SUIT FOR CLAIM FOR WORK DONE UNDER A CONTRACT BETWEEN THE PARTIES
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 is a building contractor. He was given a contract in writing on………………… 19…………………by the defendant to construct his building according to the building plan sanctioned by the Delhi Municipal Corporation, for
Rs………………… /-(…………………………………) out of which only Rs………………… (one lakh rupees) were paid to the plaintiff as advance money on the aforesaid date and the remaining amount was to be paid on completion of the work.
2. That the plaintiff took two years in completing the construction aforesaid, due to shortage of building material in……………….. and also because time was not the essence of the contract.
3. That when on……………….. 19……………….. through a registered letter the plaintiff demanded the amount due i. e., Rs………………… /-(………………………………….) from the defendant, which letter was received by the defendant on……………….. 19 ………………… the defendant has denied his liability to pay on the make belief that unnecessary delay has been caused in completing the work and as such he has suffered damage of Rs………………… /- (………………………………….) in the business which he proposed to begin and conduct from the proposed house to be built and also on the make belief that the building material used is of a very inferior quality than reasonably expected. This reply has been received by the plaintiff on……………….. 19
4. That cause of action arose on……………….. 19……………….. when the plaintiff demanded the balance amount for work done, and this Court has jurisdiction to decide the matter.
5. That the suit is valued at Rs………………… the balance amount of construction done by the plaintiff, and court-fee is paid there for.
RELIEF CLAIMED:
The plaintiff claims payment of Rs………………… from the defendant with interest from 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