. 3 at the remote place near Katraj, and the ceremony was fixed to be carried out in a bungalow of one, Shri XYZ. 8. That  accordingly,   this  complainant  lodged  a  report  with  the Sahakarnagar Police Station, requesting them to help this complainant, and the police did try to do so, but they could not register the offence committed by the accused for the reason that the venue of the marriage was changed. 9. That, however, this complainant could know the changed venue, and she collected all the details with a view to registering the said offence. 10. That this complainant states and submit that the said second marriage between the accused Nos. 1 and 3 was celebrated in the Ganesh Mandir, one km away from Katraj, which took place on ......at 6.00 p.m., and about 100 people were present for the said marriage. 11. hat while celebrating the said marriage between the accused Nos.1 and 3, all the religious ceremonies and rites were performed. 12. That the cause of action for this complaint first arose on……. and hence, this complaint filed today is well within limitation. 13. That the offence has been committed within the local limits of the jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to try and decide this complaint. 14. That the necessary court-fee is paid herewith. 15. That the complainant, therefore, prays that the accused be kindly charged with and tried for the offence punishable u/s 494 R/W Sec.34 of the Indian Penal Code and punished according to law. MUMBAI, Sd/- DAS COMPLAINANTDated : Sd/- x X x  ADVOCATE FOR COMPLAINANT VERIFICATION I, Smt. DAS, the present complainant, do hereby state on solemn affirmation that the contents of this complaint in paras 1 to 15 are true and correct to the best of my knowledge and belief, and so I have signed hereunder. Sd/- DASaaaa COMPLAINANT Download Word Document In English. (Rs.30/-) Download PDF Document In Hindi. (Rs.30/-)

Download Word Document In English. (Rs.35/-) Download PDF Document In Marathi. (Rs.35/-) SUIT FOR COMPENSATION BREACH OF A PROMISE TO DO ANYTHING AT A SPECIFIED TIME ETC Nature of grievance: Suit for compensation for breach of a promise to do anything at a specified time, or upon the happening of a specified contingency:  Where in a Contract, one of the parties fails to perform his part of promise at a specified time; or fails to perform his promise upon the happening of a specified event – A Suit may be filed for the compensation for such breach of promise, within three years from the date, of specified time or date of happening of specified event, under Article 27 of the Indian Limitation Act, 1963. Reliefs prayed: (As may be appropriate and applicable to the facts of one’s case) a)     That the Defendant be ordered and decreed to pay Rs.________, being the compensation, as per the particulars of Claim, annexed to the Plaint (Exhibit “_____”); b)     That the Defendant be further 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)     The Hon’ble Court be pleased to declare that ___________  (declaration, in the absence of which the rights of the Plaintiff is frustrated); 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. e)     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 – f)      That pending the hearing and final disposal of the above suit, the Hon’ble Court, in the dues exercise of 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)     That pending the hearing and final disposal of the above suit, the Hon’ble Court, in the dues exercise of powers u/s 94 and O.38 of CPC, 1908, Direct the defendant to furnish security to produce any property belonging to him and to place the same at the disposal of the Court or order the attachment of any property; (as may be applicable to the facts of the case) h)     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 perform any other ministerial act. i)       Interim/ad-interim reliefs in terms of prayer clauses ______ as aforesaid. j)       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 a contract was entered into between the Plaintiffs and the Defendant: 2.      The facts that, by virtue of said contract, the Defendant was obliged to discharge certain obligations under the said contract, at a specified time: or The facts that, by virtue of said contract, the Defendant was obliged to discharge certain obligations under the said contract, upon the happening of a specified event: 3.      The facts showing that the said time to discharge the obligations have arrived, or that the contingency, under which the obligations under the contract were to be discharged, has occasioned: 4.      The facts that the Defendant has failed to discharge his obligations at the said specified time; or failed to discharge his obligations upon the happening of the said contingency: 5.      The facts showing that due to aforesaid failures, the Plaintiffs have suffered pecuniary and / or other losses: 6.      The facts showing that the Plaintiffs took all possible steps to mitigate / minimize the losses which has occasioned due to the aforesaid failures: [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. 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 – 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 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 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 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 of 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. 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 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 Facts and circumstances showing that the Defendants have admittedly committed default; 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 in view of the facts that all the properties of the Defendants are already mortgaged / encumbered, there are no 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. or 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 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. Any other factual averments, having regard to the nature of Reliefs claimed.