SUIT FOR FORECLOSURE OF SALE
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. The plaintiff is the mortgagee of lands belonging to the defendant.
2. The following are the particulars of the mortgage: —
(a) (date;
(b) (names of mortgagor and mortgagee);
(c) (sum secured);
(d) (rate of interest);
(e) (property subject to mortgage);
(f) (amount now due);
(g) (if the plaintiffs title is derivative, state shortly the transfers or devolution under which he claims).
(if the plaintiff is mortgagee in possession, add).
3. The plaintiff took possession of the mortgaged property on the ……………….. day of……………….. and is ready to account as mortgagee in possession from that time.
4. Cause of action arose on……………….. 19……………….. when the defendant failed to restore the money of mortgage with interest at the notice of the plaintiff received by the defendant on……………….. 19………………..
5. The suit is valued at Rs………………… which is the market value of the property and court fee is paid accordingly to the nature of the reliefs claimed.
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