In
the Court of ......................................
kk………………………………..………….. resi……………………………
...................... Plaintiff
against
GM…………………………..…………….. resi……………………………….
.................... Defendant
KK………………………………………………………………..…..., the
above-named plaintiff, states as follows:-
1. He
is one of the trustees under an instrument of settlement bearing date on or
about the ……...... day of………………..... made upon the marriage of
……..….KM………………... and HH…………..……..., the father and mother of the defendant [or
an instrument of transfer of the estate and effects of KM……………... for the
benefit of ………. the defendant, and the other creditors of……………………….….
KM………………………….…..].
2. KK…………………..……...
has taken upon himself the burden of the said trust, and is in possession of
[or of the proceeds of] the movable and immovable property transferred by the
said instrument.
3. GM…………………………………...
claims to be entitled to a beneficial interest under the instrument.
[i. Facts showing when the cause of
action arose and that the Court has jurisdiction. ]
ii.
The value of the subject-matter of the suit for the purpose of jurisdiction is
….................rupees and for the purpose of court-fees is
..........................................................rupees.]
6.
The plaintiff is desirous to account for all the rents and profits of the said
immovable property [and the proceeds of the sale of the said, or of the part of
the said, immovable property, or movable, or the proceeds of the sale of, or of
part of, the said movable property, or the profits accruing to the plaintiff as
such trustee in the execution of the said trust]; and he prays that the Court
will take the accounts of the said trust, and also that the whole of the said
trust estate may be administered in the Court for the benefit of GM………………………..……...,
the defendant, and all other persons who may be interested in such
administration……………….. ….GM…… ……………………and such other persons so interested as
the Court may direct, or that…………………….. GM……………... may show good cause to the
contrary.
[N.B.-Where
the suit is by a beneficiary, the plaint may be modelled mutatis mutandis on
the plaint by a legatee.]
Dated :
Plaintiff
Through, Advocate
I,
_____________________________, do hereby verify that the contents from paras 1
to ____________ are correct and true to the best of my knowledge and personal
belief and no part of it is false and nothing material has been concealed
therein.
Affirmed at THANE this ______.
Plaintiff
0 Comments
Thank you for your response. It will help us to improve in the future.