SUIT FOR DAMAGES FOR CONVERTING GOODS ENTRUSTED TO THE DEFENDANT
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 had to go abroad on……………….. 19………………… as such he entrusted his valuable goods to the defendant to be kept in safe custody till his return after two months from………………… The particulars of the goods entrusted are given in the Schedule annexed hereto.
2. That when the plaintiff returned from……………….. on……………….. 19 ………………… he demanded the goods back from the defendant and the defendant handed over the boxes containing the goods. The defendant being fast friend of the plaintiff, the latter did not check the goods while delivered back but. when he opened the boxes in his house, he found that the clothes and other valuables of foreign make were altogether exchanged by similar goods of inferior quality, which have caused a damage of Rs………………… to the plaintiff.
3. That when on……………….. the very day of delivery of the goods the plaintiff complained to the defendant of the exchange and causing damage to the plaintiff, the defendant rebuked the plaintiff and did not abate the exchange and damage caused thereby.
4. That the cause of action arose on……………….. 19………………… when the goods of the plaintiff were delivered as exchanged, causing the aforesaid damage, and this court has jurisdiction to decide the matter.
5. That the suit is valued at Rs…………………. the amount of damage caused by the defendant by the exchange aforesaid and court-fee is paid thereon.
RELIEF CLAIMED:
The plaintiff claims payment of Rs………………… as damages from the defendant and interest thereon 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