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