SUIT FOR DAMAGES BY SERVANT FOR WRONGFUL DISMISSAL
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 appointed as the Office-in-Charge for their branch office at………………… at a monthly salary of Rs………………… per month, from ……………….. 19……………….. with an agreement in writing that either party may resign or terminate the services as the case may be with the prior three months notice or with offer of three months pay in cash in lieu of the notice.
2. That the defendants have terminated the services of the plaintiff on ……………….. 19……………….. without giving any notice as aforesaid or tender of three month’s salary in advance in lieu of notice. The defendants have also not paid one month’s earned salary for the month of……………….. 19………………..
3. That the plaintiff has suffered damage of Rs………………… /- the one month’s earned pay and Rs………………… three month’s salary for notice period, thus total damage being of Rs…………………. The plaintiff gave registered notice for tendering Rs………………… aforesaid as damages for wrongful termination, on ……………….. 19……………….. which was received by the defendants on……………….. 19………………..
4. That cause of action arose on……………….. 19……………….. when thedefendants terminated wrongfully the services of the plaintiff and secondly on ……………….. 19……………….. when the defendants received the notice of the plaintiff, but did not comply the terms of it.
5. That the suit is valued at Rs………………… the amount of damages and court fee is paid thereon.
RELIEF CLAIMED:
The plaintiff claims payment of Rs………………… as damages from the defendant and interest thereon from the date of filing 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