BEFORE THE LD. SENIOR CIVIL JUDGE……..COURT, AT ……………..

Civil Suit No. .............. OF 2025

1.      NAME, R/O: XXXXXXX

...PLAINTIFF(S)

VERSUS

1.      NAME, R/O: XXXXXXX

2.      NAME, R/O: XXXXXXX

...DEFENDANT(S)

SUIT FOR RECOVERY OF ₹ ………../- (RUPEES ……. LACS …… THOUSAND …….. HUNDRED ONLY)

MOST RESPECTIFULLY SHOWETH :

1. That the plaintiff is residing at the above said address and is involved in the business of ………………...
2. That the Defendant is a limited company involved in the business of ………………...
3. That on 00.00.2025 the Plaintiff had submitted his estimate with the Defendant for their project of ………. 
4. That satisfied with the estimate, the Defendant placed order vide e-mail dated 00.00.2025
5. That pursuant to the same, the plaintiff completed the works as per the requirements of the defendants.
6. That for the abovesaid works the plaintiffs raised an invoice of ₹ ………../- (Rupees ……. Lacs …… Thousand …….. Hundred only) Dated 00.00.2025.
7. That the payment was never made by the Defendant company to the Plaintiff.
8. That the Plaintiffs sent sever reminder mails on 00.00.2025,  00.01.2025, 00.02.2025, 00.03.2025, 00.05.2025, and 00.07.2025.
9. That as of this date, the plaintiff is entitled to the interest on the above said outstanding amount @ 18% .
10. That aggrieved by the aforesaid acts and omissions of the defendant company, the Plaintiff, through his Advocate, sent a legal notice dated 26.05.2016 to the Defendant company through registered post on 31.05.2016, thereby calling upon the defendant company to make the payment of a total sum of ₹ ………../- (Rupees ……. Lacs …… Thousand …….. Hundred only) against the aforesaid work within 15 days from the date of receipt of the aforesaid notice.
11. That the aforesaid notice has been duly served to the Defendant company, but despite service of the legal notice, the defendant company has neither replied to the same nor paid the above said outstanding dues to the Plaintiff.
12. That therefore the Plaintiff is constrained to approach this Hon’ble Court by way of filing the present suit for recovery.
13. That the present suit is filed within the period of limitation as the date on which the cause of action arose is 00.00.2025.
14. That no similar suit between the parties to the under whom they or any of them claim, litigating on the same grounds has been previously instituted or finally decided by the court of competent jurisdiction or limited jurisdiction.
15. That the value of the suit for the purpose of court fee and jurisdiction is fixed at  ₹ ………../- upon which the requisite ad-valorem court fee has been paid.
16. That this Hon’ble Court has the territorial jurisdiction to try, entertain and decide the present suit as both the parties to the suit reside and work for gain in ……..

P R A Y E R :-

It is therefore most respectfully prayed that this Hon’ble Court may :-

1. Pass a decree in favour of plaintiff and against the defendant for a sum of ₹ ………../- (Rupees ……. Lacs …… Thousand …….. Hundred only) along with interest @ 18% p.a. from the date of filing of the present suit till the date of actual realization.; and
2. Award the costs of present proceedings in favour of Plaintiff and against the defendant; and
3. Pass any other order/s which this Hon'ble Court may deems fit and proper in the facts and circumstances of the case in the interest of justice.

Plaintiff

Through

Date

Place

Verification

I ..................................... , the Plaintiff above named. Do hereby solemnly verify that the contents of my above Plaint are true and correct to my knowledge, no part of it is false and nothing material has been concealed therein. 

Verified this ...................... day of ......................................... 20 ...... at ................ Plaintiff.

BEFORE THE LD. SENIOR CIVIL JUDGE……..COURT, AT ……………..

Civil Suit No. .............. OF 2025

IN THE MATTER OF :

................ Plaintiffs)

Versus

............ Defendant(s)

LIST OF DOCUMENTS

Sl No………....Particulars………………………………………….Page No…..

1……………….Estimate dated 00.00.2025………………

2……………..Email dated 00.00.2025……………………..

3. … ………..Agreement dated 00.00.2025………………

4. … ………..Invoice Dated 00.00.2025…………….……..

5……………..Email Dated 00.00.2025…………….……….

5……………..Legal Notice dated 00.00.2025…………….

Plaintiff

Through

Date

Place

BEFORE THE LD. SENIOR CIVIL JUDGE……..COURT, AT ……………..

Civil Suit No. .............. OF 2025

IN THE MATTER OF :

................ Plaintiffs)

Versus

............ Defendant(s)

AFFIDAVIT

Affidavit of Shri ................................. S/o Shri ...................................... aged .....................years, resident of ................................................

I, the above named deponent do hereby solemnly affirm and declare as under :-

1. That I am plaintiff in the above noted case and being well conversant with the facts of the present case am competent to swear this affidavit.
2. That the accompanying suit for recovery has been drafted by my counsel at my instructions, the contents of which have been read over and explained in vernacular language. The contents thereof are true and correct to my knowledge and the same be read and treated as part of this affidavit as the same are not being repeated herein for the sake of brevity. 

Deponent

Verification

I, the above named deponent do herby solemnly verify that the contents of my above affidavit are true and correct to my knowledge, no part of it is false and nothing has been concealed therein.

Verified this .................. day of ................ 20 ....... at ...........................

Deponent