SUIT FOR DAMAGES ON AN INDEMNITY BOND
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 purchased the Bhumidhari Land of Khata No………….. situate at village……………….. of Tahsil……………….. District……………….. of ……………….. on……………….. 19……………….. from E. F. for Rs………………… through a registered sale deed executed on……………….. 19………………..
2. That while purchasing the land aforesaid, the defendant executed an indemnity bond to the effect that the land aforesaid is free from any encumbrance, and if anything is found due to the land, the defendant would satisfy the damages so caused to the plaintiff.
3. That after purchase of the aforesaid land, the plaintiff was demanded Rs. ……………….. as arrears of electricity consumed for the tubewell, and the amount of Rs………………… on account of a simple mortgage of the same land executed on ……………….. 19……………….. in favour of XY. The plaintiff had to pay the electricity charges aforesaid as land revenue to the Electricity Board, and Rs………………… to XY for the satisfaction of the simple mortgage mentioned above.
4. That cause of action arose on……………….. 19………………… when the plaintiff had to pay the electricity charges, arrears and on……………….. 19 ……………….. when the plaintiff had to pay Rs………………… in satisfaction of the mortgage aforesaid, and this Court has jurisdiction to decide the suit.
5. That the suit is valued at Rs………………… the amount of the electricity charges plus the amount paid in satisfaction of the mortgage aforesaid, and court fee is paid on the said amount.
RELIEF CLAIMED:
The plaintiff claims Rs………………… from the defendant as damages on account of payment of electricity charges and the amount of the said mortgage and interest 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