Professional Documents
Culture Documents
Founders publications
_______________
V/s.
Mr.Arvind Upadhyay)
Kandiwali(W) Mumbai...Defendant )
1. I state that the Plaintiff is a company which is in the business of manufacturing and
publication of notebooks and stationery. The manufacturing and publication unit is situated at
Surendranagar while its distribution and marketing is extended to pan India. I state that
Defendant is doing the retail business of books and stationery. The Plaintiff and the Defendant
3. The plaintiff on believing the representations made by the defendant to be true entered into an
agreement with the defendant for sale of notebooks and stationery in 2016.
4. The plaintiff states that as per the terms in the agreement the plaintiff has supplied notebooks
and stationery to the defendant from time to time. However, the defendant has only given part
payment of Rs. 200,000/-(Rupees two lakh only) out of total outstanding amount of Rs.
11,19,132/-(Rupees Eleven lakh nineteen thousand one hundred thirty two only)
5. The Plaintiff states that repeated attempts were made to recover the amount of
9,19,132(Rupees Nine lakh nineteen thousand one hundred thirty two only) due to the
plaintiff. However, the Defendants have not responded to the repeated requests for payment
6. The Plaintiff though discharged his obligation under the agreement and supplied the
notebooks and stationery; the Defendant failed and neglected in their duty to pay the amount
of Rs. 9,19,132 (Rupees Nine lakh nineteen thousand one hundred thirty two only) due to the
plaintiff.
7. The Plaintiff states that the defendant is liable to pay the sum of Rs. 9,19,132 (Rupees Nine
lakh nineteen thousand one hundred thirty two only) due to the plaintiff with interest thereon
at ____% from _____ to_____. The Plaintiff states that the defendant admitted their liability
and there is no defence whatsoever or any justifiable dispute. The Plaintiff states that the
amount of Rs. 9,19,132(Rupees Nine lakh nineteen thousand one hundred thirty two only) is
due and payable by the Defendant to the Plaintiff and the Defendant has admitted the
liability.
8. The Plaintiff states that the Plaintiff has not claimed any reliefs beyond the scope of order 37
Rule 1 of CPC. The Plaintiff states that in the facts and circumstances mentioned hereinabove
9. The Plaintiff states that in the circumstances the Plaintiff is entitled to the decree of Rs.
9,19,132(Rupees Nine lakh nineteen thousand one hundred thirty two only) due to the plaintiff
with interest thereon @___ % p.a. from _______ to ____________ against the defendant and
10. The Plaintiff states that the defendant has their office in Mumbai. The Plaintiff is carrying on
business in Gujarat; the contract was entered into at Gujarat. The Plaintiff states that the whole
cause of action has arisen in Gujarat and this Hon'ble Court has jurisdiction to try and
11. The plaintiff has not filed any other suit either in this Hon'ble court or any other court or in the
12. The plaintiff submits that no part of the claim in the suit is barred by law of limitation.
13. The Plaintiff states that the Plaintiff values the suit at Rs. 9,19,132 (Rupees Nine lakh
nineteen thousand one hundred thirty two only)due to the plaintiff and pays the court fees
accordingly.
14. The Plaintiff will rely upon the list of documents a list whereof is annexed.
a) By a decree and judgment in plaintiff's favour and against the defendant for
Rs9,19,132(Rupees Nine lakh nineteen thousand one hundred thirty two only)due to the
plaintiff with further interest thereon @___% p.a. of Rs. 9,19,132(Rupees Nine lakh
nineteen thousand one hundred thirty two only) due to the plaintiff from the date of suit till
b) For cost;
c) For such other and further reliefs which this Hon'ble court may deem fit and proper
Verification
I, ________, aged about __ years the Authorized representative of plaintiff above named do hereby
Solemnly declare that what is stated in the foregoing paragraphs No.__ to __ is true to my own
knowledge and what is stated in the remaining paragraphs No.__ to __ is based on information
BEFORE ME