PLEADING

• PLAINT
• WRITTEN STATEMENT
PLAINT
• The plaint shall contain the following particulars :-
(a) the name of the Court in which the suit is
brought;
IN THE COURT OF THE SMALL CAUSES JUDGES AT BOMBAY
Suit No.________Of 20____________
(b) the name, description and place of
residence of the plaintiff;
(Between)

John Smith
S/o William Smith
Aged about 38 Years
R/o or Residing at – Street No. 21, Churchill Lane,
Mumbai …Plaintiff
 v.
(versus)
Or
(And)
(c) the name, description and place of residence
of the defendant, so far as they can be
ascertained;
Gregory Paul
S/o James Paul
Aged about 39 Years
R/o or Residing at – Flat No. 7, Thakur Niwas, Nanpura, Mumbai
…Defendant
Nature or class of suit and amount of claim
SUIT FOR EJECTMENT OF THE TENANT

(Plaint filed under Section …. read with order …., Rule ….of CPC)
The body of the plaint
The plaintiff begs to state as under that:
The plaintiff is a landlord of “ Thakur Niwas” situated at Nanpura,
Mumbai. The plaintiff knows the defendant for the last (seven) years as
his tenant in respect of Flat No. 7 in “Thakur Niwas” at Nanpura,
Mumbai. The defendant is the plaintiff’s monthly tenant in respect of
the said flat at a rent of Rs. …………….
The defendant has been paying the rent regularly to the plaintiff. But
the defendant failed to pay the rent to the plaintiff since ………(month
and year) and hence he is in arrears of rent amounting to Rs………….for
………… months at the rate of Rs. …………..
The defendant has also constructed a partition brick wall in the hall of
this flat without the prior consent of the plaintiff and the partition wall
has devalued the hall.
The plaintiff has got a very large family and the said flat is badly needed
to accommodate the members of his family for their bona fide use.
The plaintiff has verbally requested the defendant to quit, vacate and
hand over the possession of the said flat to the plaintiff but he has
failed and neglected to do so. The plaintiff, finally, called upon the
defendant by his advocate’s letter dated ……………… . A copy of the said
letter is annexed hereto and is marked as Annexure A to the plaint.
Cause of Action
The cause of action arose when the defendant made default in
payment of arrears of rent and also made an unauthorised structure in
the premises.
Jurisdiction
The suit premises are situated within the jurisdiction of this
Honourable Court and , therefore, this Court has jurisdiction to try and
entertain this suit.
Valuation of the Suit
The plaintiff values the suit at Rs………. for the purposes of court fees
and jurisdiction.
Claim
The plaintiff, therefore, prays that:
a. The Honourable Court be pleased to order the ejectment of the
defendant.
b. A decree for arrears of rent of Rs. …… be made against the
defendant in favour of the plaintiff.
c. Costs of the suit.
Plaints drawn by

Sd/- Sd/-
Advocate for the plaintiff Plaintiff
Verification
Verification

I, s/o …………, residing as above, do herby solemnly declare and

state that the contents of paras 1 to …. of the plaint are true to my own
knowledge and the contents of remaining paras are based on
information received and I believe the same to be true.
Solemnly affirmed as aforesaid at Mumbai.
Dated ……….. Sd/-
Plaintiff