SUIT FOR CANCELLATION OF AN INSTRUMENT
IN THE COURT OF THE………………..
Suit No………………… of 19………………..
C. D………………………………………………………….. Plaintiff
versus
C. F……………………………………………………….. Defendant
The abovenamed plaintiff most respectfully submits as under: —
1. The plaintiff purchased a plot of land measuring……………….. square yards from defendant……………….. on…………… 19……………for constructing a house thereon, through a registered sale deed in his favour.
2. The defendant……………….. has executed another sale deed in favour of the defendant……………….. through another sale deed on……………… 19………………….. of the same plot of land aforementioned of which he had executed the sale deed in favour of the Plaintiff as aforesaid and given possession to the plaintiff.
3. That the plaintiff is still in possession of the land aforesaid.
4. That the sale deed executed in favour of……………….. is void and inoperative, but however the plaintiff has reasonable apprehension that if the sale deed is left outstanding the defendant……………….. may obtain possession of the land per force, and may cause wrongful loss to the plaintiff.
5. The cause of action arose on……………….. when the defendant……………….. executed another sale deed of the same land aforesaid in favour of the defendant ………………… and this Court has jurisdiction to decide the suit.
6. That the valuation of the suit for the purpose of jurisdiction is Rs. ……………….. and for purpose of Court fee is Rs………………… and court fee is paid thereon.
RELIEF CLAIMED:
The plaintiff claims to have the said sale-deed dated……………….. adjudicated void and cancelled.
Plaintiff
Through Advocate
VERIFICATION
I, abovenamed plaintiff, do hereby verify that the contents of paras ……………….. to……………….. of the plaint are true to my personal knowledge and those of paras……………….. and……………….. thereof are based on legal advice which I believe to be true.
Verified on this…………….. day of……………….. 19……………….. at………………..
Plaintiff