A Suit for Recovery of Possession and Arrears of Rent

Updated at:March 2010
 
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IN THE COURT OF THE SMALL CAUSES JUDGE,................. AT.................

Civil Suit No. _/ 200_Smt _M_V_D_)

age...... years, occupation................) PlaintiffAddress........................................................)

Versus

Shri _V_M__L_)

age...... years, occupation -................) Defendant

Addreess.....................................................)

A SUIT FOR RECOVERY OF POSSESSION AND ARREARS OF RENT

The plaintiff above named submits this plaint, praying to state as follows:

  1. Description of Suit Property: All that piece and parcel of premises consisting of three rooms along with attached sanitary block totally admeasuring.......... sft situate on the ground floor in the old building standing at CTS No...........of Rasta Peth,................. City.

  2. That the property fully described in para 1 above is owned by the present plaintiff, and the defendant is a monthly tenant therein.

  3. That the month of tenancy is according to the English calendar, commencing on the first day in a month and ending on the last day of the same month.

  4. That the monthly rent for the suit premises is @ Rs........../- exclusive of all other charges and taxes.

  5. That the defendant was irregular in making the payment of the rent from the beginning, and on that account, the plaintiff had previously filed a civil suit against the defendant for possession in the Small Causes Court,................., and eventually the said suit came to be compromised. In that suit, the defendant had given in writing an undertaking that he would be paying the rent regularly, i.e. month to month basis.

  6. That irrespective of that, the defendant is irregular in the payment of rent and is in the habit of paying the rent occasionally and pays the rent for a period of........ months or sometimes even 8/9 months also. Thus, the defendant has become a defaulter in the payment of rent, as he failed to observe the terms and conditions of the compromise arrived at by and between the parties in the previous civil suit No. 420/1996.

  7. That the defendant is occupying the suit premises for the last thirty years, and from the beginning, he using the suit premises in such a fashion so as to cause damage and waste to the said property. Of the late, the defendant has demolished the wall between the two rooms, and he has fixed a door. He has also demolished another wall and fixed a window therein. While doing so, he has not obtained any permission of the plaintiff. Thus, the act of...

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