SUIT FOR DELIVERY OF MOVABLES WRONGFULLY DETAINED OR FOR COMPENSATION THEREFOR
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. On the……………….. day of……………….. 19………………… the Plaintiff owned (or state facts showing a right to the possession) the goods mentioned in the Schedule hereto annexed (or describe the goods), the estimated value of which is ……………….. rupees.
2. From that day until the commencement of this suit the defendant has detained the same from the plaintiff.
3. Before the commencement of the suit, to wit, on the……………….. day ……………….. 19………………… the plaintiff demanded the same from the defendant, but he refused to deliver them.
The cause of action arose with the jurisdiction of this Court on……………….. 19……………….. when the defendant detained wrongfully the movable of the plaintiff, which are detailed in the Schedule annexed hereto.
5. The valuation of the suit is Rs…………………. the approximate price of the goods detained. and court-fee is paid thereon.
RELIEF CLAIMED:
The plaintiff claims Rs………………… to be paid by the defendant as damages for the detention of goods aforesaid, or the delivery of the said goods.
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