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