Suit For Recovery Format

CIVIL SUIT FORMAT 

BEFORE THE CIVIL JUDGE, XXXXX 

CIVIL SUIT NO XX/XXXX

 

Mr. A                                                                                                              ……………PLAINTIFF

VS.

Mr. B                                                                                                     ………………….DEFENDANT

SUIT FOR RECOVERY OF RS. 90,000/- ALONG WITH 18 % INTEREST PER ANNUM

MOST HUMBLY SHOETH:

1. That the Plaintiff is filing this suit for recovery of Rs. 90,000/- alongiwth 18% interest per annum  against the Defendant.
2. That the plaintiff runs a leading music and singing classes in name and style of M/s Mr. A’s Singing Classes.

3. That the Defendant approached the Plaintiff to train his friend Mr. C  in music and singing.  The Defendant had represented that Mr. C  has a very good voice but is not a trained singer. That the Defendant   requested the Plaintiff   to train him  in classical as well as modern singing.

4. That Defendant  agreed to pay Rs. 1,00,000/- for those classes. The Defendant  had paid only Rs. 10,000/- in advance.  The Defendant promised to pay Rs 90,000/-  after one month.  A contract  to this effect has been duly signed between Plaintiff  and the defendant.  Copy of Agreement is attached herwith and marked as Annexure A.

5. That the Plaintiff gave best of training to Mr. C .  Mr. C’s  training has already been completed and he has also become a renowned singer, but despite the same, Defendant has  not paid remaining Rs. 90,000/-.

6. That Plaintiff has many times sent the Defendant  reminders through e-mail, whats app and despite the same the Defendant has  failed to pay the balance outstanding amount.

7. The Plaintiff was constrained to send legal notice through his counsel through speed post, which has been duly delivered to the plaintiff’s  address, despite the same the said amount has not been paid.  Copy of the speed post and tracking report is attached herewith and marked as Annexure B.

8. That the cause of action arose when the training of  Mr. C was completed. The cause of action further arose when various e-mails were sent for payment. The cause of action further arose when the Plaintiff sent legal notice.

9. That the Defendant resides within jurisdiction of this Court as such this Hon’ble Court has jurisdiction to entertain this suit.

10. That requisite court fee of Rs. xxxxxx   has been paid.

PRAYER

In light of aforesaid facts and circumstances, it is therefore prayed that this Hon’ble Court may be pleased to

1. Grant decree of Rs. 90,000/- alongwith 18% per annum thereon w.e.f xxxxxxx in favour of Plaintiff.
2. Award pendentelite and future interest @18% per annum on the said amount of Rs. 90,000/-
3. Award cost of suit in favour of the plaintiff.
4. Any other order(s)/direction(s) as this Hon’ble Court deem fit and proper.

PLAINTIFF

THROUGH

COUNSEL

 

 

VERIFICATION

Verified on this xxxxxxx that the contents of Para 1 to Para xx are true to my knowledge , those of para  xx to xx are true on information received and believed to be true and last para is humble prayer to this Hon’ble Court.

                                                                                                                        PLAINTIFF

 

Note:

Civil suit should be  accompanied by Memo of Parties and an affidavit