SUIT FOR DAMAGES AND FOR WAGES BY A SERVANT
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 was employed by the defendant as his typist on a monthly salary of Rs…………………. on……………….. 19………………… for his office at…………………
2. That the plaintiff was given appointment letter dated……………….. 19……………….. to the effect abovenamed.
3. That the plaintiff is a young unmarried lady of high caste Brahman family of Punjab, and the defendant belongs to a Scheduled Caste family and is married. He wanted to black mail the plaintiff to keep her as his concubine under the colour of a clerk, and for that he began to disturb her modesty under one make belief or the other, which the plaintiff did not like and flatly objected to his mischiefs.
4. That thereafter on……………….. 19……………….. the defendant accused the plaintiff of stealing his money from his drawer and under that accusation he terminated the services of the plaintiff, without paying her salary for last month, i. e., the month of……………….. 19………………..
5. The defendant also made a false report to the Police, for which the plaintiff was prosecuted, but later on discharged on finding the accusation to be baseless, on ……………….. 19…………………
6. The plaintiff has suffered a damage in her reputation for Rs………………… as she has been degraded in the esteem of the relations and acquaintances of her and the general public.
7. That cause of action arose on……………….. 19……………….. when the plaintiff was wrongfully terminated by the defendant after misbehaving many a time with her disturbing her modesty, and blaming her for committing theft of his money, and secondly when the defendant falsely accused the plaintiff of theft; and this Court has jurisdiction to try the suit.
8. That the suit is valued at Rs…………………. the damages for defamation and malicious prosecution and one month’s salary. Court fee is paid thereon.
RELIEFS CLAIMED:
The plaintiff claims the following reliefs:
(1) payment of Rs………………… from the defendant;
(2) interest on the aforesaid amount from the date of filing the suit till payment of the amount aforesaid.
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