MOD – 1

I. Plaint Structure Format

IN THE COURT OF ____________

Civil Suit No. ________ of 20__
A.B.
S/o __________
R/o __________
…
Plaintiff
Versus
C.D.
S/o __________
R/o __________
…
Defendant
PLAINT UNDER ORDER VII OF CPC
The Plaintiff most respectfully submits as follows:

1. That the plaintiff is __________ (brief description of the plaintiff, such as

occupation, status, etc.).

2. That the defendant is __________ (brief description of the defendant).

3. Jurisdiction of the Court

That this Hon’ble Court has jurisdiction to try and entertain the present suit
because __________ (state facts showing territorial and pecuniary
jurisdiction).
4. Facts of the Case
That __________ (state material facts in chronological order, each fact in
separate numbered paragraphs, clearly explaining the dispute).

5. Cause of Action
That the cause of action for the present suit arose on __________ at
 __________ when __________ (mention when and where the right was
violated).

6. Limitation
That the present suit is within the period of limitation as prescribed under
law.

7. Relief Claimed
That the plaintiff is entitled to the following reliefs:
(a) __________
(b) __________
(c) Any other relief which this Hon’ble Court deems fit.

8. Valuation and Court Fee

That the suit is valued at Rs. __________ for the purpose of jurisdiction
and court fee, and the appropriate court fee has been affixed.

PRAYER
It is therefore most respectfully prayed that this Hon’ble Court may be pleased to:

(a) __________
(b) __________
(c) Pass any other order deemed fit in the interest of justice.

Date:
Place:
Plaintiff

(Signature)
Through counsel
Advocate name & signature

VERIFICATION
I, A.B., the plaintiff above named, do hereby verify that the contents of paragraphs
1 to ___ are true to my personal knowledge and paragraphs ___ to ___ are based
on information believed to be true.
Verified at __________ on this ___ day of ________, 20.

Date:
Place:
Plaintiff

(Signature)
Through counsel
Advocate name & signature
AFFIDAVIT

I______, W/O______, D/O______, R/O______ do hereby solemnly affirm and

declare as under: -
1. That the deponent is the Plaintiff in the abovementioned case, filing the present
plaint hence, competent to sign this affidavit.
2. That the content of the accompanying plaint is drafted by the counsel of the
plaintiff and all the legal averments are true and correct to the belief of the
respondent which is based on legal advice rendered and believed to be correct.

3. That the plaintiff has gone through and understood the contents of the same, and
says that the facts stated therein are true and correct to the best of her knowledge.

Deponent

VERIFICATION:

Verified at Delhi on day of______ that the contents of the above affidavit are true
and correct to the best of my knowledge and belief and nothing material has been
concealed therefrom.

Date:
Place:
Plaintiff
(Signature)
Through counsel
Advocate name & signature

II. Written Statement Format

IN THE COURT OF ____________

Civil Suit No. ________ of 20__
A.B.
S/o __________
R/o __________
…
Plaintiff
Versus
C.D.
S/o __________
R/o __________
…
Defendant
WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT
TO THE SUIT FILED BY THE PLAINTIFF

MOST RESPECTFULLY SHOWETH:

The Defendant above named respectfully submits as follows:

PRELIMINARY OBJECTIONS: -

1. That at the outset itself, the defendant denies each and every allegations levelled
by the plaintiff against the defendant in the present suit. The plaintiff has filed the
present suit against the defendant with malafide intentions and ulterior motive. The
allegations levelled by the plaintiff in the present suit are completely false and
frivolous and the same are merely made with the intention to harass the defendant.

2. The allegations made by plaintiff in its plaint are denied as false. The plaintiff has
not approached this Hon'ble court with clean hands. The plaintiff has with malafide
intentions concealed various material facts and information from this Hon'ble court
and only presented the facts that are favourable to their case.

3. That the instant suit being devoid of any cause of action against the defendant and
its liable to be dismissed with punitive costs. It is submitted that the suit is
misconceived and is based on suppression and incorrect facts and on this ground
alone the suit is liable to be dismissed.

PARA WISE REPLY:

PARA 1- The contends of the corresponding para of the plaint do not require any
reply as the same does not concern the defendants and are beyond the knowledge of
the defendant.

PARA 2- The contends of the corresponding para of the plaint are true and correct.

PARA 3- The contends of the corresponding para of the plaint are true and admitted.

PARA 4 - The contends of the corresponding para of the plaint are denied as false
and plaintiff strict proof of the same. It is hereby submitted__________.

PARA 5 - The contends of the corresponding para of the plaint are specifically
denied as false and plaintiff is put to strict proof of the same. It is hereby submitted
__________.
PARA 6- The calculation of the corresponding para of the plaint is not correct and
denied as false. It is hereby submitted that__________.

PARA 7- The content of the corresponding para of the plaint are denied as false. No
cause of action aroused in favour of the plaintiff and against the defendant in the
present suit and the present suit filed by the plaintiff is liable to be dismissed for
want of cause of action.

PARA 8 AND 9- The contends of the corresponding para of the plaint are denied as
false. The plaintiff is put to strict proof of the same.

PARA 10-The contends of the corresponding para of the plaint does not require ant
reply as the same is legal para regarding the court fee paid and valuation of the suit.

PARA 11-The contends of the corresponding para of the plaint are denied as false
and plaintiff is put to strict proof of the same.

PRAYER
It is therefore most respectfully prayed that this Hon’ble Court may be pleased to:

(a) Dismiss the suit filed by the plaintiff on the grounds brought out in the written
statement as the plaintiff is not entitled to any relief as claimed in the prayer clause
of the plaint.

(b) Impose exemplary costs upon the plaintiff for abusing the process of this
Hon'ble court and wasting the precious time of this Hon'ble court by filling the
present frivolous litigation.
(c) Award the costs of the present case in favour of the defendant.

(d) Any other or further order which this Hon'ble court may deem fit in the interest
of justice and equity.

Date:
Place:
Defendant

(Signature)
Through counsel
Advocate name & signature

VERIFICATION
I, C.D., the plaintiff above named, do hereby verify that the contents of paragraphs
1 to ___ are true to my personal knowledge and paragraphs ___ to ___ are based
on information believed to be true.

Verified at __________ on this ___ day of ________, 20.

Date:
Place:
Defendant

(Signature)
Through counsel
Advocate name & signature
 AFFIDAVIT

I______, W/O______, D/O______, R/O______ do hereby solemnly affirm and

declare as under: -

1. That the deponent is the Defendant in the abovementioned case, filing the
present written statement hence, competent to sign this affidavit.

2. That the content of the accompanying written statement is drafted by the

counsel of the defendant and all the legal averments are true and correct to the
belief of the defendant which is based on legal advice rendered and believed to be
correct.

3. That the defendant has gone through and understood the contents of the same,
and says that the facts stated therein are true and correct to the best of her
knowledge.

Deponent

VERIFICATION:

Verified at Delhi on day of______ that the contents of the above affidavit are true
and correct to the best of my knowledge and belief and nothing material has been
concealed therefrom.

Date:
Place:
Defendant

(Signature)
Through counsel
Advocate name & signature

III. Affidavit Format

 AFFIDAVIT

I______, W/O______, D/O______, R/O______ do hereby solemnly affirm and

declare as under: -

1. That the deponent is the Defendant/Plaintiff in the abovementioned case, filing

the present written statement/reply/plaint hence, competent to sign this affidavit.

2. That the content of the accompanying written statement/reply/plaint is drafted

by the counsel of the Defendant/Plaintiff and all the legal averments are true and
correct to the belief of the Defendant/Plaintiff which is based on legal advice
rendered and believed to be correct.

3. That the Defendant/Plaintiff has gone through and understood the contents of
the same, and says that the facts stated therein are true and correct to the best of
her knowledge.

Deponent

VERIFICATION:

Verified at Delhi on day of______ that the contents of the above affidavit are true
and correct to the best of my knowledge and belief and nothing material has been
concealed therefrom.

Date:
Place:
Deponent

(Signature)
Through counsel
Advocate name & signature

IV. Verification of Pleading Format

 VERIFICATION
I, C.D., the plaintiff above named, do hereby verify that the contents of paragraphs
1 to ___ are true to my personal knowledge and paragraphs ___ to ___ are based
on information believed to be true.
Verified at __________ on this ___ day of ________, 20.

Date:
Place:
Deponent

(Signature)
Through counsel
Advocate name & signature

V. Amendment of Pleadings Format

IN THE COURT OF ____________
Civil Suit No. ________ of 20__
A.B.
S/o __________
R/o __________
…
Plaintiff
Versus
C.D.
S/o __________
R/o __________
…
Defendant
APPLICATION UNDER ORDER VI RULE 17 READ WITH
SECTION 151 CPC FOR AMENDMENT OF PLAINT /
WRITTEN STATEMENT
The Applicant (Plaintiff/Defendant) most respectfully submits as
under:

1. That the above-mentioned suit is pending adjudication before this

Hon’ble Court and is at the stage of __________.
2. That the Applicant has already filed the (Plaint/Written Statement)
in the present suit.
3. That due to inadvertence / bona fide mistake / subsequent events,
certain facts could not be incorporated earlier and hence amendment is
necessary.
[Link] the Applicant seeks to amend the (Plaint/Written Statement) in
the following manner:
• In para 3, the following words be added:
“_______________________”
• In para 7, the following words be deleted:
“_______________________”
• After para 11, a new para 12 be inserted as under:
“_______________________”
5. That the proposed amendment is necessary for determining the real
questions in controversy between the parties.
6. That the amendment will not cause any prejudice to the opposite
party and can be compensated by costs.
7. That despite due diligence, the Applicant could not have raised the
matter before the commencement of trial.
[Link] the amendment does not change the nature or character of the
suit.
9. That the present application is made bona fide and in the interest of
justice.
 PRAYER
It is therefore most respectfully prayed that this Hon’ble Court may be
pleased to:
a) Allow the present application and permit the Applicant to amend the
(Plaint/Written Statement);
b) Pass any other order deemed fit and proper in the interest of justice.

Date:
Place:
Deponent

(Signature)
Through counsel
Advocate name & signature

VERIFICATION
I, ________, do hereby verify that the contents of this application are
true and correct to my knowledge and belief.
Verified at ______ on this ___ day of ____, 20.

Date:
Place:
Deponent

(Signature)
Through counsel
Advocate name & signature
 AFFIDAVIT

I______, W/O______, D/O______, R/O______ do hereby solemnly affirm and

declare as under: -

1. That the deponent is the Defendant/Plaintiff in the abovementioned case, filing

the present aapplication hence, competent to sign this affidavit.

2. That the content of the accompanying application is drafted by the counsel of

the Defendant/Plaintiff and all the legal averments are true and correct to the belief
of the Defendant/Plaintiff which is based on legal advice rendered and believed to
be correct.

3. That the Defendant/Plaintiff has gone through and understood the contents of
the same, and says that the facts stated therein are true and correct to the best of
her knowledge.

Deponent

VERIFICATION:

Verified at Delhi on day of______ that the contents of the above affidavit are true
and correct to the best of my knowledge and belief and nothing material has been
concealed therefrom.

Date:
Place:
Deponent

(Signature)
Through counsel
Advocate name & signature