SUIT FOR DAMAGE ON AN AGREEMENT OF INDEMNITY
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. On the……………….. day of……………….. 19……………….. the plaintiff and the defendant, being partners in trade under the style of………………………………….. dissolved the partnership, and mutually agreed that the defendant should take and keep all the partnership property, pay all debts of the firm and indemnify the plaintiff against all claims that might be made upon him on account of any indebtedness of the firm.
2. The plaintiff duly performed all the conditions of the agreement on his part.
3. On the……………….. day of……………….. 19………………… (a judgment was recovered against the plaintiff and the defendant by E. F., in the High Court of Judicature at………………… upon a debt due from the Firm to E. F., and on the ……………….. day of……………….. 19……………….. ) the plaintiff paid……………….. rupees (in satisfaction of the same. ).
4. The defendant has not paid the same to the plaintiff.
5. The plaintiff through a registered notice demanded the amount aforesaid which notice was received by the defendant on……………….. 19………………… and a reply dated………………. 19……………… of the defendant refusing his liability was received by the plaintiff on……………….. 19…………………
6. Cause of action arose within the jurisdiction of this Court on……………….. 19……………….. when the defendant refused to pay.
7. The suit is valued at Rs…………………. and court fee is paid thereon.
RELIEF CLAIMED:
The plaintiff claims Rs………………… as damage from the defendant.
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