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easy sample draft for recovery of money & ejectment

The document contains two hypothetical legal drafts: one for a suit for recovery of money where Mr. Rajesh Verma seeks ₹5,00,000 from Mr. Amit Sharma due to non-repayment of a loan, and another for a suit for ejectment where Mrs. Sunita Gupta seeks to evict Mr. Rakesh Mehta from her leased shop after the lease expired. Both drafts outline the parties involved, the nature of the claims, and the prayers for relief to the court. The suits are structured according to legal formalities and include necessary details such as dates and amounts.

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Saumya Patel
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14 views3 pages

easy sample draft for recovery of money & ejectment

The document contains two hypothetical legal drafts: one for a suit for recovery of money where Mr. Rajesh Verma seeks ₹5,00,000 from Mr. Amit Sharma due to non-repayment of a loan, and another for a suit for ejectment where Mrs. Sunita Gupta seeks to evict Mr. Rakesh Mehta from her leased shop after the lease expired. Both drafts outline the parties involved, the nature of the claims, and the prayers for relief to the court. The suits are structured according to legal formalities and include necessary details such as dates and amounts.

Uploaded by

Saumya Patel
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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Sample draft based on the formats of "Suit for Recovery of Money" and "Suit for Ejectment"

Hypothetical Situation 1 (Suit for Recovery of Money)

Mr. Rajesh Verma, a businessman from Delhi, lent ₹5,00,000 to his acquaintance, Mr. Amit Sharma,
on 1st January 2023 through a promissory note. Despite repeated reminders and demands, Amit
Sharma has failed to repay the amount. After serving a legal notice, which was ignored, Mr. Verma
now seeks legal recourse.

Suit for Recovery of Money under order xxxvii of cpc,1908

IN THE COURT OF THE CIVIL JUDGE, DELHI

Suit No. ______ of 2024

Suit under order xxxvii of cpc,1908

IN THE MATTER OF

Mr. Rajesh Verma


S/o Late Sh. Ramesh Verma
R/o 56, Connaught Place, New Delhi – 110001 …Plaintiff

Versus

Mr. Amit Sharma


S/o Sh. Suresh Sharma
R/o 22, Lajpat Nagar, New Delhi – 110024 …Defendant

Suit for Recovery of ₹5,00,000/- along with interest

The Hon’ble Court is most respectfully submitted as under:

1. That the plaintiff is a reputed businessman engaged in trading, and the defendant is an
acquaintance who had approached the plaintiff for a financial loan.

2. That on 1st January 2023, the plaintiff lent an amount of ₹5,00,000/- to the defendant, which
was executed through a promissory note duly signed by the defendant, acknowledging the
debt.

3. That the defendant had agreed to repay the amount within six months, i.e., by 1st July 2023,
along with an interest of 12% per annum.

4. That despite repeated reminders and a legal notice dated 15th August 2023, the defendant
has failed to make the payment.

5. That the plaintiff, having no other alternative remedy, is constrained to approach this Hon’ble
Court for the recovery of ₹5,00,000/- along with interest @12% per annum from the due
date till realization.
Prayer:
It is, therefore, most respectfully prayed that this Hon’ble Court may kindly pass a decree in favor of
the plaintiff and against the defendant for:
a) Recovery of ₹5,00,000/- along with interest @12% per annum from 1st July 2023 till realization.
b) Costs of the suit.
c) Any other relief that this Hon’ble Court deems fit and proper in the interest of justice.

Place: Delhi
Date: //2024 Plaintiff - Rajesh Verma
Through Advocate

VERIFICATION

Hypothetical Situation 2 (Suit for Ejectment)

Mrs. Sunita Gupta, a landlord in Mumbai, leased her shop to Mr. Rakesh Mehta for a period of three
years, ending on 31st December 2023. The lease agreement clearly stated that upon expiry, the
tenant must vacate the premises. Despite repeated requests, Mr. Mehta refuses to vacate and is
unlawfully occupying the premises.

Draft: Suit for Ejectment

IN THE COURT OF THE CIVIL JUDGE, MUMBAI

Suit No. ______ of 2024

Mrs. Sunita Gupta


W/o Late Sh. Mohan Gupta
R/o 78, Andheri West, Mumbai – 400058
…Plaintiff

Versus

Mr. Rakesh Mehta


S/o Sh. Sohan Mehta
R/o 14, Bandra East, Mumbai – 400051
…Defendant

Suit for Ejectment of the Defendant from the Suit Premises

The Hon’ble Court is respectfully submitted as under:

1. That the plaintiff is the lawful owner of the commercial premises situated at Shop No. 12,
Andheri West, Mumbai, which was leased to the defendant under a registered lease
agreement dated 1st January 2021 for a period of three years.

2. That as per the lease agreement, the tenancy expired on 31st December 2023, and the
defendant was required to vacate the premises.
3. That despite repeated verbal and written notices, including a legal notice dated 15th January
2024, the defendant has unlawfully continued to occupy the premises.

4. That the plaintiff requires the premises for her personal use and has suffered financial losses
due to the illegal occupation of the defendant.

5. That the defendant has no legal right to remain in possession, and his continued occupation
amounts to trespass.

Prayer:
It is, therefore, most respectfully prayed that this Hon’ble Court may kindly:
a) Pass a decree directing the defendant to vacate and hand over peaceful possession of Shop No.
12, Andheri West, Mumbai, to the plaintiff.
b) Grant mesne profits of ₹50,000/- per month for the period of illegal occupation from 1st January
2024 till the defendant vacates the premises.
c) Grant costs of the suit.
d) Pass any other relief that this Hon’ble Court deems just and proper in the circumstances of the
case.

Place: Mumbai
Date: //2024

Plaintiff
Sunita Gupta
Through Advocate

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