A Suit for Recovery of Possession and Money Claim

Updated at:March 2010
 
FREE EXCERPT

IN THE COURT OF THE SMALL CAUSES JUDGE,................

AT................

Civil Suit No._______________________________________________ / 200_

Shri____________ L____ N___ D_______________)

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

Versus

Shri __T__N__T______________)

age..... years, occupation..........,) DefendantAddress......................................................)

A SUIT FOR RECOVERY OF POSSESSION AND MONDY CLAIM

The plaintiff abovenamed 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 3..... sft situate on the ground floor in the old building standing at CTS No. 2..... of...................................... City.

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

  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 has not paid the amount of monthly rent from................ 200_., and thus, he has become a defaulter within the meaning, provision and interpretation of the Maharashtra Rent Control Act 1999.

  6. That the defendant without the consent of this plaintiff also erected a permanent structure in the suit premises by providing a wall.

  7. That the defendant has already acquired a spacious flat in the................. Cooperative Housing Society at................., and the defendant has shifted his residence there and kept the suit premises duly locked for more than two years.

  8. That there are as many as twelve members in the family of the plaintiff, and since the premises in possession of the plaintiff are inadequate and insufficient, he requires the suit premises for his personal bonafide occupation.

  9. That the plaintiff served upon the defendant a notice, on__________________ calling upon him to vacate the premises and hand over vacant and peaceful possession thereof unto the plaintiff, but the defendant refused to do so, and hence, this suit.

  10. That the defendant has also been very irregular in making the payment of monthly rent, and sometimes he pays the rent occasionally or for a period...

To continue reading

REQUEST YOUR TRIAL