SUIT FOR DAMAGES ON AN INDEMNITY BOND[CD1]
IN THE COURT OF THE ........
Suit No. ................... of 20........
C.D..................................... Plaintiff
versus
C.F.....................................
Defendant
The
abovenamed plaintiff most respectfully submits as under:
1.
That
the plaintiff purchased the Bhumidhari Land of Khata No. ....................
situate at village .................... of Tahsil .................... District
.................... of ....................on .............. 20
..................... from E.F. for Rs. ................. through a registered
sale deed executed on ....................20 ....................
2.
That
while purchasing the land aforesaid, the defendant executed an indemnity bond
to the effect that the land aforesaid is free from any encumbrance, and if
anything is found due to the land, the defendant would satisfy the damages so
caused to the plaintiff.
3.
That
after purchase of the aforesaid land, the plaintiff was demanded
Rs..................... as arrears of electricity consumed for the tubewell,
and the amount of Rs. ................... on account of a simple mortgage of
the same land executed on ................. 20 ..................... in favour
of XY. The plaintiff had to pay the electricity charges aforesaid as land
revenue to the Electricity Board, and Rs. .............. to XY for the
satisfaction of the simple mortgage mentioned above.
4.
That
cause of action arose on ... .............. 20 ..................., when the
plaintiff had to pay the electricity charges, arrears and on
................... when the plaintiff had to pay Rs. ........... in
satisfaction of the mortgage aforesaid, and this Court has jurisdiction to
decide the suit.
5.
That
the suit is valued at Rs. .................... the amount of the electric
charges plus the amount paid in satisfaction of the mortgage aforesaid, a is
paid on the said amount.
RELIEF CLAIMED[CD2]
The
plaintiff claims Rs. .................. from the defendant as damages on
account of payment of electricity charges and the amount of the said mortgage
and interest from the date of filing the suit till payment thereof.
Plaintiff
Through
Advocate
I, abovenamed plaintiff, do hereby
verify that the contents of paras ................... to ................... of
the plaint are true to my personal knowledge and the of paras
...................and ................... thereof are based on legal advice which
I believe to be true.
Verified on this ................ day
of ................... 20 .................. at ......
Plaintiff
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