SUIT FOR ENFORCEMENT OF A CHARGE
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 is the father of defendants……………….. and he transferred his property equally among them by way of an oral family settlement, with a condition that both of them will pay Rs………………… /- each to the plaintiff for his maintenance throughout the remainder of his life.
2. That the defendants for the first six months paid regularly the aforesaid charge, but later on have ceased to pay anything to the plaintiff for the last three months, and have now flatly refused to pay anything to him.
3. That the defendants have been in possession of the settled shares of the properties of the plaintiff allotted to them as mentioned at the foot of the plaint.
4. That cause of action arose on……………….. 19……………….. when the defendants refused to pay the aforesaid charge on the properties transferred to them by way of family settlement aforesaid, and this Court has jurisdiction to decide the suit.
5. That the suit is valued at……………….. rupees, the valuation of the yearly charge on the properties, and……………….. rupees for obtaining possession of the properties from the defendants in the alternative, and court fee is paid according to the nature of the reliefs claimed. RELIEFS CLAIMED:
The plaintiff claims:
(1) payment of Rs………………… /- the amount of the charge on the properties for one year from both the defendants in equal shares of Rs………………… each
in the alternative —
(2) possession of the properties in the hands of the defendants with the charge for three months due, i.e., Rs………………… /-.
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