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In The Hon'Ble Court of - Delhi

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15 views

In The Hon'Ble Court of - Delhi

Uploaded by

harpreet
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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IN THE HON’BLE COURT OF ________

DELHI

Civil Suit no._________

IN THE MATTER OF:

Sushant …PLAINTIFF

VERSUS

Neha …DEFENDANTS

SUIT FOR EVICTION AND RECOVERY OF DAMAGES/MESNE

PROFITS.

MOST RESPECTFULLY SHOWETH:

1. That the Plaintiff had been married to the Defendant i.e Neha. Their

marriage got disputed due to certain factors and the defendant i.e.

Neha decided to move out and live separately in another alternate

accommodation.

2. It is humbly submitted upon the honourable court that the plaintiff is

the legal, actual, rightful and exclusive owner of the property

bearing House no. H-608, SUNCITY AVENUE, 102, SECTOR 102,


Gurugram , admeasuring _ sq. mtrs. i.e. ½ share of 83.62 sq. mtrs.,

hereinafter referred as ‘Suit property’.

3. It is humbly submitted upon the honourable court that plaintiff had

been paying the EMI of the said suit property. Documents Pertaining

to the payment of the EMI are annexed herewith. (Annexure- )

4. It is humbly submitted upon the honourable court that the

defendant had stolen the keys of the said suit property in question

and was living there without the permission of the plaintiff who has

been paying the EMI of the said suit property in question.

5. It is humbly submitted upon the honorable court that the plaintiff

had asked the defendant to vacate the said property on several

occasions but the defendant clearly denied to do the same.

6. That the defendant clearly is liable for trespassing the said suit

property in the absence of the plaintiff

7. That the cause of action first arose when the defendant went into

said suit property at first for living by stealing the keys of the said

suit property from the plaintiff.

8. That when the plaintiff countered the defendants, the defendant had

no reply.

9. That this caused a lot of mental agony and harassment for the

plaintiff.

10. That when despite repeated requests, reminders, visits,

demands and service of legal notice the defendants have failed to

evict the suit property and pay damages and that too without any

reason, cause or justification, the plaintiff was left with no other


alternative except to approach this Hon'ble court by virtue of instant

suit.

11. That cause of action for filling the present suit arose in favour

of plaintiff and against the defendant on all those dates when

defendant failed to evict the suit property, despite plaintiff’s

requests and visits then on ________when by virtue of legal notice

the license of defendants to enjoy the suit property was terminated

but they are still in the possession and had failed to vacate the

same. The cause of action therefore still subsists and is continuing.

12. That the Suit property is situated within the prescribed

territorial jurisdiction of this Hon'ble court therefore this has got the

jurisdiction to entertain and try the present suit.

13. That the valuation of the suit for the purpose of jurisdiction

and court fee for the relief mandatory and permanent injunction is

Rs. _________each and for the purpose of recovery of damages is Rs.

________The requisite court fee is been affixed along with the plaint.

14. That this Hon'ble Court has got the pecuniary jurisdiction to

entertain and try the instant suit.

15. That present suit has been filed within the statutory period of

limitation.
PRAYER:-

The plaintiff therefore prays that the Hon'ble Court may be pleased

to grant a decree for vacant possession of the plaint schedule

property after ejecting the defendant from the plaint schedule

property and award future profits and award costs and such other

relief as the Hon'ble court deems fit and proper in the circumstances

of the case.

Be pleased to consider,

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