Legal English Writing Formats
Legal English Writing Formats
FORMAT
Table of Contents
1. SALE DEED ................................................................................................................................................................ 3
2. LEASE DEED ............................................................................................................................................................. 5
3. SIMPLE MORTGAGE............................................................................................................................................... 7
4. GIFT DEED.................................................................................................................................................................. 8
5. WILL .......................................................................................................................................................................... 10
6. AFFIDAVIT FOR CHANGE IN NAME ................................................................................................................. 12
7. GENERAL POWER OF ATTORNEY.................................................................................................................... 13
8. SPECIAL POWER OF ATTORNEY ...................................................................................................................... 15
9. BILLS OF EXCHANGE .......................................................................................................................................... 17
10. PROMISSORY NOTE ........................................................................................................................................... 18
11. ASSIGNMENT OF COPYRIGHT ........................................................................................................................ 19
12. ASSIGNMENT OF PATENT ................................................................................................................................. 20
13. ASSIGNMENT OF TRADEMARK ...................................................................................................................... 21
14. NOTICE UNDER THE NEGOTIABLE INSTRUMENTS ACT ....................................................................... 22
15. COMPLAINT UNDER NI ACT ............................................................................................................................ 24
16. CIVIL PLAINT ....................................................................................................................................................... 26
17. WRITTEN STATEMENT ...................................................................................................................................... 30
By:
Satej
Subham
1. SALE DEED
Between
, residing herein after called the SELLER (which expression shall, unless it is repugnant to
the context or meaning thereof, be deemed to mean and include his heirs, executors, administrators,
representative, and assigns)
And
, residing at____________herein after called the PURCHASER (which expression shall, unless it
is repugnant to the context or meaning thereof, be deemed to mean and include his heirs, executors,
administrators, representatives, and assigns)
WHEREAS the SELLER is the absolute owner and possesses the property bearing no. situated
at____________, more particularly described in 'schedule A' written hereunder and hereafter referred to
as SCHEDULE PROPERTY.
AND WHEREAS the SELLER agreed to sell, convey and transfer the SCHEDULE PROPERTY to the
PURCHASER for a total consideration of Rs.
(Rupees ) only and the PURCHASER herein agreed to same for the aforesaid consideration.
All that piece and parcel of land situated in Survey No. situated in ____________and adjoining
lands allotted by the Development Authority, admeasuring ____ sq.mts. which is
surrounded by Survey No. ____of _______and the entire lands being bounded on the:
East by :
West by :
North by :
South by :
Their signatures on the day month and year first above written.
SELLER
PURCHASER
WITNESSES:
1.
2.
2. LEASE DEED
Between
Sri/Smt aged , S/o, D/o, W/o , occupation , residing at herein after called
the LESSOR (which expression shall, unless it be repugnant to the context or meaning thereof, be deemed to
mean and includehis heirs, executors, administrators, representatives and assigns)
And
Sri/Smt aged , S/o, D/o, W/o , occupation , residing at herein after called
the LESSEE (which expression shall, unless it be repugnant to the context or meaning thereof, be deemed to
mean and includehis heirs, executors, administrators, representatives, and assigns)
WHEREAS the LESSOR has agreed to grant to the Lessee a lease in respect of the said premises for a period
of .............. years, vide Agreement of premises lease dated hereinafter
referred to as "the said agreement" subject to terms and conditions laid down in the saidagreement.
1. THAT in pursuance of the said agreement and in consideration of the rent hereby granted and the Lessee's
covenants hereinafter mentioned, the Lessor hereby demise unto the lessee the demised premises, to hold
the demised premises unto the Lessee (and his heirs, executors, administrators and assigns) for a period
of____years commencing from the____day of_______Month of __, at a monthly rent which it is
due, the first of every month.
2. THAT the LESSOR is the only owner of the property leased and is in absolute possession, occupation,
and enjoyment of the Schedule mentioned property. None else has got right, title, power, and interest to
lease the property hereby leased.
3. THAT the LESSEE has approached the lessor to grant a lease of the property described in the schedule
below for a period mentioned above, and the lessor has agreed to grant the said lease.
4. THAT in consideration of the lessee agreeing to pay a monthly rent and or theadvance as mentioned above,
the lease is agreed to be given by the lessor.
5. THAT the LESSOR acknowledges the receipt of an advance amount ofRs.................. (Rupees_____only)
by cash/cheque/DD.
6. THAT the LESSEE agrees to pay the rent fixed above every month without default on the__day of every
month concerned.
7. THAT the LESSEE shall pay the Electricity and water consumption charges regularly.
8. THAR the LESSEE may/ shall not Sublet/lease any portion of the property.
9. THAT the lease shall terminate at the end of the terms agreed, and the lessor retains the option to renew it.
10. Thus, at the end of the lease period, the property shall be handed over to the lessor in good condition. The
lessor shall forfeit the advance paid if any of the conditions agreed is violated.
LESSOR
11. Thus, the Lessor retains the right to inspect the building during the tenancy of the lease to know the
condition of the building.
LESSEE
12. If the Lessor or Lessee wants to have the premises vacated before the close of thetenancy period, one-
month clear notice shall be given in writing to the other party. On such vacation, the lessor shall refund
the advance paid after deducting any dues to be paid.
SCHEDULE A
All that piece and parcel of land situated in Survey No.______situated in ____________and
adjoining lands allotted by the Development Authority, admeasuring ____ sq.mtrs. which is
surrounded by Survey No. ____of _______and the entire lands being bounded on the:
IN WITNESS WHEREOF, the LESSOR and LESSEE have set their signatures on the day, month, and year
first above written.
WITNESSES:
1. _________________
2. _________________
3. SIMPLE MORTGAGE
THIS DEED OF SIMPLE MORTGAGE made on ______the of _______ Month of ____ year.
BETWEEN Shri _______ s/o _______ age ______ years, Occupation ______, resident of _________, (here
in after called the “Mortgagor”) of the one part AND Shri _____ s/o _____, resident of ________, occupation
________ resident of _____, (hereinafter called the “Mortagagee” of the other part, WITNESSES that I
consideration of Rupees_____ only (Rs. ___________________) paid by Shri______________.
to the said Shri receipt whereof the said mortgagor hereby acknowledges. The said mortgagor
as beneficial owner hereby transfers unto the mortgages by way of simple mortgage, the landed property
bearing RS No. of , more specifically described in the schedule hereto AND IT IS HEREBY AGREED
AND DECLARED that the said sum of Rs.
with interest thereon at the rate of % compounded , shall be repaid within a period of
years from the date of this deed, AND further declared that in the event of failure to repay the aforesaid
sum by the mortgaged to be sold with a view to satisfy the claim and if any amount remains unsatisfied the
mortgagee shall be at a liberty to recover that remaining sum from the mortgagor.
IN WITNESS whereof the said mortgagor and mortgagee have hereto signed at _________ the day and the
year first above mentioned.
SCHEDULE OF THE LANDED PROPERTY
Landed property bearing Rs. _____________ No. Measuring ________ acres situated at ________ and bounded
by the following boundaries:
towards East :
towards West :
towards North :
towards South :
Witnesses
1. _______________
2. ________________
MORTGAGER
MORTGAGEE
4. GIFT DEED
WHEREAS the said donor is the absolute owner in possession of the lands, tenements hereinafter more
specifically described in the schedule hereto.
AND WHEREAS, the said Shri is the donor’s cousin living with the donor since the age of seven years
and the said donor has great love and affection to dispose the said lands and tenements in the manner
hereinafter appearing.
NOW THIS DEED OF GIFT WITNESSES that in pursuance of the said indication and in consideration of
natural love and affection which the said donor has for the donee, the said donor out of his own free will,
without fraud, coercion or undue influence from anybody whatsoever and in full possession of his senses does
hereby give, convey, grant, transfer and conform on the said donee the double storied house measuring 1500
sq.ft. with open site together with all outhouses, garage and all privileges, profits, advantages and all other
amenities whatsoever; TO HAVE AND HOLD the tenements and the lands hereby gifted on to and to these
of the said donee forever and absolutely.
AND THAT THE SAID DONEE shall and may from time to time and at all times peacefully and quietly enter
upon, have, hold, occupy, possess and enjoy the property hereby gifted and receive and take the rents, issues
and profits thereof and every part thereof without any let or hindrance whatsoever from the said donor or by
any person or persons claiming from under or interested of him
IN WITNESS WHEREOF the said donor has hereunto set and subscribe his signature and delivered in the
presence of the day, month and year first above mentioned.
SCHEDULE OF THE LANDED PROPERTY
Landed property bearing Rs. _____________ No. Measuring ________ acres situated at ________ and bounded
by the following boundaries:
towards East :
towards West :
towards North :
towards South :
Witnesses
1. _______________
2. ________________
DONOR
DONEE
5. WILL
Will giving Life Estate to Wife and Property to Children and appointing Guardian of Minor Children
THIS IS THE LAST AND ONLY WILL OF ME, _________aged about _________years, son of_________of
____________and now residing at._____________in the city of __________.
If any of my children should on my demise be minors then I direct that my friend Shri_________if he be alive,
together with one of my major sons assume joint guardianship of the property of the said child or children.
I leave and bequeath all my movable property in my residential house and the said house situated at
__________in the city of __________to my wife, the said ___________subject to the condition that she shall
only have a life interest, with no power to encumber or mortgage the same in any manner whatsoever. On her
death or on her remarriage the said house and all the movable property therein shall revert absolutely to my
daughters then living in equal shares.
To my two sons___________ and _____________,I leave and bequeath all the cash, securities, shares, debts
and moneys whether at the bank or elsewhere in equal shares, my two remaining houses situated at
__________, and ___________, in the city of, ____________ together with all movable properties therein.,
___________ I leave and bequeath, the former to my eldest son and the latter to my younger son.
The residue of my property consisting of,____________and other property not disposed of above which I may
die possessed of or entitled to I direct to be given to the church or temple of, _____________for the purposes
of its annual repairs and such other like uses as may be required from time to time.
In case I die leaving debts then such debts shall be payable from the immovable properties and all expenses
of administration, death duties and deathbed charges shall be borne from the cash or the movable property not
bequeathed to my wife, the aforesaid. . . . .
IN WITNESS whereof I, the said A. B., have hereto signed at, ___________this the _________day
of____________ of _________ year, and I have also signed the addition on page one, line four of this my
Will.
SIGNED by the said testator as his last Will, in the presence of us, present at the same time, who, at his request,
in his presence and in the presence of each other, have subscribed our names as witnesses. The said testator
having before signing the same, caused the words ‘‘. . . . . . . .’’ to be inserted in the fourth line of page one.
SCHEDULE OF THE LANDED PROPERTY
Landed property bearing Rs. _____________ No. Measuring ________ acres situated at ________ and bounded
by the following boundaries:
towards East :
towards West :
towards North :
towards South :
Witnesses
1. ______________________
2. ______________________
6. AFFIDAVIT FOR CHANGE IN NAME
______________________ v. _____________________
Date: _____
U/S: _____IPC
P.S: _____
APPLICATION FOR CORRECTION OF THE NAME OF COMPLAINANT AND THE NAME OF THE
COUNSEL OF THE ACCUSED IN THE _____ ORDER DATED _____.
Sir,
1. That the above noted case is pending before this Hon’ble court and is fixed for _____ for awaiting the
_____.
2. That the applicant/accused moved an application dated _____ for giving the directions to the _____ for
_____ of the complainant namely _____alias _____.
3. That this Hon’ble court was pleased to direct the _____ to _____ the complainant _____ alias _____ but
due to some clerical mistake the name of the complainant has been mentioned as _____ instead of _____ in
the order dated _____. The name of the counsel of the applicant /accused has been wrongly mentioned as
_____ instead of _____, _____.
4. That now the applicant wants to get rectified/corrected the said mistake in the order dated _____.
It is, therefore, prayed that the order for necessary correction in the order dated _____ may kindly be given
the interest of justice.
Dated: _____
KNOW ALL ME BY THIS POWER OF ATTORNEY that I, Shri________ s/o ________age ______ years,
occupation , resident of state that I intend to go abroad and stay therefore a long time and so it is
necessary and expedient for me to appoint an agent to look after all my affairs in my absence.
By these present, I do hereby nominate, constitute and appoint Shri ________ s/o
________age_________years, occupation__________resident of _________as my attorney, in my name and
on my behalf to execute or do all or any of the acts or things hereinunder mentioned –
(1) THAT to appear and act in all the Courts, civil, revenue or criminal, whether original or appellate, in the
registration office or in any other office of Government or District Board, Municipal Board or notified
area or any other local authority.
(2) THAT to sign and verify plaints and written statements, petitions of claims and objections, memorandum
of appeal and applications of all kinds and to file them in any such Court or office.
(5) THAT to file and receive back documents, to deposit and withdraw money, and to grant receipts thereof.
(8) THAT to take delivery of possession of property in execution of my decrees or of property purchased
for me at an auction sale.
(9) THAT to realize debts due to me, to collect rents from my tenants of houses and to receive any money
due to me from any other person and to grant receipts and discharges for the same.
(10) THAT to distrain the crops of my tenants for the arrears of rents.
(11) THAT to grant lease of my house property lands, agricultural and non-agricultural.
(12) THAT to file suits for rent and ejectment of tenants, and when expressly instructed by me, other kinds
of suits.
(13) THAT to apply to Courts and officers for copies of documents and papers.
(14) THAT to apply for further inspection of and to inspect judicial records.
(15) THAT to nominate and to give consent to the appointment of a patwari, mukhia or chaukidar.
(16) THAT to accept service of any summons, notice or writ issued by any Court or officer against me, and
(17) THAT to generally to do all lawful acts necessary for the above-mentioned purposes.
AND I hereby agree that all acts, deeds and things lawfully done by my said attorney shall be construed as
acts, deeds and things done by me and I undertake to ratify and confirm all whatsoever that my said
attorney shall lawfully do or cause to be done for me by virtue of the power hereby given.
Place:
Date: EXECUTANT
“I KNOW THE EXECUTANT”
(Shri ) Advocate
Landed property bearing Rs. _____________ No. Measuring ________ acres situated at ________ and bounded
by the following boundaries:
towards East :
towards West :
towards North :
towards South :
8. SPECIAL POWER OF ATTORNEY
WHEREAS I am owner in possession of properties, amongst others the one detailed below situated in the city
of______________.
AND WHEREAS, owing to business commitments I am unable to attend personally the sale, or the negotiation
of its sale and I am desirous of disposing of the some at an early date.
AND WHEREAS, the said Shri is willing to undertake the negotiation and the sale of the same.
NOW THEREFORE BY THESE PRESENTS, I, the said Shri ________hereby authorize and empower the
said Shri as the lawful attorney for me and on my behalf to do the following acts, deeds and things:
(1) THAT to advertise for sale or otherwise procure and negotiate the sale of my said property described
below situate in the city of at a net price of not below Rupees (Rs.________________) only.
(2) THAT to receive from the purchaser the purchase money and to give proper receipt and discharge for the
same.
(3) THAT in my name and as my act and deed to execute and sign a proper conveyancing of the said property
to the purchaser.
(4) THAT to present the said deed of conveyance for registration to the proper Registration Authority, to
admit the receipt of the consideration money and to have the said deed registered AND to do all acts,
deeds and things which are necessary for conveying the property and registering the said deed as fully
and effectually in all respects as I could do the same if I were present personally.
AND I HEREBY AGREE to ratify and confirm all and whatsoever my said attorney shall lawfully do or
cause to be done by virtue of these presents.
IN WITNESS whereof, I, the said Shri ______hereto put my signature at ___________ this
________th day of________.
Place:
Date:
EXECUTANT
“I KNOW THE EXECUTANT”
(Shri ) Advocate
SCHEDULE OF THE LANDED PROPERTY
Landed property bearing Rs. _____________ No. Measuring ________ acres situated at ________ and bounded
by the following boundaries:
towards East :
towards West :
towards North :
towards South :
Whereas I am the sole and absolute owner and in possession of the scheduled property.
Whereas, I am unable to maintain, manage and look after the affairs of the scheduled property and hereby the
said attorney holder to the following acts, deeds, and perform things on my behalf and in my name with entire
powers thereon.
1. To make payment of taxes, rates, cesses, and assessments, to get plan sanction to anycompetent authority
levied by them from time to time on my behalf.
2. To appoint advocate/s, pleader/s, prosecutor/s, or any other competent authority for allpurpose.
3. To file civil or criminal cases in any competent court/s and complete theproceedings.
4. To apply and obtain relevant documents in respect of the scheduled property on my behalf and to put up
any constructions in the schedule property.
5. To sign all documents, papers, agreements, affidavits, forms, vakalaths, receipts, declarations, etc., and to
derive all kinds of benefits and profits in respect of the scheduledproperty on my behalf.
6. I have not given any power to this attorney holder to alienate property.
9. BILLS OF EXCHANGE
10. PROMISSORY NOTE
PROMISSORY NOTE
(location) (state) (date)
(Borrower) agrees and promises to pay (lender) the sum of rupees for value received, with interest at the
annual rate of % payable after (Date). If this note is in defaultand is placed for collection, (Borrower) shall
pay all reasonable costs of collection and attorneys' fees.
(Borrower) (date)
(Witness)
11. ASSIGNMENT OF COPYRIGHT
1. The Owner warrants that he/she is the sole creator and/or owner of all copyrights in the Work and that
he/she has full power to enter into this Agreement, and that this Agreement does not infringe the rights
of any third party.
2. The Owner hereby assigns and transfers to the Assignee the following copyrights in the Work, without
reservation or exclusion, in consideration of a sum of Rs. (The receipt of which has been
acknowledged).
3. The Owner agrees that the Assignee shall, from here on, own the said copyrights in the Work, benefit,
and dispose of these rights in any way and at his/her sole discretion.
4. The Parties agree that this Agreement shall be binding upon the legal successors andassigns.
5. The Owner agrees to sign all necessary papers to procure the registration of, or as furthernecessary to
effect the assignment under this Agreement, as and where necessary.
6. In consideration of this Assignment of Copyright, the Owner acknowledges receipt of due and sufficient
consideration.
IN WITNESS WHEREOF the Assignor has put his hand the day and year herein above written.
Owner: ___________________
Assignee: ________________
12. ASSIGNMENT OF PATENT
Between
The Assignor:
The Assignee:
Whereas the assignor is the sole owner of the 'invention' (description of the invention), more particularly
described in the schedule hereinunder. The said invention is duly registered under the Patents Act 1970.
Whereas the assignee wishes to acquire the entire rights, title, and interest in the invention and the patent.
1. The assignor warrants that they are the sole creator and/or owner of all patents in the invention and that
they have full power to enter into this Agreement, and that this Agreement does not infringe the rights of
any third party.
2. The assignor warrants that the inventions and patents are free of any liens, security interests, or
encumbrances.
3. The assignor does hereby irrevocably assign to the assignee all rights, title, and interest inand to the patent
and invention.
4. In consideration for the assignment, the assignor has paid the assignee the sum of_______, the receipt of
which has been acknowledged by the assignor
5. The Parties agree that this Agreement shall be binding upon the legal successors and assigns.
IN WITNESS WHEREOF the Assignors have put their hands the day and year first hereinabove written.
(SCHEDULE)
Signed
Assignor__________________
Assignee__________________
WITNESSES:
1.
2.
13. ASSIGNMENT OF TRADEMARK
Between
The Assignor: ___________________________
Whereas the said assignor is the owner and proprietor of a trademark (description).
Now the deed witnesses that
1. The ASSIGNOR is the lawful owner having all the rights, titles, and interests in and to thesaid Trademarks.
Moreover, the ASSIGNOR has full right, absolute power, and lawful authority to sell, assign and convey
the same in the manner herein set forth.
2. The ASSIGNOR has agreed to assign the full rights, titles, and interests to the ASSIGNEEin respect of
the said Trademarks.
3. The assignor does hereby irrevocably assign to the assignee all rights, title, and interest in and to the
trademark.
4. In consideration for the assignment, the assignor has paid the assignee the sum of________, the receipt of
which has been acknowledged by the assignor.
5. The said Assignor hereby covenants with the Assignee that he will not infringe or use a mark identical
with the Trade Mark hereby assigned or use another Trade Mark nearly resembling it as to be likely to
deceive or cause confusion, in the course of trade and in relation to the goods in respect of which it is
registered and, in a manner, as to render the use of this mark likely to be taken either as being a user of
the said Trade Mark or to importa reference to the Assignor.
IN WITNESS WHEREOF the Assignors have put their hands the day and year first hereinabove written.
(SCHEDULE)
Signed
Assignors
Assignee
WITNESSES
1.
2.
14. NOTICE UNDER THE NEGOTIABLE INSTRUMENTS ACT
NOTICE
To,
________________
________________
_________________
Subject: Notice Under section 138 of the Negotiable Instruments Act, 1881, for dishonor of cheque.
Dear _____,
Under instructions and authority from our client_____, we serve upon you this notice of demand under
section (138 for dishonor of cheque) of the NI Act.
1. That your business had purchased goods from my client (describe goods - invoice no, receipt,
etc)
2. On delivery of goods, you issued cheque numbered
3. That when the aforesaid cheque was presented by our client M/s. to your Bankers i.e. the same
was returned unpaid by the Bank with the remarks/reasons 'Insufficient Funds'. This fact was brought
to your notice by our client vide letter dated .
4. To that, you replied with a letter dated asking our client to deposit the cheque again with the
assurance that it will be cleared this time around.
5. My client again presented your above-mentioned cheque with its bankers; this time, again cheque
was returned unpaid by the bank due to insufficient funds.
6. That thereafter in spite of many telephonic reminders and personal visits by the representative of our
client to your office, you failed to make the payment due to our client.
7. That on account of the above facts, you are liable to be prosecuted under section 138 of the Negotiable
Instrument Act, 1881, as amended up to date, under which you are liable to be punished with
imprisonment which may extend to one year or with fine which may extend to twice the amount of
cheque or with both.
8. That we call upon you to repay a sum of the principal amount along with interest % pa
within a period of 2 weeks from this letter failing which we would be compelled to take necessary
actions under the Negotiable Instruments act against you in a competent court of law at your cost.
This is without prejudice to all other legal rights and remedies available to our client for the above-
stated purpose.
Yours Faithfully,
(Name, designation)
15. COMPLAINT UNDER NI ACT
(complainant)
Vs
(Accused)
Complaint Under sections 138 and 142 of the Negotiable Instrument Act,1881
Respectfully shows,
1. That the accused issued one cheque bearing No. dated for a sum of Rs.______drawn
on______for a lawful valuable consideration in the discharge of his liability in favor of the complainant.
2. That the complainant presented the cheque last on which was returned unpaid for 'Insufficient
funds'. The cheque was presented within its validity period and stands dishonored.
3. The complainant issued a notice through his counsel dated to the accused demanding the amount to
be repaid within 15 days. However, it is submitted that the accused deliberately ignored the serving of
the notice.
4. That the accused person has not made the payment of the amount of dishonored cheques to the
complainant within 15 days as required under the law as demanded in the notice.
5. That the accused is guilty of an offense under section 138 of the Negotiable Instrument Act, 1881, and is
liable to be punished under section 142 of the said Act.
It is, therefore, prayed that the accused person be proceeded against and punished in accordance with the law
as envisaged under section 142 of the Negotiable Instrument Act in accordance with the law.
Complainant
Through
Advocates
Place:
Date:
- Dishonored cheque
- Copy of notice
- Envelope + Postal receipt of notice
WITNESSES:
1.
2.
16. CIVIL PLAINT
Property Encroachment
Between
PLAINTIFF
AND
DEFENDANT
Plaint Under Order VII, Rule 1 of The Code of Civil Procedure, 1908
(1) Description of the suit property: The suit property bearing CTS No. and measuring sq.
mts. is situated at ______________.
Towards South _ _ _ _
(2) The suit property described in the above Paragraph No. 1 belongs to the Plaintiff abovenamed who has
purchased the same on and since the date of purchase, the suit property is in the possession and
occupation of the Plaintiff.
(3) The Defendant is the owner of the adjoining property bearing CTS No. and is in the possession of
the same. In between the suit property and the Defendant’s property mentioned here, there is no
compound wall to demarcate the boundaries.
(4) That, the Defendant has started excavation for the purpose of erecting a compound wall. The Defendant
has encroached upon the Plaintiff’s property and has made preparations for putting up the foundation.
Immediately after seeing the defendant making preparations for encroachment, the Plaintiff requested the
Defendant not to encroach upon his property. The Defendant gave deaf ear to the Plaintiff’s request and
continued to encroach upon the Plaintiff’s property.
(5) The Plaintiff approached the City Survey authorities and got measured his property and fixed the
boundary stones between the properties of the Plaintiff and the Defendant. On demarcation it is confirmed
that the Defendant has encroached upon the property of the Plaintiff
(6) The Plaintiff, being aggrieved by the act of encroachment on his property by the Defendant has
constrained to file this suit for permanent injunction against the Defendant.
(7) Cause of Action: The cause of action for the suit arose on , the day on which the Defendant started
encroaching on the Plaintiff’s property by excavation of the land to put up a compound wall.
(8) Jurisdiction: The suit property is situated within the jurisdiction on this Hon’ble Court; the Plaintiff and
the Defendant are residing within the jurisdiction of this Hon’ble Court. Hence this Court has the
jurisdiction to try this suit.
(9) Court-Fee and Suits Valuation: Fixed Court-fee Rupees twenty-five only (Rs. 25/- has been paid under
sub-section (c) of section 26 of the Karnataka Court Fees and Suit Valuation Act. The same is the value
for jurisdiction.
• decree may kindly be passed issuing permanent injunction against the Defendant restraining him
permanently from obstructing the peaceful possession and occupation of the Plaintiff over the suit property;
and
Place:
Date:
PLAINTIFF
I Shri _________ s/o __________, the Plaintiff above named do hereby swear on solemn affirmation that
the contents of the above plaint are all correct to the best of my knowledge derived from the official records
and I believe the same to be true. In token whereof I have signed hereto.
Place:
Date:
PLAINTIFF
17. WRITTEN STATEMENT
Between
PLAINTIFF
AND
DEFENDANT
Herein, the advocate for the Defendant No.1 most respectfully submits his written statement as under:
(1) That the averments made in the plaint are hereby denied by this Defendant in toto, and therefore, the
Plaintiff be put to strict proof of the same.
(2) That, the averments made in the paragraph 2 of the plaint are hereby specifically denied by this Defendant.
The Plaintiff be put to strict proof of the same.
(3) That, the averments made in paragraph of the plaint are also specifically denied by this Defendant.
The Defendant No.1 has not borrowed any loan amount from the Plaintiff Bank, thereby he is not liable
to pay instalments towards the alleged loan.
(4) That, consequent on non-borrowing of loan amount from the Plaintiff, the cause of action does not arise
against Defendant No.1.
(5) The suit against Defendant No.1 is false, frivolous and vaxatious and made to harass the Defendant No.1
at the instance of Defendant No.2 in collusion with the Plaintiff Bank.
(6) That, in the year , Defendant No.1 was subordinate to Defendant No.2 who has used his undue influence
over his subordinates and has created number of documents. Defendant No.1 specially denies his liability
towards Plaintiff. It is Defendant No.2 who has borrowed the loan amount and it is he who is liable to
liquidate the outstanding and not the Defendant No.1.
(7) That, if this Hon’ble Court deems think correct to a decree against the Defendants, it is Defendant No.2
who is severally liable to pay the decretal amount as he is the author of the documents produced in this
case by the Plaintiff.
(8) That, the Plaintiff be put to strict proof of the documents produced by him.
Therefore, it is humbly prayed that this Hon’ble Court be pleased to strike down the liability against Defendant
No.1 and direct Plaintiff to proceed against Defendant No.2, in the interest of justice.
Place:
Date:
I Shri_________ s/o _________, the Defendant above named do hereby swear on solemn affirmation that the
contents of the above written statement are all true and correct to the best of my knowledge and belief. In
token whereof I have signed hereto.
DEFENDANT: