SUIT FOR DAMAGE CAUSED BY CONSPIRACY OF THE DEFENDANTS TO DEFRAUD THE DECREE-HOLDER
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 applied for the execution of the Decree No………………… on……………….. 19……………….. against the defendant No. 1,……………….. and order of attachment of the crop, and cattle of the said defendant was obtained on ……………….. 19……………….. But before this date of order, the defendant No. 1 conspired with defendants Nos. 2 and 3 namely,……………….. and.. !…………….. and through fake transactions of sale and purchase, the defendant No. 2 purchased the grain spread in the harvest of the defendant No. 1 and the defendant No. 2 purchased the cattle of the defendant No. 1, i. e., his buffalow, cow and bullocks and fetched them to their respective houses.
2. That when the Amin went to the defendant No. 1 to attach the goods aforesaid, he did not find them with the defendant No. 1 but with the defendant Nos. 2 and 3 and thus finding himself unable to attach the said crop and cattle, he returned without attaching anything.
The defendant No. 1 has no agricultural fields of his own but he takes rent from other bhumidhars of some plots every year, and accordingly the decree now cannot be satisfied from defendant No. 1 alone.
3. That due to the aforesaid conspiracy of the defendants, the plaintiff suffered the following loss:
Expenses incurred in court for attachment……………….. Rs…………………
The amount of the decree under execution……………….. Rs…………………
4. That cause of action arose on when the defendant sold the goods sought to be attached, in conspiracy with the defendants Nos. 2 and 3, and this Court has jurisdiction to decide the matter.
5. The suit is valued at Rs………………… the expenses incurred in Court and the decretal amount aforesaid, and Court-fee is paid according to the relief claimed:
RELIEF CLAIMED:
The plaintiff claims payment of Rs………………… the decretal amount and expenses made on attachment proceedings, lost by the plaintiff due to the conspiracy of the defendants, and interest from date of 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