Free Legal Drafts

  No. 22 FRAUDULENTLY PROCURING CREDIT TO BE GIVEN TO ANOTHER PERSON (Title) A.B., the above named plaintiff, states as follows:-- 1. On the ...... day of .....19......, the defendant represented to the plaintiff the E.F., was solvent and in good credit, and worth..... rupees over all his liabilities [or that E.F, then held a responsible situation and was in good circumstances, and might safely be trusted with goods on credit.] 2. The Plaintiff was thereby induced to sell to E.F [rice] of the value of ...... rupees [on ...... months credit.] 3. The said representations were false and where then known by the defendant to be so, and were made by him with intent to deceive and defraud the plaintiff [or to deceive and injure the plaintiff.] 4. E.F [did not pay for the said goods at the expiration of the credit aforesaid, or] has not paid for the said rice, and the plaintiff has wholly lost the same. [As in paras 4 and 5 of Form No. 1, and relief claimed.]

  No. 5 GOODS MADE AT DEFENDANT'S REQUEST, AND NOT ACCEPTED (Title) A.B., the above named plaintiff, states as follows:-- 1. On the ....... day of ........20 ......, E.F., agreed with the plaintiff that the plaintiff should make for him [six tables and fifty chairs] and that E.F. should pay for the goods on delivery..... rupees. 2. The plaintiff made the goods, and on the ....... day of....... 20......, offered to deliver them to E.F., and has ever since been ready and willing so to do. 3. E.F. has not accepted the goods or paid for them. [As in paras 4 and 5 of Form No. 1, and relief claimed.]

  No. 4 GOODS SOLD AT A REASONABLE PRICE AND DELIVERED (Title) A.B., the above named plaintiff, states as follows:-- 1. On the ...... day of....... 20......, plaintiff sold and delivered to the defendant [sundry articles of house furniture], but no express agreement was made as to the price. 2. The goods were reasonably worth ..... rupees. 3. The defendant has not paid the money. [As in paras 4 and 5 of Form No. 1, and relief claimed.]

  No. 36 INJUNCTION RESTRAINING NUISANCE (Title) A.B., the above named plaintiff, states as follows:-- 1. Plaintiff is, and at all the times hereinafter mentioned was, the absolute owner of [the house No....., Street, Calcutta]. 2. The defendant is, and at all the said times was, the absolute owner of [a plot of ground in the same street.....]. 3. On the ....... day of .....19...., the defendant erected upon his said plot a slaughter house, and still maintains the same; and from that day until the present time has continually caused cattle to be brought and killed there [and has caused the blood and offal to be thrown into the street opposite the said house of the plaintiff]. 4. In consequence the plaintiff has been compelled to abandon the said house, and has been unable to rent the same.] [As in paras 5 and 6 of Form No. 1.] 7. The plaintiff claims that the defendant be retrained by injunction from committing or permitting any further nuisance.

No. 29 INJURIES CAUSED BY NEGLIGENCE ON A RAILROAD (Title) A.B., the above named plaintiff, states as follows:-- 1. On the ...... day of ...... 19....., the defendants were common carriers of passengers by railway between...... and ...... 2. On that day the plaintiff was a passenger in one of the carriages of the defendants on the said railway. 3. While he was such passenger, at .... [or near the station of. or between the stations of and ..], a collision occurred on the said railway caused by the negligence and unskillfulness of the defendants servants, whereby the plaintiff was much injured [having his leg broken, his head cut, etc., and state the special damage, if any, as], and incurred expenses for medical attendance and is permanently disabled from carrying on his former business as [a salesman]. [As in paras 4 and 5 of Form No. 1, and relief claimed.] [Or thus:--2. On that day the defendants by their servants so negligently and unskillfully drove and managed an engine and ...

  No. 30 INJURIES CAUSED BY NEGLIGENT DRIVING (Title) A.B., the above named plaintiff, states as follows:-- 1. The plaintiff a shoemaker, carrying on business at...... The defendant is a merchant of ........ 2. On the ........ day of ......... 20........, the plaintiff was walking southward along Chowringhee, in the city of Calcutta, at about 3 o'clock in the afternoon.  He was obliged to cross Middleton Street, which is a street running into Chowringhee at right angles.  While he was crossing this street, and just before he could reach the foot pavement on the further side thereof, a carriage of the defendant's drawn by two horses under the charge and control of the defendant's servants, was negligently, suddenly and without any warning turned at a rapid  and dangerous pace of Middleton Street into Chowringhee.  The pole of the carriage struck the plaintiff and knocked him down, and he was much trampled by the horses. 3. By the blow and fall and trampling...

  INTERIM WRITTEN STATEMENT ON BEHALF OF DEFENDANTS IN THE COURT OF......................................... Suit No.................................. /200 In the matter of AB.................................................................... Plaintiff versus CD.............................................................. Defendants INTERIM WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT Most Respectfully Showeth: - 1. The defendant does not admit any of the contentions, averments, allegations or insinuations of the plaintiff as embodied in the plaint for mandatory injunction dated................................. and denies the same as being false and misconceived. 2. That there is a purely legal objection, of preliminaary nature, to the maintainability/institution of the plaint itself which goes to the root of the matter and warrants dismissal of the suit on that short ground alone. 3. Therefore the defendant seeks kind indulgence of this Hon’ble Court to file the present interim ...

  No. 40 INTERPLEADER (Title) A.B., the above named plaintiff, states as follows:-- 1. Before the date of the claims hereinafter mentioned G.H deposited with the plaintiff [describe the property] for [safe keeping]. 2. The defendant C.D. claims the same [under an alleged assignment thereof to him from G.H.] 3. The defendant E.F. also claims the same [under an order of G.H. transferring the same to him]. 4. The plaintiff is ignorant of the respective rights of the defendants. 5. He has no claim upon the said property other than for charges and costs, and is ready and willing to deliver it to such persons as the court shall direct. 6. The suit is not brought by collusion with either of the defendants. [As in paras 4 and 5 of Form No. 1.] 7. The plaintiff claims— (1) that the defendants be restrained, by injunction, from taking any proceedings against the      plaintiff in relation thereto; (2) that they be required to interplead together concerning their ...

  Jurisdiction under Art.,32 of the Constitution In the Supreme Court of  India, New Delhi (In exercise of jurisdiction under Art.,32 of the Constitution) Mr. ………………………………, s/o. ………………………… village ……………….., district …………………….., at present detained at……………………. District Jail at………. ……………. Petitioner Versus (1) The State of  ………                                                               } (2) The District Magistrate,  ……….. and                                    } Respondents. (3) The Superintendent, District Jail, ………                               }          Hon'ble Shri ………………….……., Chief Ju...

List of Documents held in Suit (Interim of an Application) In the Court of………………… Suit No……………… of 20….. A…………………………. …Petitioner Versus B………………………… …Defendants List of papers filed by Sri ……….…………….. Advocate on behalf of the plaintiff to day i.e. ………20…….. 1. Photostat copy of the allotment order dated ..……… 20…… No.1119 in favour of the plaintiff. 2. Photostat copy of the Hire Purchase Tenancy Agreement in favour of the plaintiff dated ……… 20…….. 3. Photostat copy of certificate of possession dated …….. 20….. in favour of the plaintiff. 4. Site plan of …………situated in …………….., …………………., ………….. 5. Photostat copy of the police report lodged by Sri ………………. dated……….20……. 6. Photostat copy of the bank receipt dated ………20…… depositing the last in statement of the hire purchase money. 7. Photostat copy of the report/application submitted to the Executive Engineer, Works Divisional was ……………., ……………… dated …………. 20…… by Sri …………… Advocate for the Plaintiff.