Model - Plaint 1

Model-I
In the court of the civil judge,Bangalore
Suit No………..of 20……..
A,son of …………residing at ………Plaintiff.
B,Son of…………residing at …………..Defendant.
Plaint under section 26 read with Order VII Rule 1 of Civil Procedure Code 1908
1. The address of the plaintiff for the purpose of service of summons……

2. The address of the Defendants for the purpose of service of summons…
3. The Plaintiff hereby humbly submits as follows:
4. The Plaintiff is the owner of House No…………..the boundaries whereof are
given at the end of the plaint.
5. The above mentioned house has a window at its east.
6. The plaintiff has been peacefully and legally without any interruption
enjoying as an easement ,free light and air through the aforesaid window
for the last 20 years until the date of obstruction mentioned herein.
7. The defendant erected a huge wall of 12 feet height on the west of his
house No:…….The wall has closed the window aforesaid and has therefore
completely obstructed the passage of air and light to the said house
through the said window.
8. The house has become unfit for comfortable and healthy living due to no
light and ventilation.
9. That due to the said obstruction the market value of the said house has
come down to Rs 60,00,000/-( words) as against the previous value of Rs
80,00,000/-( words)
10.The cause of action arose on …………when the defendant erected the above
mentioned wall.
11. The suit is valued at Rs 20,00,000/-( words) being the loss occasioned to
the plaintiff by the deterioration in the value of the plaintiff’s house due to
the aforesaid construction.
12.The plaintiff submit that there is no other civil case pending against the suit
schedule property in any other civil court for the same cause of action.
13.The suit is within the local limits of the jurisdiction of this court.
PRAYER
The plaintiff prays that
I) A mandatory injunction to the defendant to demolish the portion of the

wall which obstructs the passage of light and air to the aforesaid house
of the plaintiff.
II) Permission to demolish the above mentioned wall on the event of the
defendant’s failure to do so.
III) If the wall demolished by the plaintiff,the cost of demolition to be added
to the decree in favour of plaintiff.
IV) Any other relief that the Honourable Court deems fit and proper to
render justice.
Sd Sd
Advocate for plaintiff Plaintiff
VERIFICATION
I ,A….Verify that the facts stated in Paragraph 1 to 4 of the above plaint are true
to the best of my personal knowledge and belief and the contents of paragraphs 5
to 7 are believed by me on information received,to be correct.
Verified at Bangalore this …..day of ….20…..

Sd
Plaintiff
SCHEDULE OF THE PROPERTY
(Describe district ,nature of property,boundaries,extent etc)
East:
West:
North:
South:
LIST OF DOCUMENTS
1.
2.
VERIFICATION
I,A….the plaintiff,herein declare that that the description of property as stated

above is true to the best of my knowledge and belief.
Dated this the …….day of ……20…
(signature)
Plaintiff
In the court of the civil judge,Bangalore
Suit No………..of 20……..
Plaintiff .A
Defendant. B
AFFIDAVIT
I, A,son of …………………………………..do hereby solemnly affirm and state as follows:-
I am the Plaintiff in the above matter and I am well acquainted with the facts of
the case.
I submit that ,the averments made therein may be read part and parcel of this
affidavit also.
I also submit that what is stated in paragraphs 1 to 7 ,are true to the best of my
knowledge ,information and belief.I have signed this affidavit.
Identified by me
Sworn to before me Deponent
Advocate
Bangalore
Date
A notice of tenant on behalf of his landlord.
Under instructions from my client,……………I have to address you as follows:
1. That the property bearing number……………….is owned by my client.

2. That in the said property you are a monthly tenant occupying…………….
3. That the month of your tenancy is according to the English calendar………
4. That the monthly rent for the premises…………………………………….
5. That since the month of February ,you have not paid the rent to my client
and you are a defaulter ………………..
6. That you have purchased a spacious residential apartment…..
7. …….
8. ……..
9. That in the circumstances ,my client does hereby terminate your
tenancy,and you are, therefore hereby called upon to vacate the premises
and handover vacant and peaceful possession thereof to my client by the
end of June 20…..failing which my client will be constrained to take against
you an appropriate legal action and the costs and consequences thereof.
Your Faithfully,
Advocate

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Model-I

In the court of the civil judge,Bangalore

Suit No………..of 20……..

A,son of …………residing at ………Plaintiff.

B,Son of…………residing at …………..Defendant.

1. The address of the plaintiff for the purpose of service of summons……

The plaintiff prays that

I) A mandatory injunction to the defendant to demolish the portion of the

Advocate for plaintiff Plaintiff

Verified at Bangalore this …..day of ….20…..

SCHEDULE OF THE PROPERTY

(Describe district ,nature of property,boundaries,extent etc)

I,A….the plaintiff,herein declare that that the description of property as stated

Dated this the …….day of ……20…

Suit No………..of 20……..

I, A,son of …………………………………..do hereby solemnly affirm and state as follows:-

Sworn to before me Deponent

A notice of tenant on behalf of his landlord.

Under instructions from my client,……………I have to address you as follows:

1. That the property bearing number……………….is owned by my client.

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