SUIT FOR DAMAGES FOR NOT ACCEPTING GOODS SENT TO 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 Defendant ordered per his order No………………… of Book No. ………………… on……………….. 19……………….. to send the Books detailed in the Schedule hereto annexed, per railway parcel, the R. R. to be sent per V. P. P., to ………………… a Representative of the Plaintiff, who is a publisher of law books.
2. The plaintiff sent the goods aforementioned through Railway, and sent R. R. through V. P. P. for Rs…………………. but the defendant did not honour the V. P. P. and it returned with a postal note thereon "the addressee not met even after repeated visits. Accordingly the V. P. P. returned unserved and the plaintiff had to call back Railway Parcel and had to pay demurrage and return freight, which amounted to Rs…………………
3. That in transit some books also were damaged causing a loss in their depreciation of Rs………………… to the plaintiff. The whole loss to the plaintiff thus amounts to Rs…………………
4. That cause of action arose on……………….. 19……………….. when the goods sent by the plaintiff had to be got returned back, the V. P. P. having been not honoured by the defendant, and this Court has jurisdiction to decide the case.
5. The suit is valued at Rs………………… the total amount of the loss as mentioned above, and court-fee is paid therefor.
RELIEF CLAIMED:
The plaintiff claims payment of Rs………………… as damages from the defendant with interest thereon up to the date of filing the suit and thereafter till payment is made.
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