Suit For Damages Or Compensation

___________

____________ VERSUS M/S ___________ & OTHERS

SUIT FOR DAMAGES/COMPENSATION OF RS. _______/-

APPLICATION UNDER ORDER __ RULE _ READ WITH SECTION ___ OF CPC FOR PERMISSION TO INSTITTUE THIS SUIT AS FORMA PAUPERIS/INDIGENT PERSON AND SUIT FOR RECOVERY OF DAMAGES OF RS. _______/-

RESPECTFULLY SHOWETH:

1- That the applicant /plaintiffs having no means and individual /independent source of income. They are not possessed of sufficient means (other than property exempted from the attachment in execution of the decree and the subject matter of the suit) , to enable them to pay the advalorem court fee payable on the amount of Rs. _______/- on the plaint i.e. Rs. ______________.

2- That on _______ _______ deceased who was assigned fieldwork in M/s ___________, at ___________, ___________ went to ____ for the work of the company on his vehcle no. _____________. The deceased was coming back to ___________ after finishing the work at about _____ when the deceased reached just ahead of __________ there was wind and rain. Suddenly a hoarding board on which __________ was written which was installed above both the sides of the road had broken and fell down upon the deceased and his ___________. Due to which _______ and ___________ were pressed under the hoarding board. Consequently _______ sustained injuries on his head and abdomen. Vehicle of _______ was also damaged. One person of _______ namely _______ was coming behind him, who lifted/supported _______ and admitted him in ______________, ___________, where the _________ dated _______ was prepared by the concerned Doctor. The Doctor conducted the operation of abdomen of _______. The deceased became very serious and was referred _____________, ________ but the condition of the deceased was not improved there hence he was admitted in ____________ on ________. The deceased _______ sustained the said injuries due to the fall of the hoarding board after broken the same. The said accident has been caused due to the negligence of the defendant No.2 (Mr. ___________ Proprietor/GM/M.D. of _________ of the hoarding board) who is the agent /contractor of defendant No.1 by installing the same above middle of the road. On _________ was expired during the treatment at _________, _____--. That upon the statement of Shri ________ FIRNO. ____ dated _________ under section ________ IPC was registered in P.S. __________, ___________. The defendant No.2 had not properly installed the said hoarding board and due to negligence of the defendant NO.2, the said accident had taken place. The post mortem of the deceased was conducted by the Medical Officer of ___________, ___________ vide PMR No. ________ dated ________--. the plaintiffs have spent an amount of approximately Rs. ___________/- on the treatment of the deceased.

3- That the ___________ of the deceased _______ was also damaged in the said accident, which was financed and the deceased paid Rs. ___________/- as down payment at the time of purchasing of the said ___________, paid insurance charge about Rs. _____/-, Rs. ________/- as registration. That due to the death of ____ of the plaintiffs the installments were not paid and the possession of the ___________ was taken by the financer and the plaintiffs have suffered a loss of Rs. _______/- as damages of the ___________ due to the said accident.

4- That due to the negligence of the respondents the plaintiffs have lost their earning member of the family and now there is no earning member in the family of the plaintiffs and they lost their liquidity and are not possessed a sufficient means other than exemption from the attachment in execution of a decree and subject matter of the suit to enable them to pay the court fees prescribed by the law amounting to Rs. __________, the plaintiffs due to the death of the earning member of the family have come at the point of starvation.


5- That the plaintiffs do not own any moveable or immoveable property belonging to the plaintiffs except within the Schedule __ enclosed hereto showing the estimated value thereby which has been signed and verified by the plaintiffs.
6- That the plaintiffs are indigent persons and have not within the two months next before the presentation of the petition disposed off any property fraudulently or to be able to apply for the permission to sue as an indigent person.

7- That the plaintiffs never owned any property, which could enable them to pay the prescribed court fees.
8- That the plaintiffs have not entered into any agreement with reference to the subject matter of the proposed suit which in person has not obtained the interest in such subject matter and the suit of the plaintiffs which is legal and maintainable.

9- That the plaintiffs have not done act of omission which has incapacitated them to pay the court fees and on the other hand it is because of the respondents as due to the negligence of the respondent earning member of the family of the plaintiffs has been expired and the plaintiffs have no assets moveable or immovable to pay the court fees as such are to be declared as indigent persons incapable of paying the court fees.


PRAYER

It is, therefore, prayed that the plaintiffs may kindly be declared as indigent persons the suit of the plaintiffs may kindly be registered and the plaintiffs may kindly be exempted from paying the court fees of Rs. _________ or any other sum which is payable on the plaint for the recovery of Rs. _______/- of damages against the respondents.
Dated Plaintiffs –Plaintiffs (in person)


Through counsel
__________ Advocate, ___________

VERIFICATION

Verified that the contents of our above application are true and correct to the best of our knowledge and belief and nothing has been concealed therein. Verified at ___________

Plaintiffs –Applicants

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Application for Setting Aside the exparte order

In the court of Shri _______________, _________________
In the matter of :-
___________
Versus
____________ & others.
CLAIM PETITION UNDER SECTION 166/140 OF
M.V.ACT.

Application for Setting Aside the exparte order dated
____________

AFFIDAVIT.
I, __________ S/o Shri ____________, R/o _________________, do hereby solemnly affirm and declare as under :-

1- That the above noted case was fixed for ____________ and the deponent was present before the Hon’ble court on the same day. The above noted case as further adjourned for __________.

2- That on __________ due to mishearing and misunderstanding the deponent noted down the next date as __________ instead of _________- hence the deponent could not attend this Hon’ble court on __________. due to non appearance of the deponent this Hon’ble court proceeded the above noted petition as exparte against the deponent.

3- That on __________ when the deponent appeared before the Hon’ble court then he came to know that the above noted petition was preceded ex-parte as against the deponent on _________.

4- That the absence of the deponent was not intentional but was due to the reason referred above.

5- That in case the above noted petition is not restored then the deponent will suffer an irreparable loss and injuries.

6- That the application is within time since the date of knowledge.


Deponent.

VERIFICATION:

Verified that the contents my above affidavit is true to bet of my knowledge and belief and nothing has been concealed therein.

Verified at ________ on
Deponent.

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Sworn Affidavit

Sworn Affidavit
(AFFIDAVIT – 9)

SPECIMEN OF SWORN AFFIDAVIT / DECLARATION OF PARENTS WHO APPLY FOR PASSPORT IN

FAVOUR OF MINOR CHILD / CHILDREN IN _________

(To be submitted in duplicate with copy/copies of birth certificate
of child(ren) and copy each of Passport and ________)

I ___________________________,HOLDER OF PASSPORT ____________________

ISSUED AT_________________ON ________________RESIDING IN ________________ _____________, HUSBAND / WIFE OF SMT/ SHRI _____________________________S/O OR D/O ___________________________ RESIDING IN INDIA AT ________________ _______________________________________ DO SOLEMNLY SWEAR AND AFFIRM THAT:

1.THERE IS NO PASSPORT (S) IN THE NAME (S) OF MY CHILD / CHILDREN LISTED BELOW

NAME DATE OF BIRTH SEX RELATIONSHIP

a) ____________________________________________________________________

b) ____________________________________________________________________

c) ____________________________________________________________________


1. His /her / their names (s) is / are not included in mother’s/father’s passport
2. The passport (s) is / are required by the child / children for visiting __________ to stay with
his/her/their Parents.
3. The photocopy of my passport is submitted along with new passport application.

I declare my consent for obtaining passport (s) for my child / children listed above


( )
DEPONENT
Signed before me :-


VICE CONSUL(CONSULAR)

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Notaries In India

Notaries in Andaman and Nicobar
Notaries in Andhra Pradesh
Notaries in Arunachal Pradesh
Notaries in Asom (Assam)
Notaries in Bihar
Notaries in Chandigarh
Notaries in Chhattisgarh
Notaries in Dadra and Nagar Haveli
Notaries in Daman and Diu
Notaries in Delhi
Notaries in Goa
Notaries in Gujarat
Notaries in Haryana
Notaries in Himachal Pradesh
Notaries in Jammu And Kashmir
Notaries in Jharkhand
Notaries in Karnataka
Notaries in Kerala
Notaries in Lakshadweep
Notaries in Madhya Pradesh
Notaries in Maharashtra
Notaries in Manipur
Notaries in Meghalaya
Notaries in Mizoram
Notaries in Nagaland
Notaries in Orissa
Notaries in Pondicherry
Notaries in Punjab
Notaries in Rajasthan
Notaries in Sikkim
Notaries in Tamilnadu
Notaries in Tripura
Notaries in Uttarakhand (Uttaranchal)
Notaries in Uttar Pradesh
Notaries in West Bengal

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Application form for Registration of Hindu Marriage (Marriage Registration Application)

Application form for Registration of Hindu Marriage
FORM - A (See Rule 5 (1))

Application for Registration of Hindu Marriage.
Date of Receipt ……………

The Registrar
We request you to register the particulars relating to our Marriage solemnized on ……….……… at ………..............………. Village / Town................................... Taluk……………………Mandal………

Full Name of parties Husband Wife


1. Full Name of parties

2. Religion & Caste of the parties

3. Age at solemnisation of the marriage

4. Rank of Profession

5. Permanent place of residence before solemnisation of the marriage

6. Date of Birth

7. Place with name of Taluk and District at which marriage was solemnised.

8. Date of solemnisation of the marriage (Name in full)

9. Father

10. Mother

11. Guardian if any the wife with relationship (See Section 6)

12. Address of the Guardian (information to be furnished in case of divorced persons who may marry again (See Section 15)

13. Date of the decree in the Court of the first instance.

14. Whether the period of one year has elapsed from the date noted in the Col (12) to the date of the application See Section 151.

15. Remarks

We hereby declare that the particulars mentioned above are correct to the best of our knowledge and belief that our marriage is one to which the Hindu Marriage Act, 1955 (central Act xxv of 1995) applies and that we have fulfilled the conditions, laid in Section 5, 6 or 15 wherever necessary.

(If the wife is a minor, signature of the guardian in marriage at the time of marriage)

Station: Signature with Date

Date:
Husband:
Wife:
Witnesses:
Name : Name:
Address: Address:
Signature: Signature:




Signature of the Registrar with date

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Suit for Declaration with the consequential relief of Permanent Injunction

IN THE COURT OF _____ JUDGE, SENIOR DIVISON, ___________.

______________ Versus. _______________

Suit for Declaration with the consequential relief of Permanent Injunction

AFFIDAVIT.

________ of Shri _________ R/o _________________
District ___________, do hereby solemnly affirm and declare as under:

1- That the deponent was appointed by the defendants in the Defendant No.1 School on the vacant post of __________ on _________ through the _____________, _________ on a monthly salary of Rs. ________ per month. The copy of appointment letter is enclosed herewith the plaint.

2- That ever since the date of her employment as ___________ with the defendants the deponent regularly and continuously discharged her duties upto the year ________. Thereafter, the defendants after passing a proposal kept the deponent continued her services. The salary of the deponent was released by the defendants from the ____________ in the year ________. The defendant No.1 wrote the letter dated ____________ to the defendant No. 3 in this regard. The copy of the letter is enclosed.

3- That the defendants further extended the period of service of the deponent from time to time. The defendant No.1 wrote various letters to the defendant No. 3 in respect of the service of the plaintiff, extension of the period of service of the deponent vide letters dated _________________, upto __________. The photocopies of the letters are enclosed herewith for the kind perusal of this hon’ble court.

4- That the respondent No.1 wrote the letter bearing its Memo No. ____ dated __________ to the defendant No. 3 for the extension of the period of the deponent upto the year ________. Thereafter the services of the deponent were continued by the defendants on the said terms and conditions and she was kept as Part time ________ upto the year _________. The defendants paid the salary amount of the deponent for the year ______ vide their Account payee Cheque No. _________ dated _______ for Rs. ______/-. The defendants again continued the part time services of the deponent for the year 2005-2006_________ and they also made the payment of the salary through the Account Payee Cheque No..__________ for Rs. ___________. After a span of about _ years continuous and regular services of the plaintiff, the defendants being satisfied with the works of the plaintiff, and the deponent never gave any chance for any complaint to the defendants. Due to the long span of time she has become regular employee and she has become entitled for all the benefits of a permanent and regular employee.

5- That now the defendants with a malafide intention for the purpose of recruiting some other employee at the post of the deponent are bent upon to terminate the services of the deponent forcibly and illegally. The defendants are also threatening the deponent to submit her resignation voluntarily to them, sign the resignation, full and final vouchers of the payment otherwise they would forcibly took the signatures of the deponent and would terminate her immediately.

6- That the deponent requested the defendants several times to see reason and to terminate her from her services as she has no other source of income for her livelihood. The deponent also requested the defendants to regularly her services as part time _______ but the defendants refused to regularize the services of the deponent and they threatened that they would recruit some other person in place of services of the plaintiff.

7- That the cause of action to file the present suit accrued on each and every date when the defendants extended the period of services of the deponent and it further arose on ___________ when the Cheque for the salary of the deponent was handed over by the defendants to the plaintiff. The cause of action further arose on _________ when the defendants threatened the deponent to terminate her services forcibly and illegally. Hence _____ is the final date of cause of action arose in favour of the deponent and against the defendants. Hence this suit.

Deponent

VERIFICATION:

Verified that the contents of my above affidavit are true and correct to best of our knowledge and belief and nothing material has been concealed therein.
Verified at ___________ on
Deponent.

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SUIT FOR DECLARATION

In the court of Hon’ble Civil Judge, Senior Division,__________
_____________ Vs. ___________

SUIT FOR DECLARATION

Affidavit

I, __________ son of Late Shri ____________ R/o ____________________ do hereby solemnly affirm and declare as under: -

1- That the deponent is owner and in possession of a Plot comprised in ______________ No. ______________, _____________, admeasuring __’x__’ total measuring __ Marlas i.e. ___ Sq. yards which is situated within the _______________________.

2- That the defendant is the real brother of deponent and the parties to the suit constitute a Joint ___________ family and are governed by _______ law.

3- That as a matter of fact the property, which is mentioned in Para No.1 of the plaint, was purchased by the defendant vide Sale Deed bearing its document No. ______ dated _____________ registered in the office of __________________. The copy of the Sale Deed is enclosed herewith the plaint.

4- That on ______________ a family settlement took place between the deponent and the defendant vide which the defendant relinquished all his rights, title and interest in the suit property in favour of the deponent and he put the deponent into the actual and physical possession of the suit property mentioned in Para No.1 of the plaint and since then the deponent is owner and in possession of the suit property which is mentioned in Para No.1 of the plaint.

5- That now the defendant with a malafide intention is not admitting the family settlement and he is not admitting the claim of the deponent in respect of the suit property for which the defendant has got no right, title and interest to do so.

6- That the deponent asked the defendant several times to see reason and to admit the claim of the deponent in respect of the suit property which is mentioned in Para No.1 of the plaint. First of all the defendant was avoiding to the requests of the deponent on one pretext or the other and finally on ______________ the defendant refused to admit the claim of the plaintiff.

7- That the cause of action to file the present suit firstly accrued on ______________ when the family settlement took place between the deponent and the defendant and it further accrued on each and every date when the deponent requested the defendant to admit the claim of the plaintiff. The cause of action finally arose on _____________ when the defendant finally refused to admit the claim of the plaintiff. Hence _______________ is the final date of cause of action accrued in favour of the plaintiff. Hence this suit.



DEPONENT

VERIFICATION:

Verified that the contents of my above affidavit are true to best of my knowledge and belief and nothing has been concealed therein.
Verified at __________ on ___________
DEPONENT

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SUIT FOR PERMANENT INJUCTION

IN THE COURT OF SH._____________.


_________ Versus _____________


SUIT FOR PERMANENT INJUCTION
AFFIDAVIT

I, __________ son of Sh. ___________, R/o _______________, do hereby solemnly affirm and declare as under:
1 That the deponent along with his ___________ son of Sh. ____________ purchased a site consisting of a house and a shop situated at _____________ formerly ________, forming part of __________- measuring ___ Sq. yards admeasuring __ x __ show in ___ colour in the site attached with the plaint from ___________ S/o Sh. __________________ vide registered sale deed dated _________. The Photo Copy the sale Deed is EX-P-1. The said shop is bounded as under :-

North - ____________
South - ____________
East - ____________
West - ____________

2- That the afore-said _____________ had purchased the above mentioned site from ____________ of _____________ vide registered sale Deed dated _______________ in which ____ room _____ and _____ were existing. Water and electricity connections were also therein the site. The photocopy of sale Deed dated ______ is EXP-2.

3- That at the time of purchase of the said site by the deponent and his ______ from _________ aforesaid , _____ room ______ ,______ and ______ were there at the site and the electric and water connections were also there. The property in question is subject to house tax by the defendants and the same is being paid by the deponent from time to time.

4- That the construction mentioned in Para No.2 above is existing at the site for the last more than __ years as is evident from the Photocopy of the conveyance Deed attached with the plaint. The photocopy of the House Tax receipt is EXP-3 and the copy of the site plan is EXP-4.

5- That the defendants illegally and unlawfully issued show cause notice dated __________ under Section ___ of the _____________ Act and order of demolition dated ___________ in the name off Shri ____ father of the deponent on receipt of which the deponent visited the office of the defendants and apprised them that the construction regarding which notices has been issued by the defendants was an old one having been raised in the premises in question for the last more than __ years and documents in the support there of were also shown to them. On seeing the same they were satisfied and told that the deponent that no action thereon shall be taken by the defendants.

6- That the defendants through their employees now on __________ came to the suit premises and tried to demolish the construction rose thereon illegally and unlawfully. However, their attempt to do so was failed with the help of the respectables of the area. They left the spot but held out threats to demolish the same. The deponent apprehends that in case they succeed in their illegal designs, in that event he would suffer irreparable loss and injury. This is the final date of cause of action and hence this suit.


Deponent

VERIFICATION
Verified that the contents of my above affidavit are true to best of my knowledge and belief and nothing concealed therein.
Verified at __________ on _________

Deponent

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CIVIL APPEAL Report

In the Court of Shri ______________________

___________ Vs. ___________

CIVIL APPEAL

Report of the Local ________

Sir,

The Local ___________- submits the following report :-

That I was appointed as a Local ____________ by this Hon’ble court vide order dated _________ with the directions to visit the spot and to submit the report about the existing position of the suit property alongwith rough site plan after issuing Notice to the parties.
As per the directions of this Hon’ble court, I served notices upon the counsels for the parties intimating them to come present on the spot on __________ at about _________. I reached the spot on ________ at __________ and firstly I prepared the memo of appearance of the parties. Both the counsels of the parties were present at the spot. I prepared a rough site plan at the spot which is enclosed herewith this report. I visited the spot and prepared the following report: -
1- That I entered into the property in dispute from _________ and I found that there is _____ portion just adjacent to the ________. The property is facing towards the _________side. On the main gate I found ________ and the wall with the main gate. The wall was ___. and the same was newly constructed. I found that there were _____ rooms and _____. There were total _ pillars on which the ______ is entangled. There were ____ pillars in the middle of the _____ and these rooms were old constructed rooms probably constructed about _ years ago. I found there was kitchen foundation and wall adjacent to the same was _______ Ft. in height. I found lying dust with the _____ wall of the said property. On the western side I found ____, which were also newly constructed. The _____ wall is the joint wall of Shri ______ and _________. In the _________ side there is _______ land in which ________ is standing. I also found the ____ _______ outside the gate and ______ inside the property and property is bounded as under:-
East - _____________
West - _____________
North - ______________
South - ______________

It is, therefore, prayed the Local ____________ report may kindly be accepted in the interest of justice.
Dated Local _________.

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Cheque Deposit Affidavit

IN THE COURT OF SHRI _______________, _______________

____________ Vs. ____________

CLAIM PETITION

APPLICATION FOR PERMISSION TO DEPOSIT CHEQUE NO. _______ DATED ________ FOR RS. __________/--(RUPEES ____________ ONLY) DRAWN ON _______ BANK ___________ AS COMPENSATION .

Respectfully Showeeth:

1- That the above mentioned petition has been decided vide award dated __________ of Shri _________ the learned predecessor of this Hon’ble court.

2- That the respondent No. _ _____________ wants to deposit its share of the amount of award alongwith interest upto date vide Cheque ________ dated ___________ for Rs. _________/--(Rupees ____________ only) drawn on ________ Bank __________- today before this Hon’ble court.

It is, therefore, prayed that the above-mentioned Cheque may kindly permitted to be deposited before this Hon’ble court today.

Dated ________ Respondent No. _/Applicant

_____________________
Through counsel

________ Advocate, _________

RECEIPT

Received Cheque _______ dated _________ for Rs. ____________/--(Rupees ______________ only) drawn on _______ Bank _________ through __________ Advocate on behalf of ___________, ___________
______, _________

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Agriculture land Affidavit

IN THE COURT OF CIVIL JUDGE, SENIOR DIVISON, ___________.

______________

……Plaintiffs

VERSUS
_________________
….Defendant


SUIT FOR DECLARATION

Affidavit
I, ____________ son of Shri ____________, resident of _________________, do hereby solemnly affirm and declare as under :-

1- That the defendant are recorded owner in possession of the agricultural land comprising ___________________, total measuring _____________, which is situated with in the revenue estate of village ___________________. A copy of the Jamabandi for the year of _________________ is enclosed herewith the plaint.

2- That the plaintiffs are the real ___________ of the defendant and the parties to the suit constitute joint _____ Family.

3- That on ____________ a family settlement took place between the plaintiffs and the defendant vide which the defendant gave the suit property to the plaintiffs in equal share each (1/2 share each) and put the plaintiffs into the actual and physical possession of the suit property, mentioned in Paras No.1 of the plaint, and since then the plaintiffs are owners in possession to the extent of ½ share each of the suit property as mentioned in Para No.1 of the plaint. However, the name of the defendant still exists in the revenue records which is wrong and is not binding upon the rights, title and interest of the plaintiffs.

4- That now the defendant with a malafide intention are not admitting the family settlement and by getting the benefit of revenue entries in his name he is still declaring himself as owner in possession of the suit property for which the defendant have got no right, title and interest to do so.

5- That the plaintiffs asked the defendant several times to admit the claim of the plaintiffs and to get name of the plaintiffs recorded in the revenue records in place of his name. First of all the defendant was avoiding the requests of the plaintiffs on one pretext or the other and finally on ____________ the defendant refused to accept the legitimate requests of the plaintiffs.

6- That the cause of action to file the present suit firstly accrued on _____________ when the family settlement took place between the plaintiffs and the defendant. It further arose on each and every date when the plaintiffs asked the defendant to admit the claim of the plaintiffs and the cause of action finally ___________ when the defendant finally refused to accept the claim of the plaintiffs. Hence this is the date when the final cause of action has arisen in favour of the plaintiffs and against the defendant, which necessitated the institution of the present suit.

DEPONENT

VERIFICATION:

Verified that the contents of my above affidavit are true and correct to best of my knowledge and belief and nothing has been concealed therein.

Verified at _________ on _________
DEPONENT

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Application for claim of wrong statement

BEFORE THE PRESIDENT DISTRICT CONSUMER DISPUTES
REDRESSAL FORUM, ____________.


M/S _________________

Versus

M/S _________________

Complaint _____ of the Consumer Protection Act 1986.

Written statement on behalf of Respondents.
Sir,
The respondents respectfully submit as under: -

PRELIMINARY OBJECTIONS:
1- That the complaint of the complainant is not maintainable in the present form because the respondents do not fall under the definition of the consumer.

2- That complainant has no locus-standi to file the present complaint against the answering respondents.

3- That the complainant has no cause of action to file the present complaint against the answering respondents.

4- That the complaint of the complainant is bad for misjoiner of the necessary parties. It is hereby submitted that M/s __________________ at ______ is the necessary party.

5- That the complainant has falsely dragged the complainant in the present false complaint. The respondent delivered the goods at its destination but M/s _________________ did not collect the material from the office of the respondent at Chennai. It is further submitted that it was well settled that the complainant will responsible for packages of the goods and in case of any fault the respondent company is not liable for the same which is also mentioned on the backside of the consignment note. It is further submitted that the complainant company did not packed the cartons properly and the same were loose and straps were not tied properly but the goods were in O.K condition and there was no shortage.

6- That the complainant has not come with clean hands before this Hon’ble Forum and he has suppressed the actual and material facts from this Hon’ble Forum.

REPLY PARAWISE:
1- That the contents of Para No.1 of the complaint are wrong and denied.

2- That the contents of Para No.2 of the complaint are matter of record.

3- That the contents of the Para No. 3 of the complaint are correct to the extent that the complainant company sent _ boxes of ____________ vide consignment Note No. ________ dated ___________. Rest of the contents of this para is wrong and incorrect and the complainant is put strict proof to prove the present para.

4- That the contents of the Para No. 4 of the complaint are wrong and vehemently denied. It is incorrect that the respondents are solely responsible and the complainant is legally entitled to claim the amount from the respondents.

5- That the contents of the Para No. 5 of the complaint are wrong, false, incorrect and hence denied. It is incorrect that there was great deficiency of the service on the part of the respondents. It is submitted that the respondents delivered the goods at its destination at ______ Office and also informed to M/s ________ company who reason best known to him did not collect the material from the site intentionally and deliberately.
Hence there is no deficiency on the part of the respondents.

6- That the contents of Para No. 6 of the complaint are wrong and denied being misconceived.

7- That the contents of the Para No.7 of the complaint are totally wrong and vehemently denied.

8- That the contents of Para No. 8 of the complaint are wrong and denied. It is incorrect that due to deficiency of Service there was mental, harassment, agony and tension to the complainant. It is incorrect that the complainant is legally entitled to claim compensation to the tune of Rs.________/- from the respondent.

9- That the contents of Para No. 9 of the complaint are matter of record.

10- That the contents of Para No. 10 of the complaint are wrong and incorrect.

REPLY TO PRAYER:

That the prayer of the complaint is also wrong and vehemently denied. The complainant is not entitled for any relief.

PRAYER

It is, therefore, prayed that in the interest of justice and in view of the forgoing facts and circumstances the complaint of the complainant may kindly be dismissed with costs.
RESPONDENTS.
Through counsel:
_________, Advocate, ___________.

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Application for Complaining against Mobile Tower Installation

IN THE COURT OF HON’BLE CIVIL JUDGE, SENIOR DIVISION,
____________.

Civil suit No.____of ____
_________________ S/o Shri_________
R/o _________________

…Plaintiff
Versus
1- ____________
R/o _______________.

2- The Joint Commissioner
Municipal Corporation,
________________.


…Defendants.

SUIT FOR PERMANENT INJUNCTION & IN THE
CONSEUENTIAL RELIEF FOR MANDATORY INJUNCTION

Sir,
The plaintiff respectfully submits as under: -
1- That the plaintiff is the owner in possession of _____________, consisting of one room, one Tin Shed, Open Space and one Shop, which is situated at ________________________. The said house is fully shown in the attached site plan Annexure –P-1. The said house is bounded as under:-
EAST - ___________
WEST - ___________
NORTH - ___________
SOUTH - ______________

2- That the defendant NO.1 is owner in possession in the adjoining double Storey _____________________ which is situated towards the __________ side of the house of the plaintiff and the same is shown in the enclosed site plan Annexure __.

3- That the defendant NO.1 has installed some portion of _____________ Mobile Tower over the first floor of his house which is shown in the red colour in the enclosed site plan. It is pertinent to mention that the ______________ is the residential colony and the defendant No.1 OR ANY body else of the colony is not legally entitled to install any Mobile Tower over the first floor of his house. The said Mobile Tower is being installed by the defendant No.1 on the floor of first floor of his house which has no any base on the ground. The proposed Tower can fallen at any time in the heavy rain and storm at any time and if the same will be fallen then the said Mobile Tower will be fallen on the roof of the plaintiff due to which the plaintiff will suffer a huge loss. It is worth to mention here that the rays of the said Tower will discharge the rays, which will affect the residents of ___________________.

4- That the plaintiff asked the defendant to remove the said Mobile Tower from the roof of first floor of his house but the defendant No.1 told that he has taken the permission from the defendant No.2 in this regard. The plaintiff moved an application before the defendant No.2 and requested him to stop the defendant No.1 from installing the Mobile Tower on the first floor of his house. The plaintiff sent the copies of the same to the __________________ and to the Commissioner Municipal corporation, _________ but no action was taken by the said authorities. The photocopy of the application dated ____________ is enclosed herewith the plaint for the kind perusal of this Hon’ble court. However the defendant No.1 has succeeded to install some penels over the first floor of his house.

5- That on ___________ the defendant No.1 called about 15-20 persons and he tried to install the Mobile Tower over the roof of his house but due to the intervention of the plaintiff he could not succeed in his illegal designs. However the defendant No.1 is still adamant to install the Mobile tower with the help and support of the defendant No.2 forcibly and illegally for which the defendant No.1 has got no right, title and interest to do so. The defendant No.2 is still threatening to completely install the _________ MOBILE TOWER over the roof of first floor of his house forcibly and illegally. If the defendant No.1 will succeed in his illegal motives then the plaintiff will suffer an irreparable loss and injuries which cannot be compensated in any manner whatsoever;

6- That the of cause of action to file the present suit firstly arose on ______________ when the defendant No. 1 installed some portion of the __________ Mobile Tower forcibly. The cause of action further arose on ___________ when the plaintiff moved the application to the defendant No.2 requesting him to stop the defendant No.1 from installing the Mobile Tower over the first floor of his house forcibly and illegally. The cause of action finally arose on _____________ the defendant No.1 called about ______ persons and he tried to install the Mobile Tower over the roof of his house. Hence this is the date when the final cause of action arose in favour of the plaintiff and against the defendants, which necessitated the institution of the present suit.

7- That the present suit being filed by the plaintiffs against the defendant is the first suit and no such suit has been previously filed, pending or decided by any court of law on the same subject matter.

8- That plaintiff and the defendant No.1 reside and suit property is situated at _________ and the and entire cause of action also accrued between the parties at __________, within the territorial jurisdiction of this Hon’ble court, therefore, this Hon’ble court has got the jurisdiction to entertain and try the present suit

9- That the value of the suit for the purposes of court fee and jurisdiction is assessed at Rs. ___/- upon which a fixed court fees has been affixed on the plaint.

PRAYER:
It is, therefore, prayed that this Hon’ble court may kindly be pleased to:

(i) Pass a decree permanent injunction restraining the defendants from installing the MOBILE TOWER over the first floor of his house which is situated just near the house of the plaintiff mentioned in para No.1 of the plaint and fully shown in the enclosed site plan forcibly, illegally and in coercive manner whatsoever, may kindly be passed in favour of the plaintiff and against the defendants alongwith costs of the suit.

(ii) In the consequential relief a decree for mandatory injunction thereby directing the respondent No.1 and 2 to remove the some Penal installed by the defendant No.1 over the first floor of his house immediately, may kindly be passed in favour of the plaintiff and against the defendants

(iii) Or any other relief, which this Hon’ble court deems fit and proper, be also granted in favour of the plaintiff and against the defendants.

Plaintiff.
Through counsel:
______________, Advocate, _______________
VERIFICATION:

Verified that the contents of paras No.1 to 6 and of the plaint are true and correct to best of my knowledge and Paras No. 7 to 9 of the plaint are true to best of my belief and on the information received. The last Para is the humble submission before this Hon’ble court.
Verified at ___________ on ___________
Plaintiff.

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Criminal Complaint after legal Notice

IN THE COURT OF HON’BLE ILLAKA MAGISTRATE/JMIC, _______

___________ son of ___________,
resident of _______________
…COMPLAINANT.
VERSUS

Mr. _________________
______________________
…..ACCUSED.

Criminal Complaint Under Section ___ of ________ & Under Section ___ I.P.C.

P.S.: ______________
Sir,
The complainant most respectfully submits as under:-
1- That the complainant and the accused are having friendly relations with each other. The accused requested the complainant to lend some money as the accused was in need of this amount for some his urgent work. Keeping in view the friendly relations the complainant could not ignore the request of the accused and consequently he gave a friendly loan amount of Rs. _____/- in cash to the accused in the first week of _______. At the time of taking this loan amount the accused assured that the accused would refund the same to the complainant within the period of _______ months positively.

2- That after admitting his liability to refund /repay the said loan amount, the accused issued an account payee Cheque No. _______ dated _____ for Rs. _____/- drawn on __________, ___________ in favour of the complainant.

3- That the complainant presented the above mentioned Cheque with their banker i.e. _______________ for encashment but to the utter surprise of the complainant above mentioned Cheque was dishonoured by the banker of the accused i.e. ________________, _______ due to the reason “insufficient fund” vide Cheque return Memo dated ________. The intimation in this regard was received by the complainant from his banker.

4- That after dishonourment of the said Cheque the complainant contacted the accused and requested the accused to make the payment of the dishonoured Cheque then the accused requested the complainant to present the above said Cheque again for encashment.

5- That as per the definite assurances the complainant again presented the above mentioned Cheque with their banker i.e. __________________ for encashment but to the utter surprise of the complainant above mentioned Cheque was dishonoured by the banker of the accused ___________________ due to the reason “ACCOUNT CLOSED” vide _______ Cheque return Memo dated ___________. The intimation in this regard was received by the complainant from his banker.

6- That at the time of issuing the above mentioned Cheque the accused had full knowledge that the said Cheque would be dishonoured due to insufficiency of the funds as the accused had no sufficient amount in his bank account to encash the same. Firstly the accused issued the said Cheque then after closed his bank account intentionally and deliberately. By issuing this false and bogus Cheque intentionally and deliberately the accused has cheated the complainant and have committed the criminal offence punishable under section ___ of the Negotiable Instruments Act and under Section ___ of Indian Penal Code hence the accused is liable to be prosecuted and punished as per the provisions of the Act.

7- That the complainant sent a legal Notice dated_________ through registered A.D. calling upon the accused to make the payment of bounced Cheque to the complainant within 15 days of receipt of this legal notice. But after receiving these legal Notice neither the accused made the payment nor send the reply of the legal Notices to the complainant.

8- That complainant and the accused have been residing at ______________________, the banker of the complainant is also situated at ______________________ the accused handed over the Cheque to the complainant at __________________ and thus entire cause of action accrued in favour of the complainant at ______________ within the territorial jurisdiction of this Hon’ble court and therefore this Hon’ble court has got the jurisdiction to entertain and try the present complaint.

PRAYER:-

It is, therefore, most respectfully prayed that the accused may kindly be summoned, prosecuted and punished as per the provisions of the law.
Dated ________ Complainant.


Through counsel:
_____________, Advocate, ________________

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Marriage Divorce Legal Notice

___________ RESIDENCE CUM OFFICE
Advocate
Seat No.___, _________

Ref No.________ Dated ____________


LEGAL NOTICE
To,

_______ S/o Shri __________
______________________

Sir,

Under instruction from and on behalf of my client Smt. _________ daughter of Shri __________, resident of _________________, I do hereby serve you with the following notice, the contents of which are set forth herein below :-
1- That you were married with my client about ______ years ago at _____________, according to Hindu rites and ceremonies in the presence of friends, relatives and family members of both the parties.

2- That after the marriage you and my client lived together as husband and wife and cohabited with each other at ___________ and . Out of the said wedlock of my said client and you one son named _____ aged __ years, _____ daughter aged __ years were born.

3- That at the time of solemnization of this marriage the parents of my client had given sufficient dowry articles to you. At the time of marriage you were involved in unsocial activities. You used to consume wine daily and were also involved in gambling. You started adopting cruelties mentally as well as physical upon my client and whenever my client tried to mend your ways then you and your mother mercilessly beat my client.

4- That your attitude towards my client was very rude and indifferent from the very beginning and my client always fulfilled your illegal demands time to time. Your mother always taunted my client and said if she was interested to live in the matrimonial house then she would have to bear all the atrocities and cruelties.

5- That my client was of the opinion that after the birth of children you will improve your acts and behaviour and would leave your bad habits but you did not do so and you and your mother always abused, insulted, maltreated and misbehaved my client. Your mother refused turned out my client time to time from her matrimonial house.

6- That on _____________ you turned out my said client from her matrimonial house in three wearing clothes. You kept the children of my said client in our custody. Since the month of ____________ you and your above said mother are black mailing my client and her family members. You and your family members threatened to my client and her family members threatening my client for dire consequences according and as per directions of mother. You have refused to return the entire dowry articles and jewelaries of my said client. You have deserted my said client and hence my said client is not interested to live in your client. My client is also not interest to take the custody of the minor children from you. It my client would join your company then you would cause her death hence my client wants to dissolve her marriage immediately

I, therefore, call upon you through this legal notice to execute the Divorce Deed and papers etc. dissolving this marriage immediately within a period of 15 days from the date of receipt of this legal notice, failing which my client shall constrained to file appropriate proceedings against you in the court of law and in that event you shall be responsible for all costs, risks and responsibilities which you please note well.

A copy of this legal notice is retained in my office for record and further necessary action.

____________, Advocate, _________.

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Labour Amount Recovery Affidavit

In the Court of
In the matter of:
1- _____________

2- _____________
3- ______________
4- ____________

..Applicants/claimants
Versus
1- M/S _____________, through its
Proprietor Mr. __________________

2- Mr. _________________ contractor
C/o M/S _____________________
Office : ______________________,
..Respondents

APPLICATION UNDER SECTION 33 (C) (2) OF THE
INDUSTRIAL DISPUTES ACT, 1947

Sir,
It is respectfully submitted as under: -
1- That the respondents No.1 and 2 are a contractor and they have been engaged in the business of taking the contracts of constructing the houses, flats, buildings, bungalows etc.

2- That the claimants have been doing the construction and labour workers with the respondents as per their instructions from time to time for the last several years.

3- That as per the instructions the respondents the claimants did the work at ______________, ______________ and the respondents collected the payment from ________________ and made some amount to the claimants of the work done by them and still an amount of Rs. ___________/- has not been paid by the respondents to the claimant.

4- That the respondents send the claimants to do the construction work at the site of M/s _____________________ and out of the amount collected by the respondents from the said company the respondents gave the less payment of Rs. ___________/- to the claimants. The respondents also sent the claimants to do work at __________________ and an amount of Rs. ____________/- are left out payable by the respondents to the claimants from the payment of work done at _____________.
5- That the total amount to Rs. ______________/- have not been paid by the respondents to the claimant’s up to date for which the claimants have been requesting the respondents to pay the same for the last about _ months.

6- That the claimant requested the respondents to make the balance amount of Rs. _______________/- to them as they are under the financial weakness but the respondents are keeping on avoiding the requests of the claimants on one pretext or the other and finally on_______________ the respondents refused to make the said payment. Now the respondents are threatening to the claimants to face dire consequences if he again approached to the respondents. It seems that the respondents have become dishonest and does not want to make the payment of the outstanding amount/dues to the respondents.

7- That the claimants are entitled to recover from the respondents the above mentioned amount along with interest as prevailing in the market jointly and severally.

PRAYER:

It is, therefore, prayed that the application of the applicant may kindly be allowed and amount of outstanding labour charges Rs.____________ may kindly be computed in favour of the applicant and against the respondents in the interest of justice which is fully detailed in attached Annexure “A” and the respondents may kindly be directed to pay the same jointly or severally to the claimant/applicant.

APPLICANTS

Through A.R.

Verification:

Verified that the contents of my above application from Para No.1 to 7 are true to best of my knowledge and belief and nothing has been concealed therein.

Verified at _____________ on

APPLICANTS

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Legal Notice to Bank Loan

__________ Advocate
District Courts,
Seat No.____,
_________________

Ref No………….. Dated _____________

LEGAL NOTICE

To

The Manager
_______________,
_______________


Dear Sir,

UINDER the instructions from and on behalf of my client Mr____________ son of Shri ____________ R/O ______________________, I do hereby serve upon you with the following legal notice:-
1. That a loan of Rs. ________________/- was sanctioned in the name of my said client by you under the Scheme of _____________ Scheme provided by _________________

2. That as per the rules and regulations my client was exempted from the _____payment of the loan amount. At the time of sanctioning of the loan amount you promised to charge the interest @ __% per annum.

3. That my said client has already repaid the amount of Rs. __________/- approximately to you and after deducting the ____ amount from the total loan amount nothing is payable by my said client to you.

4. That now you have been raising the illegal demand of the total amount along with interest @ __% from my said client which is quite unreasonable and illegal and my client is not liable to pay you any amount.

I , therefore, call upon you through this legal notice to issue No Dues certificate regarding the above said loan account in favour of my said client and not to raise any demand of money from my client , within the period of 15 days from the date of receipt of this notice , failing which my client has given me clear instructions to file civil , criminal and other Misc. proceedings against you in the competent court of law and in that event you shall be fully responsible for all costs, risks and consequences thereof.

Copy kept for record.

Yours faithfully

____________, Advocate, ___________

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Legal Notice For Snatching And Accident

________________ RESIDENCE CUM OFFICE
Advocate
Seat No._____, __________
District courts, _________
____________________
Phone No

Ref No.________ Dated ____________

REGISTERED A.D./ U.P.C.

LEGAL NOTICE
To,

_________________
Sir,

Under the instructions from and on behalf of my client Mr. _______________, resident of __________________________, I do hereby serve you with the following legal Notice: -
1- That my client is respectable person of the society and he is plying his ____________________ on the roads and is earning the livelihood for his family members.

2- That in the month of _________________my said client driving his vehicle on a very moderate and normal speed, on the extreme left side of the road keeping in view the principles of road and safety of the others on the road when reached at ____________________ meantime your client driving your offending ______________ rashly, negligently, with a high-speed came from behind side and hit vehicle
__________________ of my client from back side. You came out of the car and gave fists and slaps blow to my said client. You forcibly snatch the R.C. of the ________________________ from the custody of my said client and also snatched the purse containing Rs. ___________/-.

3- That my client went to your client and asked you to return the R.C. as well as the cash amount of Rs. ____________/- but you instead of returning the same threatened my client for dire consequences. In this way you have forced my said client to file the criminal and civil proceedings against you in the competent court of law against you as well as your driver.

4- That you along with your driver have committed criminal wrongs by snatching the R.C. and the cash amount from my said client for which my client reserves his right to file criminal proceedings as well as suit for damages against you in the competent court of law. You have robbed the money as well as R.C. from the custody of my said client

I, therefore, through this legal notice call upon you to handover the R.C. of _______________________ along with the amount of Rs. __________/- with interest to my said client and Rs. ______________/- as charges of this legal Notice within the period of 15 days from the date of receipt of this legal notice, failing which my client has given me clear instructions to file civil, criminal, suit for damages and other Misc. proceedings against you in the competent court of law and in that event you shall be responsible for all costs, risks and responsibilities which please note well.

A copy of this legal notice is retained in my office for record and further necessary action.
____________, Advocate
___________

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Application for Divorce Petition

IN THE COURT OF HON’BLE DISTRICT JUDGE, ___________.

HMA Petition No.__________ OF _____


Smt. _________ wife of Shri _________ D/o ___________ R/o __________________.
…PETITIONER

VERSUS


____________ son of Shri _____________ resident of ______________________
…..RESPONDENT


PETITION UNDER SECTION 13 OF THE HINDU MARRIAGE ACT, ______ FOR DISSOLLUTION OF THE MARRIAGE BY A DECREE OF DIVORCE

SIR/Madam
The petitioner respectfully submits as under:-
1- That the petitioner was married with the respondent on ___________ at ______________ according to Hindu rites and ceremonies in the presence of friends, relatives and family members of both the parties. An affidavit to this effect is enclosed herewith the petition.
2- That the status of the parties before the marriage and at the time of filing the present petitioner were/are as under
PETITIONER RESPONDENT
Status Residence Status Residence.
i) Before ___________________ ________________________
Marriage ___________________ ________________________

ii) At the Married -do- Married -do-
time of
filing of this
Petition

3- That after the marriage the petitioner and the respondent lived together as husband and wife and consummated their marriage at the residence of the respondent and out of the said wed lock one child namely ___________ alias __________ was born on ____________.

4- That from the very begining of the marriage the behaviour of the respondent was not good towards petitioner. The respondent is habitual of daily drinking and gambling /Lottery and after drinking the respondent always used to give merciless beatings to the petitioner. The respondent used to spent all his earnings on taking liquor and gambling. The respondent pressurized the petitioner to bring the amount of Rs. ____________/- from her parents and when the petitioner refused to bring the amount then the respondent gave merciless beatings to the petitioner. The parents of the petitioner gave the amount of Rs. _____________/- and Rs. ____________/- to the respondent on two occasions but the respondent did not mend his ways rather he continuously tortured the petitioner to bring more money from her parents. The respondent always taunted the petitioner by giving abusive and unparliamentary language without any cause in the presence of relatives and friends. The life of petitioner became like a hell due to the respondent’s behaviour.

5- That although the parents of the respondent arranged a very decent marriage according to his financial capacity and gave sufficient dowry/ Istri Dhan items, but yet the respondent was very greedy in nature from the very beginning of marriage. The respondent sold away entire jewelries and ornaments of the petitioners on playing lottery and drinking. The respondent committed a lot of cruelties with the petitioner and turned out the petitioner, only due to the reason that the respondent had refused to bring Rs. _____________/- from her parents on ______________. The life of the petitioner has been made like a hell. The respondent threatened that he will not keep and maintain the petitioner till his demands are not fulfilled by her parents.

6- That various panchayats were convened at the house of the respondent and the parents of the petitoner requested the respondent to keep and maintain the petitioner but the respondent clearly refused to keep and maintain the petitioner. The last panchayat was convened on ____________ in the presence of respectable , relatives in which Shri _________________ son of Shri ____________ R/o ____________________ and Shri ___________ son of Shri _____________ R/o House NO. __________________ were also present but the respondent did not agree to keep and maintain the petitioner and the respondent put the condition that he will not keep the petitioner without obtaining the illegal amount of Rs. ______________/-from the parents of the petitioner.

7- That the petitioner bears all type of cruelties because the petitioner wanted to save her married life and do not want to spoil her life. Many times the parents and relatives advised the respondent to get-off to drink and to behave properly but to no use. The petitioner also tried to advise the respondent many times to change his behavior and not to drink but the respondent refused to accept the legitimate requests of the petitioner and the relatives.

8- That the respondent has deserted the petitioner without any reasonable and justifiable cause and rhyme and hence it has become impossible for the petitioner to live more in the company of the respondent therefore, the petitioner is entitled for a decree of divorce on the grounds of cruelties and desertion.

9- That the cause of action to file the present petition accrued to the petitioner many times when the respondent abuses in the filthy language and the petitioner was beaten mercilessly. The cause of action also accrued on ____________ when the respondent turned out the petitioner alongwith her minor daughter. The cause of action further arose on each and every date when the Panchyats were convened and it lastly arose on ______________ when the respondent clearly refused to keep and maintain the petitioner. Hence this petition.

10- That the parties are Hindus by religion.

11- That the present petition has not been by the petitioner filed in collusion with the respondent.

12- That no such petition is pending or has been filed or decided by any court of law on the same subject matter between the same parties.

13- That petitioner has no legal impediments why the relief sought for is not granted to the petitioner.

14- That the petitioner is still residing at __________ the marriage was solemnized at _____________ within the jurisdiction of this hon’ble court therefore, this hon’ble court has got the jurisdiction to entertain and try the present petition.

15- That a fixed court fee has been paid on the petition.

PRAYER:
It is, therefore, prayed that a decree for Divorce Under section 13 of the Hindu Marriage Act, 1955 thereby dissolving their marriage of the petitioner and the respondent on the grounds of cruelty and desertion may kindly be passed in favour of the petitioner and against the respondent along with costs of the petition. It is prayed accordingly.
PETITONER.
Through counsel:
_____________ Advocate, _____________.

VERIFICATON:
Verified that the contents of Paras No.1 to 12 and 14 of the petition are true to best of my knowledge and Paras No. 13 & 15 of the petition are true to best of my belief as information received by me through my counsel. Last Para is the prayer before this hon’ble court.
Verified at ___________ on ___________
PETITONER.

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APPLICATION FOR INSPECTION OF THE CASE FILE

IN THE COURT OF HON’BLE SESSIONS JUDGE, ___________


In the matter of :

Complaint Case :

___________ son of Shri ___________________ resident of _________________

……….COMPALINANT

VERSUS

1- ________________________

2- _______________________.

3- ________________________.


………..ACCUSED

COMPLAINT UNDER SECTION _________ IPC & SECTION ___________, ______________


APPLICATION FOR INSPECTION OF THE CASE FILE

Sir/Madam,

It is respectfully submitted that the above mentioned complaint was fixed before Shri _______________l Judge, on ____________ for prosecution evidence when it was adjourned sine-die till the completition of the investigation in the case bearing FIR No. _____ dated __________ under section ______ IPC and Section _________ Act registered in the Police Station _____________ in respect of the same occurrence and the file was consigned to the record room till then.
It is, therefore prayed that I may kindly be allowed to inspect the case file.

Dated ____________ COMPALINANT /APPLICANT

________________________


Through counsel

_____________ Advocate, ____________

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APPLILCATION FOR REGULAR BAIL

IN THE COURT OF __________, HON’BLE SESSIONS
Judge ________________.


___________________
Son of ________________
R/o _________________
…….……APPLICANT/PETITIONER.

VERSUS

State of _________.
……….RESPONDENT

IN THE MATTER OF:-

FIR NO. _____ DATED __________ UNDER SECTION _____________ IPC, P.S.- ____________________.

FIRST APPLILCATION FOR REGULAR BAIL

MOST RESPECTFULLY SHOWETH:-
1- That the petitioner belongs to a respectable family and he has clean antecedents.

2- That the petitioner has been framed up and falsely implicated in the above noted case by the complainant on extraneous grounds and he is in custody since _____________.

3- That the police does not require further custody of the petitioner for the purpose of investigation in the case and the petitioner has therefore been remanded to judicial custody.

4- That the petitioner has been framed up in the case because _____________ daughter of Sh. _________________ complainant was deeply in love with the petitioner and her marriage was solemnized with Sh._____________ son ofSh. ________________,R/o House No.___________________ against her wishes on __________. Even after marriage _____________ wanted the petitioner to continue friendly relationship with her due to attachment but the petitioner always advised her that since she has been married to another person, she should try to forget her past relationship with the petitioner.

5- That the investigation of the case and thereafter the trial shall take a considerable time and the petitioner shall suffer unbearable hardship of imprisonment if he remains confined to Jail during this period.

6- That the petitioner is ready and willing to furnish bail bonds to the satisfaction of this Hon’ble court for his being released on bail.

7- That the witnesses of the prosecution are relatives of the complainant and they can not be influenced by the petitioner. The petitioner gives an undertaking to the Hon’ble court, that if he is released on bail, he shall not temper with the evidence or influence the witnesses of the prosecution and he shall abide by any condition imposed by the Hon’ble court for releasing him on bail.

It is, therefore, prayed that the petitioner/applicant may kindly be released on bail.

Dated: _________ Applicant/petitioner.

Through counsel:
__________

___________, Advocates

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Witness Application

IN THE COURT OF ________________


__________ VS. ____________

SUIT FOR SPECIFIC PERFORMANCE

Application for summoning the witnesses and
Permission to deposit the expenses of Witnesses.

Sir,

The applicant/plaintiff respectfully submits as under: -

1- That the above noted petition is pending in this hon’ble court and is fixed for ___________. The applicant wants to summon the following witnesses for the date fixed: -

(i) _________________________ with the relevant record of cash order /pay order dated _____________ vide No. ___________ Branch Code _________

(ii) _____________________ with the record of Register of attestation of affidavits dated _______ of Shri __________ Son of Shri ___________, resident of ___________________

(iii) Record keeper of record room lower court with the record of case No. ______ of ____________ Year titled as “_____________ VERSUS ____________” decided on ______________ which was decided by Shri _____________________.

(iv) Shri _______________, Advocate, ________________.


Prayer:

It is, therefore, prayed that the above mentioned witnesses may kindly be summoned for the date fixed and the applicant/plaintiff may kindly be allowed to deposit the expenses of the witnesses before this hon’ble court.

Dated _______ APPLICANT /PLAINTIFF

Through counsel:


________________, Advocate, ___________________

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Recovery Suit, Recovery Suit Application Affidavit

In the Court of Hon’ble _____________-.
Civil suit No.____of _____Year
M/____________________________
Address_______________________ ,
…Plaintiff
Versus
M/s ______________________
Address_______________________ ,Principal occupier
…Defendant

SUIT FOR RECOVERY OF RS ________/- ALONGWITH INTEREST

Court Fee paid Rs.______/-

RESPECTFULLY SHOWETH:
1- That the plaintiff is a company under the name and style of M/s _________________________ and Mr. ______________ through whom the present suit is being instituted is the ___________________ of the plaintiff company and he has been authorized by the plaintiff vide Resolution dated __________ and he is fully competent to engage the counsel, sign the vakalatnama, plaint, application for stay, affidavit, applications etc. to depose before this Hon’ble court and to do such other acts, deeds and things. The copy of the Resolution is enclosed as Annexure –A.

2- That the plaintiff is engaged in the business of _______________________________.

3- That during the course of business with the defendant the plaintiff has done _____________________________. An agreement to this effect was executed between the plaintiff and the defendant on _____________. The plaintiff did the job work as per the satisfaction of the defendant. During the course of business the plaintiff issued proper bills to the defendant, which were accepted and acknowledged by the defendant. The copy of the Bill is enclosed as Annexure –B.

4- That as per the statement of account maintained by the plaintiff the balance amount of Rs. ________/- is outstanding against the defendant as on ______________ after receiving the last payment of Rs. ___________/- on ________________. The photocopies of Agreement and statement of account are enclosed.

5- That as per the terms and conditions of the Agreement the defendant have to make the payment of ___% on the delivery of the ____________, which was supplied to the defendant in time but the payment was not made by the defendant upto ____________. Thereafter so many requests were made to the defendant to make the payment so as the work could be done in time but the defendant failed to make the payment. It is no out of place to mention here that the work was delayed due to the reason known to the defendant. The defendant violated the terms and conditions of the Agreement.

6- That the account of the defendant became irregular and inspite of repeated requests and demands the defendant failed to regularize their account and also failed to make the payment in time.

7- That the plaintiff requested the defendant several times to make the payment of the outstanding amount which is lying against them but the defendant on one pretext or the other avoided to the legitimate requests of the plaintiff without any cause or reason and has stopped the payment of the plaintiff. In this contest the plaintiff has so many times orally and in writing approached the defendant to make the payment of the outstanding amount lying with the defendant. the notice was sent to the defendant by the plaintiff but the defendant failed to make the payment thereafter the and wrote a letter stating that the account of the plaintiff is debited with Rs. ______________/- without any reason. The defendant is trying to make liable the plaintiff for their wrongs. The defendant issued the same to cheat the plaintiff. The defendant are evading and neglecting the payment of the plaintiff with one false pretext or the other and with some ulterior purpose and motives therefore, the plaintiff can not trust on the defendant any more and cannot and cannot wait for an indefinite period hence they have been compelled to take efficacious legal action against the defendant.

8- That the account of the defendant become irregular and inspite of repeated requests and demands the defendant failed to regularize their account and also failed to make the payment in time.

9- That the plaintiff was induced by the defendant to believe in making false representations that they would honour the payment on receipt of the invoice but plaintiff realized letter that the intentions of the defendant was not clear and became decisive, the defendant after receiving the goods, converted the same in their own use and still the defendants have not paid the money to the plaintiff as assured by them.

10- That the defendant fraudulently and dishonestly induced the plaintiff to deliver their property and as such the defendant deceived the plaintiff and caused wrongful loss. The defendant were bound to protect the interest of the plaintiff but the defendants failed to do so hence the defendant have committed an offence punishable under section _______________ IPC and other provisions of the law.

11- That as per the initial terms and conditions settled with the defendant by the plaintiff, the plaintiff is entitled for an interest @ ___% per annum which is the prevailing rate in the market usage and is the banking rate of interest on outstanding. The plaintiff claims interest at the above rate from the defendant it became due till the date of realization.

12- That plaintiff served a legal Notice dated ____________ through registered post upon the defendant calling upon them to make the payment of Rs. ________/- along with interest @ __% per annum which was duly received by the defendant. On the receipt of this notice the defendant contacted with the plaintiff and demanded some time for making the payment because the defendant were facing some financial problems. But on ___________ refused to make any payment to the plaintiff.

13- That the cause of action to file the present suit accrued on each and every date when the plaintiff requested the defendant to make the payment of the outstanding amount due against the defendant. The cause of action further accrued on ____________ when the plaintiff sent a legal Notice to the defendant calling upon to make the payment of the plaintiff outstanding against the defendant. The cause of action finally accrued in favour of the plaintiff and against the defendant on _________ when the defendant refused to make payment of the same to the plaintiff. Hence _____________ is the final date of cause of action accrued in favour of the plaintiff and against the defendants. Hence this suit.

14- That the present suit being filed by the plaintiffs against the defendant is the first suit and no such suit has been previously filed, pending or decided by any court of law on the same subject matter.

15- That plaintiff and the defendant reside and the and entire cause of action also accrued between the parties at ____________, within the territorial jurisdiction of this Hon’ble court, therefore, this Hon’ble court has got the jurisdiction to entertain and try the present suit

16- That the value of the suit for the purposes of court fee and jurisdiction is assessed at Rs. ____________/- upon which Advolrum Court fee Stamp of Rs. ________/- has been affixed on the plaint.

PRAYER: It is, therefore, prayed that this Hon’ble court may graciously be pleased to pass

(i) a decree for recovery of Rs. ________/- alongwith interest @ __% per annum since _________ till upto date may kindly be passed in favour of the plaintiff and against the defendant

(ii) costs of the suit may be awarded in favour of the plaintiff and against the defendant

(iii) or any other relief which this Hon’ble court deems fit and proper may kindly be granted in favour of the plaintiff and against the defendant

PLAINTIFF
Through counsel:

_________, Advocate, ___________

VERIFICATION:
Verified that the contents of Paras No.___________ of the plaint are true and correct to best of my knowledge and Paras No. ___________ of the plaint are true to best of my knowledge and belief.

Verified at __________ on___________
PLAINTIFF

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Claim Petition Affidavit

Claim Petition under Section ______ of _________ for grant of Compensation of Rupees _________/-

Respectfully showeth: -

1. The above mentioned petitioner do hereby apply for grant of compensation on account of injuries sustained by the petitioner in accident caused by respondent no. 1, which took place on __________- at about _________. near ____________________, within the area of Police Station – _________ due to rash & negligent driving of ________________, who hit the petitioner from his back, resultant sustained multiple injuries including grievous on his person.

The necessary particulars in respect of the injured and vehicle etc. are given below: -

1- Name & Father’s Name _______________
of the person injured

2- Full address of the _________________
person injured. __________


3- Age of the person __________
injured.

4- Occupation of the person ______________
injured

5- Name & Address of the ___________________
employer of the person
injured

6- Monthly income of the person About _____________ Per Month
injured

7- Does the person in respect of _______________
whom compensation is claimed
pay income tax, if so, state the
amount of tax.

8- Place, date and time of On ___________ at about_________
accident. In front of ________________

9- Name and address of the police ______________________
Station in whose jurisdiction,
the accident took place or was
Registered

10- Was the person in respect of ______________-
whom compensation is claimed
traveling in offending vehicle
If so state the starting of his
Journey & destination

11- Nature of injuries ______________________

12- Name & address of the _________________
medical Officer who
attended the injured


13- Period of treatment and _____________________
expenditure, if any,




14- Registration no. & type of _____________________
vehicle involved in
accident.

15- Name & address of the owner _______________________
of vehicle.

16- Has any claim been lodged ______________________
with owner insurer

17- Relationship with injured ___________________________

18- Name & Address of the __________________
petitioner

19- Amount of Compensation. Rupees ____________/- Under Section
claimed _________________ Act.

20- Any other information that may be helpful necessary in disposal of claim petition
(I) That the petitioner- injured was coming with_____________ at about _____________ on _____________ and when reached ________________ then ______________________ driven by respondent no. 1 negligently, carelessly without obeying the traffic rules, without blowing horn without Appling over the brakes of the vehicle in question, directly hit the petitioner from behind, in result the petitioner fell. The accident was seen by ____________, who ______________ and was brought, in ___________ Hospital.

(II) That the statement of the petitioner was recorded in _____________ by the police and a criminal case vide F.I.R. no. _____________ I.P.C. was Registered on ______________ on the statement of petitioner in respect of the accident taken place as stated above.

(III) That the petitioner is a man/women of approximately______ years of age, prior to this accident was running _____________ and earning more than Rupees ________/- per month and impressed every one who came into his hospitality and after the accident has become unemployee, confined to the bed and in future unable to walk and to do any hard work, even to run his business like previously but has come in a debt due to spending a huge amount over the treatment i.e. medicine, traveling, nursing aids etc., even have become unfit from his mind, unable to understand any thing properly and fully dependent over other family members, the life of the petitioner has sunk in a pool, in black dark as a life fully handicapped as beggar.

(IV) That the accident was caused due to reckless, careless, negligent, without obeying the traffic rules and without applying over the brakes of ________________________ in result the petitioner sustained grievous multiple injuries on his person.

(V) That the respondents are liable to pay compensation to the petitioner jointly and severally, being owner, driver, insurer of vehicle in question.

(VI) The accident taken place, the petitioner and respondent no. 1 is residing, cause of action accrued with in territorial jurisdiction of this tribunal, hence this tribunal has got jurisdiction to register, try, entertain and decide the instant petition.

(VII) That no other petition is pending or decided between the same parties regarding the same subject matter.

(VIII) That a proper court fee as per law has been affixed.
Prayer: -
It is therefore most respectfully prayed that the petition of the petitioner may kindly be accepted with cost and awarded for Rupees _______________/- under section _________________ Act with interest @ 18% per annum form the date of accident till payment, may kindly be passed in favour of the petitioner and against the respondents jointly and severally.
Or any other relief, which this Hon’ble tribunal deems fit and proper in the eyes of law, circumstances of petition on adducing evidence also be passed in favour of the petitioner and in the interest of justice.

Petitioner
Through Counsels: -
_______________________ ____________________________

VERIFICAITON: -
Verified that each and every contents and averments mentioned hereinabove have been read over and explained to me by my engaged counsels in Hindi, same are true and correct to the best of my knowledge and belief and nothing has been concealed therein.
Verified at _________________ on _______________


Petitioner

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PERSONAL LOAN

UNDERTAKING PERSONAL LOAN

I, ___________ son of Shri __________ R/o________________ employed as _____________ in __________________ have applied for a personal loan for Rs. ________/- (Rupees ____________ only)
I hereby authorize the company to deduct the monthly installments (EMIs) from my salary each month

In the event of my termination/resignation from the company before full payment of the loan amount, I hereby authorize deduction of the full outstanding balance of my personal loan, if any, from my Full & Final entitlements, including Gratuity, Leave Encashment and Bonus etc. failing which my Cheque No.________dated ______drawn on _____________________ may be encashed for the balance outstanding.



SIGNATURE OF EMPLOYEE

Place :
Dated __________


Witnesses
1.

2.

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LEASE AGREEMENT

LEASE AGREEMENT

This Rent agreement is hereby executed at _______________ on this ____ day of __________ between:

Smt. _______________ wife of Shri ______________, resident of ____________________ ( hereinafter referred to as First party/landlady) which expression shall mean and include her heirs, successors, legal representatives and assigns etc.

AND

M/S ___________________, vide Ends No. Filed No_______ dated ___________, at ___________________ having its India Office _________________________ INDIA through its President Mr. ______________ (hereinafter called the tenant/Second party) of the other part, which expression shall mean and include his heirs, successors, legal representatives and assigns etc.

Whereas the first party is owner in possession, of residential House No. ___________________ and is interested to let out basement of the said house to the second party on the monthly rental basis on the following terms and conditions :-
NOW THIS AGREEMENT WITNESSETH AS UNDER: -
1- That the rate of the rent of the said premises is settled at Rs. _______/-(Rupees __________ only) per month exclusive of water, electricity and other incidental charges.
2- That the second party will pay the rent on each and every 7th day of English calender month in advance.
3- That the tenancy will be commenced from ____________ and shall remain enforced for the period of __ years.
4- That the second party has deposited the three months advance security of Rs. __________/- with the party of the first party and this amount will be adjusted in the future arrears of rent.
5- That the rent of the rented premises shall be increased @ 5% per annum
6- That the second party shall use the said premises for the purpose of providing coaching classes for the students.
7- That the second party shall not sublet, part with possession assigned the same to any person in any manner whatsoever.
8- That in case the second party fails to pay the monthly rent to the first party consequently for the period of two months, then the second party shall have to get vacated the premises in question immediately.
9- That the second party will himself affix the furnitures and fittings in the rented premises.
10- That the second party shall not make/raise any constructions as well as alteration in the rented premises without the written consent of the first party.
11- That the second party shall permit the first party or any of his authorized person to enter the said premises at reasonable time for inspection purpose.
12- That the second party will not vacate the said rent premises upto the minimum period of one year in any manner
13- That both of the parties shall have to give three months advance notice in writing to each other , in case of vacating the premises in question before the expiry period of the tenancy.
14- That the terms & and conditions as stated above shall be binding on the both parties. The terms and conditions of this agreement are final and are irrevocable.

IN WITNESSES WHEREOF, the parties have signed this agreement on the date, month and year first above written in the present of witnesses at ___________.

WITNESSES:- FIRST PARTTY
1-

2- SECOND PARTY

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Partnership Deed

Partnership Deed

This Deed of Partnership is executed at _________ on _____ day of _________ between :-
1- ______________ son Shri ___________ resident of ________________ (hereinafter referred to as the First Party/First Partner, which expression shall include his heirs, executors, legal representatives, administrators and assignees) of the one part and
AND
2- Shri _____________ son of Shri _____________, resident of village ___________________ (hereinafter referred to as the First Party/Second Partner, which expression shall include his heirs, executors, legal representatives, administrators and assignees) of the Other Part.

WHEREAS the parties referred hereinabove wants to carry on a partnership business of ________________ Under the name and style of M/s ______________, at __________________ Under the following terms and conditions set forth herein below :-
1- That the name and style of the Partnership firm shall be /s ______________, at _____________.
2- That the partnership shall be at Will.
3- That the business of Partnership shall be carried out __________ or such other place or places as agreed upon by both the partners.
4- That the capital of the firm shall be contributed by the partners to this deed or raised through the loan as agreed upon by both the parties.
5- That the share of the profit and loss of the partnership shall be as follows :-
i) _____________ 50%
ii) _____________ 50%
6- That both the partners shall operate upon the business account of the firm.
7- That the first partner Mr. ______________ will get monthly working salary of Rs. ___________/- per month.
8- That the account of the firm shall be closed on 31st day of March every year. Immediately after signing the accounts each partner shall be entitled to draw out and receive his share of profit and loss of the business for that year.
9- That if any partner opts to retire from the partnership business he may give one month notice thereof in writing to the other partner. The account of the outgoing partner shall be settled as per the terms and conditions of this deed and the amount of profit and loss shall be paid to him within the period of 3 months from the date of retirement.
10- That such outgoing partner shall not use the name of the firm and shall not solicit any of the customer of the partnership nor carry on any such type of business similar to that the partnership within the period of 2 years.
11- That if any dispute arising out of this partnership business shall be only triable by the __________ courts .
In witness whereof both the partners have set their hands on this Partnership Deed at ____________ on this day , month and year first mentioned above in the Presence of marginal witness .

WITNESSES:

1-
First Party/First Partner



2-
Second Party/Second Partner.

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LOAN AGREEMENT

LOAN AGREEMENT

This Agreement is made at ____________ on this ___ day of ______________ , between :- Mr. ________ resident of _______________ (hereinafter called the Part of First PART )

AND

_____________ S/o _______________ R/______________________ hereinafter called the party of the second part)

WHEREAS the second party is in need of money and is having friendly term with the party of the first part and requires a sum of Rs. ____________/- (Rupees Seventy Five thousand only)

AND WHEREAS, the first party has agreed to give the said loan amount to the party of the second part and in lieu of this payment this receipt cum agreement is being executed between the parties.

AND WHEREAS, in lieu of repayment of the loan amount the second party has issued a post dated Cheque bearing its No. _______ dated __________ for Rs. ________/- drawn on _________ Bank, _______ from his saving Account No. ________

If the above mentioned Cheque would not encashed on its presentation then the first party shall have right to file a Criminal complaint under section 138 of the Negotiable Instruments Act and under section 420 of IPC and the first party shall have also right to launch other criminal proceedings as well as civil proceedings against the second party and the second party shall be fully responsible for the same.

In witnesses whereof the parties of this agreement have set their respective hands on the date month and year first above given.
WITNESES :-

1. FIRST PARTY


2. SECOND PARTY

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RENT AGREEMENT

RENT AGREEMENT


This Rent agreement is hereby executed at ____________ on this ________ day of ___________ between:

________________ son of _________________ R/o ______________________ ( hereinafter referred to as First party/landlord) which expression shall mean and include his heirs, successors, legal representatives and assigns etc.

AND

_________________ son of _________________ , resident of _________________________________ (hereinafter called the tenant/Second party) of the other part, which expression shall mean and include his heirs, successors, legal representatives and assigns etc.

Whereas the first party is owner in possession, of residential House of Flat No. _____________________________________ and he has agreed to let out the said flat as monthly rent basis to the second party /tenant




NOW THIS AGREEMENT WITNESSETH AS UNDER: -

1- That the rate of the rent of the said premises is settled at Rs___________/-(Rupees Seven thousand only) per month exclusive of water, electricity and other incidental charges.
2- That the tenancy shall be effective from 1st day of _______________ and shall remain enforced for the period of 11 months.
3- That the second party has deposited a sum of Rs. ____________/- (Rupees __________ only) as the security amount, which will be refunded /adjusted at the time of vacating the said premises.
4- That the second party shall use the said premises for the residential purpose.
5- That the second party shall not sublet, part with possession assigned the same to any person in any manner whatsoever.
6- That in case the second party fails to pay the monthly rent to the first party consequently for the period of two months, then the second party shall have to get vacated the premises in question immediately.
7- That the second party shall pay the electricity charges as per the bills raised by the ___________.
8- That the second party shall not damage the fittings and fixtures fitted in the rented premises and shall keep and maintain the same in good condition and shall also make arrangements for the repairs or replacements of the damaged fittings and fixtures whatsoever, will be required at his own expenses.
9- That the second party shall not make/raise any constructions as well as alteration in the rented premises without the written consent of the first party.
10- That the second party shall permit the first party or any of his authorized person to enter the said premises at reasonable time for inspection purpose.
11- That both of the parties shall have to give one month advance notice in writing to each other , in case of vacating the premises in question before the expiry period of the tenancy.
12- That the terms & and conditions as stated above shall be binding on the both parties. The terms and conditions of this agreement are final and are irrevocable.

IN WITNESSES WHEREOF, the parties have signed this agreement on the date, month and year first above written in the present of witnesses at _____________.

WITNESSES:- FIRST PARTTY
1-

2- SECOND PARTY

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DEED OF ADOPTION BY A WIDOW

DEED OF ADOPTION BY A WIDOW
( See Hindu Adoption and Maintenance Act.1956)

This Deed of adoption made this day of Between ____________ Aged ____ years Son of ___________ & _________ Aged ____ years, wife of _________ (daughter/ Son of __________ ) by caste ________ R/o________________________________ Hereinafter called the “ Giver” of the first part and _______________ age ___ years, Widow of ________________ R/o ___________________, by caste ___________ herein after called the “ Recipient” of the second part.
Whereas the said _________ died on ___________ leaving him surviving the recipient as his soles widow and without any son being born to him.

And whereas in the circumstance and there having none to continue the lineage of the deceased and/ or secure spiritual benefit and/or maintain PINDA relationship and perform other religious obsequies to his departed soul and that of his deceased ancestors the recipient desires to take the son the giver named ___________ at present age ______ years his date of birth __________ being (Bland) in adoption he having had and borne all the reflection of a natural born son.

AND WHEREAS THE USUAL CEREMONAY AS TO Dattak Homan Physical delivery of the child and the ceremonial gift as to taking the boy, where performed on the ___________ in the presence of several persons including those who are attesting witness.

:: 2 ::

And Whereas ever since the said adoption the said _____________ has been to all intents and purposes treated as a member of the family of the recipient.

NOW THEREFORE THESE PRESENTS WITNESS AND IT IS hereby agreed and declared as follows :-
The giver has given in adoption his son named _______________ to the recipient and the recipient has duly taken him in adoption and make him/her son, that is to say, son of her husband.

All necessary ceremonies including Dattak Homan and Physical delivery of the child from hand to hand have been observed and performed by either party on the_________ AND THESE PRESENTS FURTHER WITNESS and it is hereby agreed and declared by and between the parties hereto that the said ______________ has according to the Sastras and law become by virtue of the adoption aforesaid a son of ______________ (_______________) capable of performing the religious duties to his adoptive father with all rights and obligations of a natural born son is so entitled to inheritance and succession of all the persona and real estate of the deceased and of the recipient both ex paternal and ex maternal to all intents and purposes AND THIS INDENTURE ALSO witnesses that ever since the above adoption has been effected the said ______________ has renounced and abandoned the use of his original surname _____________ and in lieu thereof assumed and adopted the surname ___________ AND that of the recipient shall at all times hereafter in all records, deeds, documents and other writings use and subscribe the surname of the recipient and shall accordingly be knowns, described and addressed as the son of the recipient.

:: 3 ::

IN WITNESSES WHEREOF the parties hereto have hereunto set and subscribed their respective hands and seals the day, month and year first above written.

Signed, sealed and delivered by the within named parties at _____________ on dated____________ in the presence of following witnesses.


Signature of Giver/first party Signature of Recipient/Second party

Witnesses :-
1.

2.

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