Specimen Plaint -- Recovery of Money
[Illustrative -- complete template for a money recovery suit]
IN THE COURT OF THE CIVIL JUDGE (SENIOR DIVISION), [CITY]
CIVIL SUIT NO. _____ OF 20XX
[Plaintiff Name], aged [Age], S/o [Father's Name], residing at [Address] ..... PLAINTIFF
VERSUS
[Defendant Name], aged [Age], S/o [Father's Name], residing at [Address] ..... DEFENDANT
SUIT FOR RECOVERY OF RS. [AMOUNT] WITH INTEREST AND COSTS
VALUE FOR COURT FEE: Rs. [Amount] | VALUE FOR JURISDICTION: Rs. [Amount]
The Plaintiff most respectfully submits as under:
1. The Plaintiff is a [businessman/professional] residing at [Address] and is well-known in the community.
2. The Defendant is [description] residing at [Address] and carries on business at [Address].
3. The Defendant approached the Plaintiff on [Date] requesting a loan of Rs. [Amount] for [purpose]. The Plaintiff, out of goodwill, advanced Rs. [Amount] to the Defendant on [Date] by [cheque No./NEFT Ref. No.]. The Defendant executed a promissory note/loan agreement dated [Date] (Exhibit P-1) agreeing to repay the amount with interest at [X]% per annum within [X] months, i.e., by [Due Date].
4. Despite the due date having passed, the Defendant has failed and neglected to repay the said amount or any part thereof.
5. The Plaintiff sent a legal notice dated [Date] (Exhibit P-2) demanding repayment within 15 days. The Defendant failed to respond/responded denying liability (Exhibit P-3).
6. The cause of action arose on [Due Date] when the Defendant failed to repay, and continues. The suit is within limitation (3 years from due date under Article 19/Article 36 Limitation Act).
7. This Court has jurisdiction as: (a) the Defendant resides within this Court's territorial limits (Section 20 CPC), (b) the suit value of Rs. [Amount] is within this Court's pecuniary jurisdiction.
PRAYER: The Plaintiff prays that this Court may be pleased to: (a) pass a decree directing the Defendant to pay Rs. [Amount] with interest at [X]% per annum from [Due Date] till realization, (b) award costs of the suit to the Plaintiff, (c) grant any other relief as this Court may deem fit and proper in the interest of justice.
VERIFICATION: I, [Plaintiff Name], verify that the contents of paragraphs 1-7 are true to my personal knowledge and nothing material has been concealed. Verified at [City] on [Date].
Filed through: [Advocate Name], Enrollment No. [Number] | Date: [Date]
Documents Filed with Plaint
Order 7 Rule 14 requires filing all documents relied upon: (a) Exhibit P-1: Promissory Note/Loan Agreement, (b) Exhibit P-2: Legal Notice, (c) Exhibit P-3: Defendant's Reply (if any), (d) Exhibit P-4: Bank statement showing the transfer, (e) Exhibit P-5: Interest calculation statement.
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