SUIT FOR SPECIAL DAMAGE BY TENANT AGAINST LANDLORD
IN THE COURT OF THE………………..
Suit No………………… of 19………………..
CD………………………………………………………….. Plaintiff
versus
C. F……………………………………………………….. Defendant
The abovenamed plaintiff most respectfully submits as under: —
1. On the………………. day of………………. 19………… the defendant, by a registered instrument, let to the plaintiff (the house No……………….. ) for the term of………………. years, contracting with the plaintiff, that he, the plaintiff, and his legal representatives should quietly enjoy possession thereof for the said term.
2. All conditions were fulfilled and all things happened necessary to entitle the plaintiff to maintain this suit.
3. On the………………. day of………………. 19……………….. during the said term E. F. who was the lawful owner of the said house, lawfully evicted the plaintiff therefrom and still withholds possession thereof from him.
4. The plaintiff was thereby prevented from continuing the business of a tailor at the said place, was compelled to expend………………. rupees in moving and lost……………….
5. The plaintiff has thus suffered a special damage of Rs……………….. due to the wrongful act of the defendant.
6. The plaintiff demanded the amount aforesaid of special damage from the defendant through a registered notice served on the defendant to which defendant replied vide his letter dated……………… 19………………. received by the plaintiff on ………………. 19……………….
7. The cause of action arose within the jurisdiction of this Court on………….. 19……….. when the defendant received the notice of plaintiff, and lastly on…………. 19………. when the defendant refused his liability for any special damage. 8. The suit is valued at Rs……… and court fee is paid thereon.
RELIEF CLAIMED:
The plaintiff claims Rs……………….. as special damages from the defendant with costs of the suit.
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