2.

1)
Drafts for Suit for Recovery under Order XXXVII CPC
This document provides a plaintiff-side draft plaint and a defendant-side draft application for leave
to defend / reply for a summary suit for recovery under Order XXXVII of the Code of Civil
Procedure, 1908. Order XXXVII applies to suits on negotiable instruments and to suits seeking
only recovery of a debt or liquidated demand in money arising from specified written contracts,
enactments, or guarantees.

Order XXXVII structure

A plaint under Order XXXVII must specifically aver that the suit is filed under that Order and that
no relief outside the scope of Order XXXVII is claimed in the suit. In the prescribed procedure,
the defendant must enter appearance within 10 days of service, and can defend the suit only by
seeking leave to defend and disclosing facts showing a substantial or bona fide defence or triable
issue.

Plaintiff-side draft plaint

Note: Replace bracketed fields with actual facts, dates, amounts, documents, and court
details.

IN THE COURT OF THE HON'BLE [COURT NAME] AT [PLACE]

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
[Father's / Husband's Name, if individual]
[Address]
...Plaintiff

VERSUS

[NAME OF DEFENDANT]
[Father's / Husband's Name / Registered Office]
[Address]
...Defendant

PLAINT UNDER ORDER XXXVII CPC FOR RECOVERY OF MONEY

The Plaintiff above named most respectfully submits as under:

1. That the present suit is being instituted under Order XXXVII of the Code of Civil
Procedure, 1908, as the claim arises out of a written contract / invoice acknowledged in
writing / promissory note / bill of exchange / hundi / cheque / guarantee, and the suit seeks
recovery of a fixed and liquidated sum of money only.

2. That the Plaintiff is [state description, status, and capacity of plaintiff]. The present plaint is
being signed, verified, and instituted by [name and designation], who is duly authorized for
the said purpose by [authorization / board resolution / power of attorney] dated [date].

3. That the Defendant is [state description and address of defendant] and is liable to this
Hon'ble Court's territorial and pecuniary jurisdiction for the reasons stated herein.

4. That on [date], the Plaintiff and Defendant entered into a written contract / transaction
whereby [set out brief facts of supply of goods, loan, services, acknowledged liability,
dishonored cheque, or written promise to pay]. The said transaction is evidenced by
[agreement / invoice nos. / Promissory note / cheque no. / Ledger confirmation / guarantee
deed] dated [date].

5. That in terms of the said written document(s), a sum of Rs. [amount] became due and
payable by the Defendant to the Plaintiff. Despite repeated requests and demands, the
Defendant failed and neglected to discharge the said liability.

6. That the Defendant, on [date], acknowledged its liability / issued cheque bearing no.
[Number] for Rs. [amount] drawn on [bank], in favour of the Plaintiff. The said cheque,
when presented, was dishonored vide return memo dated [date] for the reason “[reason],”
thereby confirming the subsisting liability of the Defendant.
 7. That as per the statement of account / written acknowledgment / terms of contract, the
Defendant is liable to pay a principal sum of Rs. [amount], along with contractual / pendent
elite / future interest at the rate of [rate]% per annum from [date] till realization.

8. That the cause of action first arose on [date] when the amount became due, and continued to
arise on subsequent dates including [dates of acknowledgment, dishonor, notice, or refusal],
and is still continuing within the jurisdiction of this Hon'ble Court.

9. That this Hon'ble Court has territorial jurisdiction because [contract executed / goods
supplied / payment made payable / cheque presented / defendant resides or carries on
business] within the jurisdiction of this Hon'ble Court. This Hon'ble Court also has pecuniary
jurisdiction as the value of the suit is Rs. [amount].

10. That the suit is within limitation, the last acknowledged / default date being [date].

11. That no relief which does not fall within the ambit of Order XXXVII CPC is claimed in the
present suit, and the Plaintiff seeks only recovery of the liquidated amount stated herein
together with permissible interest and costs.

12. That despite service of legal notice dated [date], the Defendant failed to pay the amount
demanded. The copy of the notice and proof of service are filed along with the plaint.

Reliefs claimed

In view of the above, it is most respectfully prayed that this Hon'ble Court may be pleased to:

a. Pass a decree in favour of the Plaintiff and against the Defendant for a sum of Rs. [amount];

b. Award interest at the rate of [rate]% per annum from [date] till realization;

c. Award costs of the suit in favour of the Plaintiff; and

d. Pass such other or further orders as this Hon'ble Court may deem fit and proper in the facts and
circumstances of the case.

Plaintiff
Through Counsel
[Name of Advocate]
[Enrollment No.]
[Address]

Place: [Place]
Date: [Date]

Verification

I, [name], [designation / plaintiff], do hereby verify that the contents of paragraphs 1 to [x] of the
plaint are true and correct to my knowledge, derived from records maintained in the ordinary
course of business, and believed to be true on legal advice. Nothing material has been concealed
therefrom.

Verified at [place] on this [date].

[Signature]

List of documents typically annexed

 Written contract / loan agreement / invoice set / promissory note / cheque.

 Statement of account and certificate, where applicable.

 Legal notice and proof of dispatch / delivery.

 Board resolution / authority letter, if plaintiff is an entity.

 Dishonour memo, if claim is based on cheque.

Defendant-side draft

Under Order XXXVII, the defendant ordinarily does not file a regular written statement at the first
instance. The defendant must first enter appearance and then file an application for leave to
defend supported by affidavit after service of summons for judgment; leave may be unconditional
or conditional if a bona fide defence or triable issue is disclosed. The draft below is therefore
framed as a defendant's application for leave to defend with preliminary reply on merits, which is
the proper response format in an Order XXXVII suit.
IN THE COURT OF THE HON'BLE [COURT NAME] AT [PLACE]

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
...Plaintiff

VERSUS

[NAME OF DEFENDANT]
...Defendant / Applicant

APPLICATION FOR LEAVE TO DEFEND UNDER ORDER XXXVII CPC READ WITH
AFFIDAVIT

The Defendant / Applicant most respectfully submits as under:

1. That the Applicant has entered appearance within the prescribed period in the present
summary suit. The present application is being filed seeking leave to defend, as the
Applicant has substantial and bona fide defences raising triable issues which cannot be
summarily shut out.

2. That the suit as framed is not maintainable under Order XXXVII CPC because [state ground,
such as claim not based solely on written contract, amount is unliquidated, mixed reliefs
claimed, disputed accounts, oral terms, defective invoices, or serious factual disputes]. Order
XXXVII is confined to suits for a debt or liquidated demand in money of the kind specified
in the provision.

3. That the Plaintiff has suppressed material facts, including [state omitted facts], and has not
approached this Hon'ble Court with clean hands.

4. That no amount as alleged is due and payable by the Defendant. The alleged documents
relied upon by the Plaintiff are denied unless specifically admitted. The Plaintiff's statement
of account is unilateral, self-serving, and not acknowledged by the Defendant.

5. That the goods / services allegedly supplied were defective / incomplete / rejected / not
supplied in accordance with the contract, and therefore the claim is disputed on merits.
 Alternatively, the amount claimed is highly inflated and requires full trial, evidence, and
cross-examination.

6. That the alleged cheque / acknowledgment / document does not constitute an unconditional
admission of liability for the amount claimed, and was issued [as security / subject to
conditions / against future reconciliation / without consideration], which itself raises a triable
issue.

7. That the suit is barred by limitation / lacks territorial jurisdiction / suffers from non-joinder /
has been filed by an unauthorized person / discloses no cause of action, without prejudice to
the other defences available to the Defendant.

8. That the Defendant has a fair, bona fide, and substantial defence and, at minimum, triable
issues arise for adjudication. In such circumstances, the Defendant is entitled to leave to
defend, and refusal of such leave would cause grave prejudice and miscarriage of justice.

Prayer

In view of the foregoing, it is most respectfully prayed that this Hon'ble Court may be pleased to:

a. Grant unconditional leave to defend the present suit to the Defendant / Applicant;

b. In the alternative, grant such conditional leave as this Hon'ble Court deems fit;

c. Dismiss the summons for judgment; and

d. Pass any other order deemed fit in the interest of justice.

Defendant / Applicant
Through Counsel
[Name of Advocate]
[Enrollment No.]
[Address]

Place: [Place]
Date: [Date]
Affidavit in support

I, [name of defendant / authorized representative], aged about [age] years, resident of [address], do
hereby solemnly affirm and state:

1. That I am the Defendant / authorized representative of the Defendant in the present matter
and am competent to swear this affidavit.

2. That the contents of the accompanying application for leave to defend are true and correct to
my knowledge and belief.

3. That the annexures filed with the application are true copies of their respective originals.

Verified at [place] on this [date].

[Deponent Signature]

Practical pleading notes

 The plaint title should expressly mention that it is filed under Order XXXVII CPC.

 The plaint should seek only a liquidated money claim with interest and costs, and should
avoid unrelated declaratory or injunction reliefs if the suit is to proceed summarily.

 The defendant's first effective merits response is usually the leave-to-defend application
supported by affidavit, not a conventional written statement unless leave is granted.

 If part of the claim is admitted, courts may insist on deposit of the admitted amount before
granting leave to defend.

Use and caution

These are litigation templates for educational drafting assistance and must be tailored to the exact
documents, cause of action, limitation position, jurisdiction, and local court practice before filing.
Because court formatting, cause-title conventions, vakalatnama requirements, affidavit attestation,
and annexure marking vary, a local advocate should settle the final pleadings before use.

2)
Below is a proper legal draft set for a suit for permanent injunction from both sides in India:
first, the plaintiff/petitioner’s plaint, and second, the defendant/respondent’s written
statement. A perpetual or permanent injunction is governed principally by Sections 36, 37, and 38
of the Specific Relief Act, 1963, which distinguish temporary and perpetual injunctions and state
when a perpetual injunction may be granted.

Plaintiff draft

A permanent injunction suit is commonly framed where the plaintiff alleges lawful possession or
an enforceable civil right and seeks restraint against unlawful interference by the defendant.

IN THE COURT OF THE CIVIL JUDGE AT __________

Civil Suit No. _____ of 20__

[NAME OF PLAINTIFF]
S/o / D/o / W/o __________
R/o _______________________
...Plaintiff

VERSUS

[NAME OF DEFENDANT]
S/o / D/o / W/o __________
R/o _______________________
...Defendant

SUIT FOR PERMANENT INJUNCTION

The Plaintiff most respectfully submits as under:

1. That the plaintiff is a law-abiding citizen and is in lawful possession and enjoyment of the suit
property bearing ______________________, situated at ______________________, more fully
described in the schedule below.

2. That the plaintiff acquired rights in the suit property by virtue of ______________________
dated __________, and has been in peaceful possession thereof since then.

3. That the defendant is known to the plaintiff and has no right, title, or interest to interfere with
the peaceful possession and enjoyment of the plaintiff over the suit property, except as falsely
claimed by him.

4. That on __________ and again on __________, the defendant, with some associates, came near
the suit property and attempted to interfere with the plaintiff’s peaceful possession and threatened
to dispossess the plaintiff illegally and without due process of law.
5. That the plaintiff resisted the illegal acts of the defendant and requested him not to interfere, but
the defendant paid no heed and continued to extend threats.

6. That the cause of action first arose on __________ when the defendant initially interfered with
the plaintiff’s possession, and again arose on subsequent dates including __________, when the
defendant repeated the threats and interference. The cause of action is still continuing.

7. That this Hon’ble Court has territorial jurisdiction because the suit property is situated within
the jurisdiction of this Hon’ble Court and the cause of action arose within such jurisdiction.

8. That for the purposes of court fee and jurisdiction, the suit is valued at Rs. __________ and the
requisite court fee has been affixed as per law.

9. That the plaintiff has no other efficacious remedy except to approach this Hon’ble Court
seeking a decree of permanent injunction, since the defendant is threatening illegal interference
with the plaintiff’s civil rights.

10. That the suit is within limitation.

PRAYER

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

a. Pass a decree of permanent injunction in favour of the plaintiff and against the defendant,
thereby restraining the defendant, his agents, servants, representatives, or any person acting
through him from interfering in any manner with the peaceful possession and enjoyment of the
plaintiff over the suit property;

b. Award costs of the suit in favour of the plaintiff; and

c. Pass such other or further order as this Hon’ble Court may deem fit and proper in the facts and
circumstances of the case.

PLAINTIFF
Through Counsel
[Advocate Name]

Place: __________
Date: __________

Verification

VERIFICATION
I, [name of plaintiff], the above-named plaintiff, do hereby verify that the contents of paragraphs 1
to __ are true and correct to my knowledge, and those of paragraphs __ to __ are believed to be
true on legal advice.

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

Plaintiff

Defendant draft

In response to a permanent injunction suit, the defendant typically files a written statement
denying possession, title, interference, cause of action, or maintainability, depending on the facts.

IN THE COURT OF THE CIVIL JUDGE AT __________

Civil Suit No. _____ of 20__

[NAME OF PLAINTIFF]
...Plaintiff

VERSUS

[NAME OF DEFENDANT]
...Defendant

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the suit filed by the plaintiff is false, frivolous, and not maintainable either in law or on
facts.

2. That the plaintiff has suppressed material facts from this Hon’ble Court and has not approached
the Court with clean hands, and therefore is not entitled to the equitable relief of injunction.

3. That the plaintiff has no cause of action to file the present suit against the defendant.

4. That the suit is bad for want of proper valuation / court fee / non-joinder or mis-joinder of
necessary parties, to the extent applicable on the facts.
5. That the plaintiff is not in lawful possession of the suit property, and therefore no relief of
permanent injunction can be granted in his favour where title and possession are seriously
disputed.

PARAWISE REPLY

1. That paragraph 1 of the plaint is wrong and denied to the extent it alleges exclusive lawful
possession of the plaintiff. It is submitted that ______________________.

2. That paragraph 2 is denied. The alleged document dated __________ does not confer the rights
claimed by the plaintiff, or in the alternative, the same is denied for want of knowledge and strict
proof is demanded.

3. That paragraph 3 is denied. The defendant has lawful rights and interest in respect of the
property / has never interfered unlawfully / is in possession of his own adjoining property only.

4. That paragraph 4 is specifically denied. No such incident took place on the dates alleged, and
the story set up by the plaintiff is concocted and false.

5. That paragraph 5 is denied. The defendant never threatened the plaintiff, nor attempted any
illegal dispossession.

6. That paragraph 6 relating to cause of action is wrong and denied. No cause of action has ever
arisen in favour of the plaintiff.

7. That paragraph 7 regarding jurisdiction is a matter of record; however, the defendant submits
that this Hon’ble Court [does / does not] have jurisdiction for the reasons stated in the preliminary
objections.

8. That paragraph 8 regarding valuation and court fee is incorrect / matter of record.

9. That paragraph 9 is denied. The plaintiff is not entitled to any discretionary and equitable relief
from this Hon’ble Court.

10. That paragraph 10 is wrong and denied to the extent contrary to the record.

PRAYER

In view of the facts stated above, it is most respectfully prayed that this Hon’ble Court may be
pleased to:

a. Dismiss the suit of the plaintiff with costs;

b. Hold that the plaintiff is not entitled to the relief of permanent injunction as claimed; and

c. Pass any other order deemed fit and proper in the interest of justice.
DEFENDANT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

Verification

VERIFICATION

I, [name of defendant], the above-named defendant, do hereby verify that the contents of the
preliminary objections and reply on merits are true and correct to my knowledge and belief.

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

Defendant

Legal points

A perpetual injunction is part of “preventive relief” under the Specific Relief Act, and Section 37
distinguishes temporary injunctions from perpetual injunctions, while Section 38 states when a
perpetual injunction may be granted to prevent breach of an obligation existing in favour of the
plaintiff. Courts treat injunction as an equitable remedy, so suppression of material facts, lack of
possession, or absence of a clear civil right can defeat the claim.

The sample format available from a legal drafting site also shows the common structural parts of
such a plaint: cause title, facts of possession, interference, cause of action, jurisdiction, valuation,
prayer, verification, and often an accompanying interim injunction application under Order
XXXIX Rules 1 and 2 CPC. If your facts involve threatened dispossession during pendency, it is
common to file the main permanent injunction suit along with an interim injunction application.

3)

Below is a proper legal format draft for a Suit for Dissolution of Partnership in India. A
partner may sue for dissolution by court under Section 44 of the Indian Partnership Act, 1932 on
specified grounds, and after dissolution the assets and liabilities are to be applied for settlement of
accounts and distribution of surplus, which is why such suits commonly also seek rendition of
accounts and distribution of assets.

Plaintiff draft

A dissolution suit typically pleads the partnership deed, constitution of the firm, the plaintiff’s
status as partner, the acts or defaults justifying dissolution, and reliefs for dissolution, accounts,
and distribution.
IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

IN THE MATTER OF:

[NAME OF PLAINTIFF]
S/o / D/o / W/o __________
R/o __________________________
...Plaintiff

VERSUS

[NAME OF DEFENDANT NO. 1]

S/o / D/o / W/o __________
R/o __________________________

[NAME OF DEFENDANT NO. 2, IF ANY]

S/o / D/o / W/o __________
R/o __________________________
...Defendant(s)

SUIT FOR DISSOLUTION OF PARTNERSHIP, RENDITION OF ACCOUNTS,

AND DISTRIBUTION OF PARTNERSHIP ASSETS

The Plaintiff most respectfully submits as under:

1. That the Plaintiff and the Defendant(s) entered into a partnership under the name and style of
M/s ____________________, pursuant to a Partnership Deed dated __________ executed at
__________.

2. That as per the said Partnership Deed, the Plaintiff and the Defendant(s) agreed to carry on the
business of ____________________, and the profit-and-loss sharing ratio was as follows:
(a) Plaintiff: ____%
(b) Defendant No. 1: ____%
(c) Defendant No. 2: ____%

3. That the principal place of business of the partnership firm is / was situated at
____________________, within the jurisdiction of this Hon’ble Court.

4. That the partnership was [at will / for a fixed term / for a specific venture], and the rights and
obligations of the partners were governed by the Partnership Deed and the provisions of the Indian
Partnership Act, 1932.
5. That the Plaintiff has always acted honestly and in the interest of the firm, but the Defendant(s)
have committed repeated breaches of the terms of partnership, including:
(a) failure to maintain and disclose true and correct accounts;
(b) refusal to permit inspection of books of account;
(c) misappropriation / unauthorized withdrawal of partnership funds;
(d) exclusion of the Plaintiff from management and affairs of the firm;
(e) acts prejudicial to the business of the firm;
(f) conduct making it impossible to carry on business in partnership.

6. That despite repeated oral and written demands, the Defendant(s) failed to render accounts or
regularize the affairs of the firm.

7. That the relationship between the parties has completely broken down, and it is no longer
possible to carry on the business of the firm in accordance with the partnership agreement.

8. That the cause of action for the present suit arose on __________ when the Defendant(s) first
refused to render accounts / committed breach of the deed, and again on subsequent dates
including __________ when the Plaintiff’s rights were denied. The cause of action is continuing.

9. That this suit is maintainable under Section 44 of the Indian Partnership Act, 1932, as the
conduct of the Defendant(s) is such that the firm deserves to be dissolved by decree of this
Hon’ble Court.

10. That the Plaintiff is also entitled to rendition of true and proper accounts of the partnership
business, including all assets, liabilities, stock-in-trade, receivables, goodwill, profits, and losses of
the firm.

11. That after taking accounts, the Plaintiff is entitled to his/her lawful share in the assets, profits,
and any residue remaining after discharge of liabilities, in accordance with law.

12. That this Hon’ble Court has territorial and pecuniary jurisdiction to entertain and try the
present suit because the partnership business was carried on within its jurisdiction and the value of
the subject matter falls within its pecuniary limits.

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

PRAYER

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

a. Pass a decree dissolving the partnership firm M/s ____________________;

b. Direct rendition and taking of true and proper accounts of the partnership business;

c. Appoint a Local Commissioner / Receiver, if necessary, to inspect books of accounts, stock,

assets, and records of the firm;
d. Direct that the assets of the partnership firm be realized and applied towards discharge of
liabilities in accordance with law;

e. Direct distribution of the balance / surplus among the partners as per their lawful shares;

f. Grant mesne profits / damages / interest, if applicable;

g. Award costs of the suit; and

h. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper.

PLAINTIFF
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Verification

VERIFICATION

I, [name of plaintiff], the above-named Plaintiff, do hereby verify that the contents of paragraphs 1
to __ are true and correct to my knowledge, and the remaining paragraphs are believed to be true
on legal advice and records available with me.

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

Plaintiff

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

IN A SUIT FOR DISSOLUTION OF PARTNERSHIP

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS
[NAME OF DEFENDANT NO. 1]
[NAME OF DEFENDANT NO. 2, IF ANY]
…Defendant(s)

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the present suit is premature, not maintainable, and/or barred by law, as the Plaintiff has
not exhausted alternative remedies and/or the conditions for dissolution have not been satisfied
under the Indian Partnership Act, 1932.

2. That the Plaintiff is not entitled to the reliefs of dissolution, rendition of accounts, and
distribution of assets as claimed, and the suit is based on misrepresentation, exaggeration, and
suppression of material facts.

3. That the Plaintiff has approached this Hon’ble Court without clean hands and, in any case, the
equitable relief sought should be refused.

4. That the Plaintiff has not made out a prima facie case for dissolution of the partnership firm, and
there is no evidence of conduct making it impossible to carry on the firm in partnership.

5. That the valuation, court-fee, or jurisdiction of this Hon’ble Court is wrongly stated, to the
extent necessary on facts.

6. That the partnership firm is [registered / at-will / for a fixed term], and the Plaintiff’s claim does
not fall within the statutory exceptions where dissolution by court is permitted.

PARAWISE REPLY

1. That paragraph 1 of the plaint is denied. The nature, terms, and extent of the alleged partnership
are wrong and exaggerated. The Defendant denies the manner in which the Plaintiff has described
the constitution of the firm.

2. That paragraph 2 is denied. The profit-and-loss sharing ratio alleged by the Plaintiff is incorrect,
and the Defendant demands strict proof of the claimed deed and terms.

3. That paragraph 3 regarding place of business is a matter of record, but the Defendant submits
that the Plaintiff has not pleaded material facts correctly in this respect.

4. That paragraph 4 is denied. The partnership is [at will / for a fixed term / otherwise], and the
Defendant denies that the conduct alleged by the Plaintiff justifies dissolution under Section 44 of
the Indian Partnership Act, 1932.
5. That paragraph 5 is specifically denied. The Defendant has not committed any breach of the
partnership deed, has maintained proper accounts, and has never misappropriated funds. The
Plaintiff’s allegations are false, devoid of evidence, and based on suspicion.

6. That paragraph 6 is denied. The Defendant has always been willing to allow inspection of
accounts and has invited the Plaintiff to sit together for revision and settlement, but the Plaintiff
has unreasonably refused.

7. That paragraph 7 is denied. The Defendant is ready and willing to continue the partnership
business in accordance with the terms of the deed and the law, and there is no reasonable ground
for the Plaintiff to invoke the court’s equitable jurisdiction.

8. That the Plaintiff has not approached the Court with clean hands, and the suit is motivated by
personal malice, greed, or an ulterior motive, which should disentitle the Plaintiff to any relief.

9. That the Defendant is ready and willing to:

(a) open the books of accounts for inspection by the Plaintiff or an auditor;
(b) redress any genuine grievance through mutual settlement; and
(c) continue the firm if the Court so directs.

PRAYER

In view of the facts stated above, it is most respectfully prayed that this Hon’ble Court may be
pleased to:

a. Dismiss the suit of the Plaintiff with costs;

b. Decline to dissolve the partnership firm M/s ____________________;

c. Refuse the prayer for rendition of accounts and distribution of assets as sought by the Plaintiff;

d. Pass such other or further order as this Hon’ble Court may deem fit and proper in the interest of
justice.

DEFENDANT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Verification

VERIFICATION
I, [name of defendant], the above-named Defendant, do hereby verify that the contents of the
preliminary objections and the parawise reply are true and correct to my knowledge and belief.

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

Defendant

4)

Below is a proper legal format draft for a Money Recovery Suit from both sides: first, the
plaintiff’s plaint, and second, the defendant’s written statement. A money recovery suit under
the CPC generally requires clear pleading of the court name, parties, cause of action, jurisdiction,
valuation, relief, and verification, and success usually depends on proving the debt, documents,
and limitation.

Plaintiff draft

A plaint for recovery should clearly state the transaction, the amount due, the dates on which the
liability arose, the basis for interest, and the precise relief claimed.

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

IN THE MATTER OF:

[NAME OF PLAINTIFF]
S/o / D/o / W/o __________
R/o __________________________
...Plaintiff

VERSUS

[NAME OF DEFENDANT]
S/o / D/o / W/o __________
R/o __________________________
...Defendant

SUIT FOR RECOVERY OF MONEY

The Plaintiff most respectfully submits as under:

1. That the Plaintiff is a [individual / proprietorship / partnership firm / company] and is competent
to file the present suit. The present plaint is being signed and verified by [name], duly authorized
for that purpose.

2. That the Defendant is well known to the Plaintiff and resides / carries on business at the address
mentioned above.

3. That on or about __________, the Defendant approached the Plaintiff for [loan / supply of
goods / business transaction / services], and the Plaintiff, relying upon the assurances of the
Defendant, agreed to the same.

4. That pursuant thereto, the Plaintiff advanced a sum of Rs. __________ to the Defendant /
supplied goods / rendered services to the Defendant under invoice(s) / agreement(s) dated
__________.

5. That the Defendant agreed to repay the said amount / make payment within __________ days /
along with interest at the rate of __________% per annum.

6. That despite repeated oral requests and written demands, the Defendant failed and neglected to
pay the outstanding amount due to the Plaintiff.

7. That the Plaintiff issued a legal notice dated __________ calling upon the Defendant to make
payment of Rs. __________ along with interest, but the Defendant failed to comply.

8. That as on the date of filing of the present suit, a principal sum of Rs. __________ remains due
and payable by the Defendant to the Plaintiff, along with accrued interest of Rs. __________,
totaling Rs. __________.

9. That the cause of action first arose on __________ when the amount became due and payable,
and again on subsequent dates when repeated demands were made and denied. The cause of action
is continuing and subsists till date.

10. That this Hon’ble Court has territorial jurisdiction because the transaction took place /
agreement was executed / payment was to be made / Defendant resides or carries on business
within the jurisdiction of this Hon’ble Court.

11. That this Hon’ble Court has pecuniary jurisdiction as the value of the suit for recovery is Rs.
__________.

12. That the suit is within limitation, having been filed within the legally permissible period from
the date when the money became due / was acknowledged / was demanded.

13. That for the purposes of court fee and jurisdiction, the suit is valued at Rs. __________ and the
requisite court fee has been affixed.

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

a. Pass a decree in favour of the Plaintiff and against the Defendant for a sum of Rs. __________;

b. Award pendente lite and future interest at the rate of __________% per annum till realization;

c. Award costs of the suit in favour of the Plaintiff; and

d. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper in the facts
and circumstances of the case.

PLAINTIFF
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Verification

VERIFICATION

I, [name of plaintiff], the above-named Plaintiff, do hereby verify that the contents of paragraphs 1
to __ are true and correct to my knowledge and belief, and nothing material has been concealed
therefrom.

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

Plaintiff

Defendant draft

In a regular civil money suit, the defendant typically files a written statement disputing the
transaction, quantum, interest, limitation, jurisdiction, authorization, or maintainability, depending
on the facts.

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
...Plaintiff

VERSUS
[NAME OF DEFENDANT]
...Defendant

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the present suit is false, frivolous, and not maintainable either in law or on facts.

2. That the Plaintiff has suppressed material facts and has not approached this Hon’ble Court with
clean hands.

3. That the suit is barred by limitation / not properly valued / beyond jurisdiction / filed by an
unauthorized person, to the extent applicable.

4. That the Defendant does not admit the alleged liability, and the Plaintiff is put to strict proof of
the transaction, amount, and interest claimed.

5. That no cause of action has arisen against the Defendant in the manner alleged or at all.

PARAWISE REPLY

1. That paragraph 1 of the plaint is a matter of record to the extent of the Plaintiff’s description;
the rest is denied for want of knowledge.

2. That paragraph 2 is admitted / denied to the extent of the Defendant’s description.

3. That paragraph 3 is wrong and denied. The Defendant never approached the Plaintiff in the
manner alleged, or alternatively, the nature of the transaction is wrongly stated.

4. That paragraph 4 is denied. No amount as alleged was advanced by the Plaintiff to the
Defendant / no goods were supplied / no services were rendered as claimed. The alleged invoices /
documents are denied and strict proof thereof is demanded.

5. That paragraph 5 is denied. No agreement for interest at the alleged rate was ever entered into
between the parties.

6. That paragraph 6 is denied. The Defendant did not fail to pay any lawful admitted amount;
rather, no such amount is due and payable.

7. That paragraph 7 regarding legal notice is denied for want of service / admitted only to the
extent of receipt, without admitting contents.

8. That paragraph 8 is specifically denied. The amount claimed is excessive, arbitrary, inflated,
and unsupported by proper accounts or documentary evidence.
9. That paragraph 9 relating to cause of action is wrong and denied. No cause of action has arisen
in favour of the Plaintiff.

10. That paragraph 10 regarding jurisdiction is denied, and this Hon’ble Court lacks territorial /
pecuniary jurisdiction, to the extent applicable.

11. That paragraph 11 is wrong and denied if contrary to the record.

12. That paragraph 12 is denied, and the suit is barred by limitation, where applicable.

13. That paragraph 13 regarding valuation and court fee is wrong and denied / matter of record.

ADDITIONAL DEFENCE

14. That without prejudice, if any amount is found due, the Defendant submits that the claim for
interest is excessive and liable to be reduced to a reasonable rate in accordance with law.[web:53]

15. That without prejudice, the Defendant is entitled to set-off / adjustment / credit of Rs.
__________ on account of payments already made / defective goods / counter dealings, if
applicable.

PRAYER

In view of the above, it is most respectfully prayed that this Hon’ble Court may be pleased to:

a. Dismiss the suit of the Plaintiff with costs;

b. Reject the exaggerated claim of interest and unsupported amount;

c. Grant such relief as this Hon’ble Court deems fit and proper in the interest of justice.

DEFENDANT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Verification

VERIFICATION

I, [name of defendant], the above-named Defendant, do hereby verify that the contents of the
preliminary objections and parawise reply are true and correct to my knowledge and belief.

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

Defendant

Drafting points

Money recovery pleadings usually work best when supported by documents such as the
agreement, invoices, ledger, bank proof, acknowledgment, demand notice, and proof of service,
because the core issues are proof of debt, exact quantum, and limitation. Where the claim arises
from a written contract, invoice acknowledgment, cheque, or other liquidated written liability, the
plaintiff may also consider a summary procedure under Order XXXVII instead of an ordinary
recovery suit.

5)

1. Plaintiff draft – Suit for Breach of Contract

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

IN THE MATTER OF:

[NAME OF PLAINTIFF]
S/o / D/o / W/o __________
R/o __________________________
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
S/o / D/o / W/o __________
R/o __________________________
…Defendant

SUITE FOR BREACH OF CONTRACT AND DAMAGES

The Plaintiff most respectfully submits as under:

1. That the Plaintiff is a [individual / firm / company] and is competent to file the present suit. The
present plaint is being signed and verified by [name], duly authorized for that purpose.
2. That the Defendant is well known to the Plaintiff and resides / carries on business at the address
mentioned above.

3. That on or about the date of __________, the Plaintiff and Defendant entered into a written
contract / agreement dated __________ for [supply of goods / execution of work / lease of
premises / joint venture / service / construction, etc.].

4. That under the terms of the said contract, the Defendant undertook to:
(a) perform [specify exact obligation, e.g., “supply 1000 units of material by __________”];
(b) carry out [specify work] within the stipulated time;
(c) pay consideration amounting to Rs. __________ in the agreed manner;
(d) comply with other conditions, including [delivery within time, quality standards, safety
norms, etc.].

5. That the Plaintiff has fully performed all obligations imposed on it under the contract, including
payment of advance / release of materials / provision of site / cooperation as required.

6. That the Defendant failed and neglected to perform the contract in the manner agreed, and has
committed the following breaches:
(a) ____________ [e.g., delayed delivery beyond stipulated time];
(b) ____________ [e.g., supplied defective / sub-standard goods / work];
(c) ____________ [e.g., abandoned work without notice];
(d) ____________ [e.g., failed to pay agreed amount / milestone payment].

7. That the Plaintiff issued a legal notice dated __________ calling upon the Defendant to rectify
the breaches or perform the contract, but the Defendant failed to comply or offer any satisfactory
explanation.

8. That as a direct and proximate consequence of the Defendant’s breach of contract, the Plaintiff
has suffered:
(a) financial loss of Rs. __________;
(b) loss of opportunity / profit;
(c) additional expenses incurred in mitigating the loss;
(d) other consequential damages as may be proved at trial.

9. That the cause of action first arose on __________ when the Defendant first failed to perform /
breached the contract, and again on subsequent dates, and continues to arise till date.[web:54]

10. That this Hon’ble Court has territorial jurisdiction because the contract was entered into /
partly performed / to be performed, and/or Defendant resides or carries on business within the
jurisdiction of this Hon’ble Court.

11. That this Hon’ble Court has pecuniary jurisdiction as the suit is valued at Rs. __________.

12. That the suit is within limitation, having been filed within the prescribed period from the date
of breach or from the date of breach of a subsisting obligation.
13. That no other efficacious remedy is available to the Plaintiff except to seek damages / specific
performance / perpetual injunction, as appropriate.

PRAYER

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

a. Pass a decree in favour of the Plaintiff and against the Defendant for damages of Rs.
__________ with interest at __________% per annum till realization;

b. In the alternative, pass a decree for specific performance of the contract, if applicable; and/or

c. Pass a decree of permanent injunction restraining the Defendant from dealing with the
subject-matter of the contract if such relief is sought;

d. Award costs of the suit; and

e. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper.

PLAINTIFF
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Verification

VERIFICATION

I, [name of plaintiff], the above-named Plaintiff, do hereby verify that the contents of paragraphs 1
to __ are true and correct to my knowledge and belief, and nothing material has been concealed.

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

Plaintiff

2. Defendant draft – Written Statement in Breach-of-Contract Suit

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the present suit is false, frivolous, and not maintainable either in law or on facts.

2. That the Plaintiff has not approached this Hon’ble Court with clean hands and has suppressed
material facts, including its own breach of contract.

3. That the suit is barred by limitation / not properly valued / beyond jurisdiction, to the extent
applicable.

4. That the contract is [oral / unsigned / not binding / based on estoppel / terminated by
agreement], and the Plaintiff is put to strict proof of the alleged document and terms.

5. That the Plaintiff is not entitled to the relief of damages / specific performance as claimed, and
the equitable relief sought should be refused.

PARAWISE REPLY

1. That paragraph 1 of the plaint is a matter of record to the extent of the Plaintiff’s description;
the rest is denied for want of knowledge.

2. That paragraph 2 is admitted / denied to the extent of the Defendant’s description.

3. That paragraph 3 is denied. The alleged contract dated __________ does not reflect the true
understanding of the parties, or in the alternative, the terms are exaggerated / incorrectly stated.

4. That paragraph 4 is denied. The Defendant never undertook the obligations as pleaded, or the
obligations are wrongly framed. The Plaintiff is put to strict proof of the alleged clauses.

5. That paragraph 5 is denied. The Plaintiff did not perform all its obligations under the contract;
rather, the Plaintiff committed the following breaches:
(a) ___________;
(b) ___________;
(c) ___________.
6. That paragraph 6 is specifically denied. The Defendant performed the contract in accordance
with the terms; or in the alternative, the alleged breaches are minor, excusable, or caused by the
Plaintiff’s own conduct.

7. That paragraph 7 regarding legal notice is denied for want of service / admitted only to the
extent of receipt, without admitting the contents.

8. That paragraph 8 is wrong and denied. The Plaintiff has not suffered any loss as alleged, or the
alleged damages are exaggerated, speculative, not proximately caused by the Defendant, and not
liquidated.

9. That paragraph 9 on cause of action is denied. The Plaintiff has not set out a proper cause of
action in law.

10. That paragraph 10 regarding jurisdiction is denied, and this Hon’ble Court lacks territorial /
pecuniary jurisdiction, if applicable.

11. That paragraph 11 is denied to the extent contrary to the record.

12. That paragraph 12 is denied, and the suit is barred by limitation.

13. That paragraph 13 is denied, and the Plaintiff has an alternative remedy (e.g., arbitration /
termination of contract / mutual settlement).

ADDITIONAL DEFENCE

14. That without prejudice, the Defendant is entitled to set-off or adjustment of Rs. __________
against the Plaintiff for services rendered / goods supplied / expenses incurred by the Defendant.

15. That the contract is discharged / terminates / frustrated / rescinded by reason of the Plaintiff’s
own breach or conduct beyond the Defendant’s control.

PRAYER

In view of the above, it is most respectfully prayed that this Hon’ble Court may be pleased to:

a. Dismiss the suit of the Plaintiff with costs;

b. Refuse the claim for damages / specific performance / injunction as pleaded;

c. Pass such other or further order as this Hon’ble Court may deem fit and proper.

DEFENDANT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Verification

VERIFICATION

I, [name of defendant], the above-named Defendant, do hereby verify that the contents of the
preliminary objections and parawise reply are true and correct to my knowledge and belief.

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

Defendant

3.

1. Suit for Recovery under Order XXXVII of CPC

(a) Defendant – Written Statement (defence against Order XXXVII recovery)

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the present suit is not maintainable under Order XXXVII of the Code of Civil Procedure,
1908, as the Plaintiff’s claim is not based solely on a negotiable instrument, written contract, or
liquidated demand in money, and there is a serious dispute as to the genuineness and liability.
2. That the Defendant does not admit the alleged debt, and the Plaintiff is put to strict proof of the
instrument / contract, consideration, and the exact amount claimed.

3. That the Defendant denies the genuineness and enforceability of the cheque / promissory note /
invoice / written acknowledgment relied upon by the Plaintiff, and demands strict proof thereof.

4. That the Defendant has not admitted any amount, and the Plaintiff is not entitled to the benefit
of the summary procedure under Order XXXVII of the CPC, and therefore the suit should be
treated as an ordinary suit.

5. That, in the alternative, if any amount is admitted, the Defendant is ready to deposit the
admitted sum, but the Defendant has a bona fide defence on the balance of the claim.

PARAWISE REPLY

1. That paragraph 1 of the plaint is admitted to the extent of the Plaintiff’s description, and denied
in the rest.

2. That paragraph 2 is admitted to the extent of the Defendant’s description, and denied in the rest.

3. That paragraph 3 relating to the alleged negotiable instrument / written contract is wrong and
denied; the same is not binding on the Defendant, or is disputed.

4. That paragraph 4 stating that a sum of Rs. __________ became due is wrong and denied; the
Defendant admits no such amount.

5. That paragraph 5 regarding acknowledgment of liability is denied; the Defendant has not
acknowledged the debt as alleged.

6. That paragraph 6 regarding legal notice is denied for want of service, or admitted only to the
extent of receipt without admitting the contents.

7. That paragraph 7 regarding cause of action and jurisdiction is denied to the extent contrary to
the record.

8. That paragraph 8 regarding limitation and court fee is denied, and the suit is not in time /
wrongly valued.

PRAYER

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

a. Dismiss the suit with costs; or in the alternative,

b. Treat the suit as an ordinary suit and grant the Defendant leave to defend with such conditions
as this Hon’ble Court may deem fit;
c. Pass such other order(s) as this Hon’ble Court may deem fit in the interest of justice.

DEFENDANT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

(b) Plaintiff – Reply-style written statement (defendant-side defence followed)

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

REPLY TO THE WRITTEN STATEMENT OF THE DEFENDANT

The Plaintiff most respectfully submits as under:

1. That the present suit is filed under Order XXXVII of the CPC, being a suit for recovery of a
**liquidated demand in money** based on a written contract / negotiable instrument /
acknowledged liability within the curves of the said Order.

2. That the Defendant’s written statement is evasive, vague, and not supported by credible
evidence; the Defendant disputes the very documents on the basis of which the liability is
established.

3. That the Plaintiff’s documentary evidence (cheque bearing no. ____, dated ____, invoice nos.
____ etc., written acknowledgment dated ____) conclusively proves the amount due and payable
by the Defendant.

4. That the Defendant has not disclosed any substantial or bona fide defence, and the objections
raised are not sufficient to defeat the Plaintiff’s claim; the Defendant is not entitled to
unconditional leave to defend.
5. That the Plaintiff reiterates the prayer in the plaint for a decree of recovery of the stipulated sum
of Rs. __________ with interest at __________% per annum till realization, and costs of the suit
in favour of the Plaintiff.

PLAINTIFF
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

2. Suit for Permanent Injunction

(a) Defendant – Written Statement opposing injunction

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the suit for permanent injunction is not maintainable, as the Plaintiff is not in lawful,
peaceful, and adverse possession of the suit property, and the Defendant has lawful rights and
interest.

2. That the Defendant has not committed any unlawful interference with the Plaintiff’s possession;
the Defendant’s acts are lawful and justified, and the Plaintiff is not entitled to the equitable relief
of injunction.

3. That the Plaintiff has approached the Court without clean hands, having suppressed material
facts, including defects in title, disputes with third parties, and prior conduct of the Defendant.
4. That there is no continuous or threatened breach of the Plaintiff’s right, and the balance of
convenience favours the Defendant or the public interest.

5. That the Plaintiff is not entitled to the reliefs of perpetual injunction, damages, or costs as
claimed.

PARAWISE REPLY

1. That paragraph 1 of the plaint is admitted only to the extent of the Plaintiff’s description, and
denied in the rest.

2. That paragraph 2 regarding possession of the suit property is denied; the Defendant is in lawful
possession of its own portion / has lawful easement / right of way, etc.

3. That paragraph 3 alleging interference is wrong and denied; the Defendant has not done
anything unlawful or without lawful right.

4. That paragraph 4 regarding threats / attempts to dispossess is denied; no such incident ever took
place.

5. That paragraph 5 on cause of action, jurisdiction, and limitation is denied to the extent contrary
to the record.

6. That paragraph 6 seeking permanent injunction and damages is denied in toto.

PRAYER

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

a. Dismiss the suit for permanent injunction with costs;

b. Decline to grant any decree of injunction or damages against the Defendant; and

c. Pass such other order as this Hon’ble Court may deem fit.

DEFENDANT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

(b) Plaintiff – Reply-style written statement to defendant’s defence

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

REPLY TO THE WRITTEN STATEMENT OF THE DEFENDANT

The Plaintiff most respectfully submits as under:

1. That the Plaintiff is in **lawful, peaceful, and adverse possession** of the suit property, and the
Defendant has no right to interfere with the Plaintiff’s enjoyment of the same.

2. That the Defendant’s alleged acts of interference, encroachment, and threatening conduct are
continuing and recurrent, and if not restrained, the Plaintiff will suffer irreparable loss and injury.

3. That the balance of convenience and the considerations of equity are in favour of the Plaintiff,
and the Plaintiff has approached the Court with clean hands, having disclosed all material facts.

4. That the Defendant’s objections about title or possession are matters of evidence, and cannot be
a bar to grant of a decree of permanent injunction to protect the Plaintiff’s civil right.

5. That the Plaintiff reiterates the prayer in the plaint for a decree of permanent injunction
restraining the Defendant from interfering with the Plaintiff’s possession, along with costs of the
suit.

PLAINTIFF
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

3. Suit for Dissolution of Partnership

(a) Defendant – Written Statement resisting dissolution

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the present suit for dissolution of partnership is not maintainable, as the firm is still viable
and capable of continuing business in accordance with the partnership deed.

2. That the Plaintiff has not pleaded or proved any ground of dissolution under Section 44 of the
Indian Partnership Act, 1932, such as the conduct rendering business impossible or other just and
equitable grounds.

3. That the Defendant has not committed any breach of the partnership deed; the Defendant has
been carrying on the business honestly and in good faith.

4. That the Plaintiff has suppressed material facts, including its own defaults, non-payment of
capital, and mis-application of funds, and is not entitled to seek dissolution.

5. That the Plaintiff is not entitled to the reliefs of dissolution of the firm, rendition of accounts,
and distribution of assets.

PARAWISE REPLY

1. That paragraph 1 of the plaint is admitted to the extent of the Plaintiff’s description, and denied
in the rest.

2. That paragraph 2 relating to the partnership deed dated __________ is denied; the Defendant
denies the terms alleged and demands strict proof of the document.

3. That paragraph 3 regarding profit-sharing ratio is denied; the Defendant denies the percentage
stated and claims the same as per the true deed.

4. That paragraph 4 alleging breach of the deed is wrong and denied; the Defendant has not
committed any such breach.

5. That paragraph 5 on mis-appropriation and refusal to render accounts is denied; the Defendant
is ready to open books for inspection and settle accounts mutually.
6. That paragraph 6 seeking dissolution, accounts, and distribution is denied in toto.

PRAYER

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

a. Dismiss the suit for dissolution of partnership with costs;

b. Decline to dissolve the partnership firm M/s ____________________; and

c. Pass such other order as this Hon’ble Court may deem fit.

DEFENDANT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

(b) Plaintiff – Reply-style written statement (defendant-side defence)

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

REPLY TO THE WRITTEN STATEMENT OF THE DEFENDANT

The Plaintiff most respectfully submits as under:

1. That the Plaintiff is a bonafide partner in the firm M/s ____________________, and the
partnership deed dated __________ clearly establishes the rights and obligations of the parties,
including the profit-sharing ratio and management structure.

2. That the Defendant has persistently and contumaciously refused to render true accounts,
excluded the Plaintiff from management, and mis-applied partnership funds, thereby rendering it
impossible to carry on the firm in partnership.
3. That the Defendant’s conduct satisfies the conditions for dissolution of the partnership by court
under Section 44 of the Indian Partnership Act, 1932, and the Plaintiff is entitled to a decree of
dissolution.

4. That the Defendant’s denial of breach and offers to open accounts are merely dilatory tactics,
and the Defendant has not produced any credible evidence to contradict the Plaintiff’s pleadings.

5. That the Plaintiff reiterates the prayer in the plaint for decree of dissolution of the partnership,
rendition of true accounts, and distribution of the surplus among the partners as per their lawful
shares.

PLAINTIFF
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

4. Money recovery suit (ordinary suit)

(a) Defendant – Written Statement resisting recovery

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the present suit for recovery of money is false, frivolous, and not maintainable either in
law or on facts.
2. That the Defendant does not admit the alleged debt of Rs. __________, and the Plaintiff is put
to strict proof of the transaction, agreement, and consideration.

3. That the Defendant has either fully discharged the alleged liability or is entitled to set-off /
adjustment for counter-claims (e.g., defective goods, unrecovered dues, etc.).

4. That the suit is barred by limitation and/or the Plaintiff has not proved service of notice, if
required.

5. That the Plaintiff is not entitled to the relief of recovery of money as claimed, with interest and
costs.

PARAWISE REPLY

1. That paragraph 1 of the plaint is admitted to the extent of the Plaintiff’s description, and denied
in the rest.

2. That paragraph 2 is admitted to the extent of the Defendant’s description, and denied in the rest.

3. That paragraph 3 regarding the loan / supply of goods / transaction is wrong and denied; the
Defendant denies that any such advance was made / goods supplied as alleged.

4. That paragraph 4 regarding the amount due is wrong and denied; the Defendant admits no such
sum.

5. That paragraph 5 on notice and demand is denied for want of service, or admitted only to the
extent of receipt without admitting contents.

6. That paragraph 6 on cause of action, jurisdiction, and limitation is denied to the extent contrary
to the record.

7. That paragraph 7 on valuation and court fee is denied.

PRAYER

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

a. Dismiss the suit for recovery of money with costs;

b. Refuse the decree for recovery of the principal sum, interest, and costs; and

c. Pass such other order as this Hon’ble Court may deem fit.

DEFENDANT
Through Counsel
[Name of Advocate]
Place: __________
Date: __________

(b) Plaintiff – Reply-style written statement (defendant-side defence)

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

REPLY TO THE WRITTEN STATEMENT OF THE DEFENDANT

The Plaintiff most respectfully submits as under:

1. That the Plaintiff reaffirms the genuineness of the transaction, agreement, invoice, and
delivery / performance, all of which are supported by documentary evidence on record.

2. That the Defendant’s denial is evasive and not supported by credible evidence; the Defendant
has not produced any proof of payment or adjustment of the alleged amount.

3. That the Plaintiff has proved the cause of action, timely demand, and non-payment of the
admitted or proved sum of Rs. __________.

4. That the Defendant’s claim of set-off or adjustment is not substantiated by documentary proof,
and the Plaintiff denies the existence of such counter-claims.

5. That the Plaintiff reiterates the prayer in the plaint for decree for recovery of the principal sum
of Rs. __________ with interest at __________% per annum till realization, and costs of the suit
in favour of the Plaintiff.

PLAINTIFF
Through Counsel
[Name of Advocate]

Place: __________
Date: __________
5. Breach of Contract suit

(a) Defendant – Written Statement denying breach

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff

VERSUS

[NAME OF DEFENDANT]
…Defendant

WRITTEN STATEMENT ON BEHALF OF THE DEFENDANT

The Defendant most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the present suit for breach of contract is not maintainable, as the alleged contract is either
oral, not binding, or not duly proved, and the Plaintiff is not entitled to the relief claimed.

2. That the Defendant denies breach of the contract; the Defendant has performed all its
obligations, or has performed substantially in accordance with the terms.

3. That the Plaintiff itself has breached the contract (e.g., non-payment, defective instructions,
non-delivery of materials, etc.), and the Plaintiff is not entitled to damages or specific
performance.

4. That the alleged damages are speculative, not proved, and not proximately caused by the
Defendant’s conduct, and are not admissible under the law of damages.

5. That the contract is discharged, frustrated, or terminated by mutual consent / impossibility, and
the Plaintiff cannot claim continuation of the contract or decree of specific performance.

PARAWISE REPLY

1. That paragraph 1 of the plaint is admitted to the extent of the Plaintiff’s description, and denied
in the rest.

2. That paragraph 2 regarding the existence of the contract dated __________ is denied; the
Defendant denies the terms alleged and demands strict proof of the document.
3. That paragraph 3 regarding the Defendant’s obligation to perform [specify work / supply] is
denied; the Defendant has performed or substantially performed as per the terms.

4. That paragraph 4 alleging breach and non-performance is denied; the Defendant has not failed
to perform the contract.

5. That paragraph 5 on damages, profit-loss, and expenses is denied as speculative and

unsupported by evidence.

6. That paragraph 6 on cause of action, limitation, and jurisdiction is denied to the extent contrary
to the record.

7. That paragraph 7 on specific performance / injunction is denied.

PRAYER

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

a. Dismiss the suit for breach of contract with costs;

b. Refuse the decree for damages / specific performance / injunction as claimed by the Plaintiff;

c. Hold that the alleged contract is either not binding, discharged, or not proved, and that the
Defendant is not liable for any breach;

d. Pass such other or further order as this Hon’ble Court may deem fit in the interest of justice.

DEFENDANT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Below is a plaintiff-side, defendant-style structure for the Breach of Contract suit (i.e., when
the plaintiff is replying to the defendant’s defence). This is a reply-to-written-statement, written
in the same legal format you asked for.

IN THE COURT OF THE HON’BLE __________ AT __________

Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
…Plaintiff
VERSUS

[NAME OF DEFENDANT]
…Defendant

REPLY TO THE WRITTEN STATEMENT OF THE DEFENDANT

The Plaintiff most respectfully submits as under:

1. That the Plaintiff reaffirms the genuineness of the contract dated __________ entered into
between the Plaintiff and the Defendant for __________, and the terms of the said contract are
binding and enforceable on the Defendant.

2. That the Defendant has clearly failed to perform the contract in the manner agreed upon; the
Defendant either failed to supply the goods / render the services / complete the work within the
stipulated time, or supplied defective / sub-standard goods / work, in breach of the express terms.

3. That the Plaintiff has fully performed all its obligations under the contract, including payment
of the agreed consideration / advance / milestone amounts, as required, and the Plaintiff has not
committed any breach of the contract.

4. That as a direct and proximate consequence of the Defendant’s breach, the Plaintiff has suffered
financial loss of Rs. __________, along with loss of profit, additional expenses, and other
consequential damages, which are discernible and recoverable in law.

5. That the Defendant’s allegations of Plaintiff’s own breach, discharge, frustration, or termination
of the contract are false, exaggerated, and not supported by documentary evidence; the Defendant
is not entitled to rely on such self-serving defences.

6. That the Plaintiff is entitled to:

(a) damages for the loss suffered; and
(b) in the alternative, if applicable, specific performance of the contract or decree of injunction,
as prayed in the plaint.

7. That the Plaintiff reiterates the prayer in the plaint for a decree in favour of the Plaintiff and
against the Defendant for damages of Rs. __________ with interest at __________% per annum
till realization, and costs of the suit in favour of the Plaintiff.

PLAINTIFF
Through Counsel
[Name of Advocate]

Place: __________
Date: __________
4. Below is a proper legal-format set of applications from both sides for the four matters you
listed. Under Indian civil procedure, these are ordinarily filed as interlocutory or appellate
pleadings with title, cause-title, material facts, grounds, prayer, and verification/affidavit.

1. Section 5 Limitation Act

Section 5 is generally used to seek condonation of delay by showing “sufficient cause” for not
filing the appeal or application within limitation, and the applicant should clearly state the period
of delay, the dates, and the reasons in a chronological manner.

Applicant side

IN THE COURT OF THE HON’BLE __________ AT __________

Misc. Application No. ____ of 20__

In
[Appeal / Application / Suit] No. ____ of 20__

[NAME OF APPLICANT]
...Applicant

VERSUS

[NAME OF RESPONDENT]
...Respondent

APPLICATION UNDER SECTION 5 OF THE LIMITATION ACT, 1963

FOR CONDONATION OF DELAY

The Applicant most respectfully submits as under:

1. That the Applicant has filed / is filing the accompanying [appeal / application] against the
order / decree dated __________ passed by the Ld. __________ in __________.

2. That the limitation for filing the said proceeding expired on __________, whereas the present
proceeding has been filed on __________, resulting in a delay of ______ days.

3. That the delay occurred due to bona fide and unavoidable reasons, namely: __________ [illness
/ late receipt of certified copy / wrong legal advice / family emergency / settlement talks / other
sufficient cause].

4. That the delay was neither intentional nor deliberate, but occurred despite due diligence and for
reasons beyond the control of the Applicant.

5. That the Applicant has a good prima facie case on merits, and grave prejudice will be caused if
the delay is not condoned.
6. That no prejudice beyond ordinary litigation inconvenience will be caused to the Respondent if
the delay is condoned, whereas refusal would defeat substantial justice.

PRAYER

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

a. Condone the delay of ______ days in filing the accompanying [appeal / application];

b. Take the accompanying [appeal / application] on record; and

c. Pass such other order(s) as this Hon’ble Court may deem fit and proper.

APPLICANT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

Respondent side

IN THE COURT OF THE HON’BLE __________ AT __________

Misc. Application No. ____ of 20__

In
[Appeal / Application / Suit] No. ____ of 20__

[NAME OF APPLICANT]
...Applicant

VERSUS

[NAME OF RESPONDENT]
...Respondent

REPLY / OBJECTIONS TO APPLICATION UNDER SECTION 5 OF THE LIMITATION ACT

The Respondent most respectfully submits as under:

1. That the application is false, misconceived, and liable to be dismissed as the Applicant has
failed to disclose any sufficient cause for condonation of delay.

2. That the delay of ______ days is inordinate and unexplained, and the reasons stated are vague,
omnibus, and unsupported by documents.
3. That the Applicant has been grossly negligent and has not acted with due diligence, and
therefore is not entitled to equitable discretionary relief under Section 5.

4. That the plea of illness / legal advice / late knowledge is an afterthought and has been raised
only to overcome the bar of limitation.

5. That valuable rights have accrued in favour of the Respondent by lapse of limitation, and such
rights ought not to be disturbed casually.

PRAYER

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

a. Dismiss the application for condonation of delay; and

b. Pass such other order as this Hon’ble Court may deem fit.

RESPONDENT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

2. Setting aside ex parte decree

An application to set aside an ex parte decree is ordinarily made under Order IX Rule 13 CPC
before the same court that passed the decree, generally on the grounds that summons were not duly
served or that the defendant was prevented by sufficient cause from appearing.

Applicant / defendant side

IN THE COURT OF THE HON’BLE __________ AT __________

Misc. Application No. ____ of 20__

In
Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF]
...Plaintiff

VERSUS

[NAME OF DEFENDANT / APPLICANT]

...Defendant / Applicant
APPLICATION UNDER ORDER IX RULE 13 CPC
FOR SETTING ASIDE EX PARTE DECREE

The Applicant most respectfully submits as under:

1. That the above suit was decreed ex parte against the Applicant on __________ by this Hon’ble
Court.

2. That the Applicant came to know of the said ex parte decree only on __________ when
__________ [execution notice / demand notice / copy of decree] was received.

3. That the summons in the suit were never duly served upon the Applicant, and therefore the
Applicant could not appear before this Hon’ble Court on the relevant date.

4. That alternatively, even if service is assumed, the Applicant was prevented by sufficient cause
from appearing on the date fixed for hearing due to __________ [illness / mistaken noting of date /
unavoidable circumstance].

5. That the Applicant has a substantial defence on merits and grave injustice will result if the ex
parte decree is allowed to stand.

6. That the present application is within limitation / accompanied by an application for

condonation of delay, if required.

PRAYER

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

a. Set aside the ex parte decree dated __________ passed in Civil Suit No. ____ of 20__;

b. Restore the suit to its original number; and

c. Permit the Applicant to contest the suit on merits.

DEFENDANT / APPLICANT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

Plaintiff / respondent side

IN THE COURT OF THE HON’BLE __________ AT __________

Misc. Application No. ____ of 20__
In
Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF / RESPONDENT]

...Plaintiff / Respondent

VERSUS

[NAME OF DEFENDANT / APPLICANT]

...Defendant / Applicant

REPLY / OBJECTIONS TO APPLICATION UNDER ORDER IX RULE 13 CPC

The Respondent most respectfully submits as under:

1. That the application is false, frivolous, and liable to be dismissed.

2. That the summons in the original suit were duly served upon the Applicant in accordance with
law, and the record of the case clearly proves due service.

3. That the Applicant intentionally avoided appearance and is now attempting to delay the
execution and fruits of the decree.

4. That no sufficient cause has been shown for non-appearance on the relevant date, and the
reasons now stated are false and afterthoughts.

5. That the Applicant has not approached the Court with clean hands and has suppressed material
facts concerning service and prior knowledge of the proceedings.

PRAYER

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

a. Dismiss the application under Order IX Rule 13 CPC with costs; and

b. Pass such other order as this Hon’ble Court may deem fit.

PLAINTIFF / RESPONDENT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

3. Temporary injunction
Order XXXIX Rules 1 and 2 CPC permit a temporary injunction where property in dispute is in
danger of waste, alienation, or dispossession, or where the defendant threatens injury or repetition
of breach; notice should ordinarily be given unless delay would defeat the object of injunction.

Plaintiff / applicant side

IN THE COURT OF THE HON’BLE __________ AT __________

I.A. No. ____ of 20__

In
Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF / APPLICANT]

...Plaintiff / Applicant

VERSUS

[NAME OF DEFENDANT / RESPONDENT]

...Defendant / Respondent

APPLICATION UNDER ORDER XXXIX RULES 1 AND 2 CPC

FOR GRANT OF TEMPORARY INJUNCTION

The Applicant most respectfully submits as under:

1. That the Applicant has filed the accompanying suit for __________ and the same is pending
before this Hon’ble Court.

2. That the Applicant has a strong prima facie case in the suit, as set out in the plaint and
supporting documents.

3. That the Defendant is threatening to alienate / waste / damage the suit property, or to dispossess
the Applicant, or to continue the breach / injury complained of.

4. That unless restrained by an interim order, the Applicant will suffer irreparable loss and injury
which cannot be adequately compensated in money.

5. That the balance of convenience lies in favour of the Applicant, and against the Defendant.

6. That the object of the application will be defeated by delay and therefore urgent ex parte
protection is necessary / or notice may be issued, as the Court deems fit.

PRAYER

It is therefore most respectfully prayed that this Hon’ble Court may be pleased to:
a. Restrain the Defendant, his agents, servants, representatives, and all persons claiming through
him from __________ during pendency of the suit; and

b. Pass such further order(s) as this Hon’ble Court may deem fit.

PLAINTIFF / APPLICANT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

Defendant / respondent side

IN THE COURT OF THE HON’BLE __________ AT __________

I.A. No. ____ of 20__

In
Civil Suit No. ____ of 20__

[NAME OF PLAINTIFF / APPLICANT]

...Plaintiff / Applicant

VERSUS

[NAME OF DEFENDANT / RESPONDENT]

...Defendant / Respondent

REPLY / OBJECTIONS TO APPLICATION UNDER ORDER XXXIX RULES 1 AND 2 CPC

The Respondent most respectfully submits as under:

1. That the application is misconceived and liable to be dismissed, as the Applicant has no prima
facie case.

2. That the Respondent has not threatened to alienate, waste, damage, or dispossess the Applicant
in the manner alleged.

3. That the balance of convenience does not lie in favour of the Applicant; on the contrary, the
Respondent will suffer grave prejudice if restrained.

4. That no irreparable injury will be caused to the Applicant, and the alleged injury, if any, is
compensable in money.

5. That the Applicant has suppressed material facts and has not approached this Hon’ble Court
with clean hands; therefore, no equitable discretionary relief should be granted.
PRAYER

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

a. Dismiss the application under Order XXXIX Rules 1 and 2 CPC; and

b. Vacate any ad interim ex parte order, if already granted.

DEFENDANT / RESPONDENT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

4. Appeal from original decree

An appeal from an original decree is generally governed by Section 96 CPC read with Order
XLI CPC, and the memorandum of appeal should identify the impugned decree, the facts, and the
grounds of challenge.

Appellant side

IN THE COURT OF THE HON’BLE __________ AT __________

First Appeal No. ____ of 20__

[NAME OF APPELLANT]
...Appellant

VERSUS

[NAME OF RESPONDENT]
...Respondent

MEMORANDUM OF APPEAL UNDER SECTION 96 CPC

READ WITH ORDER XLI CPC

The Appellant most respectfully submits as under:

1. That the present appeal is directed against the judgment and decree dated __________ passed
by the Ld. __________ in Civil Suit No. ____ of 20__, whereby the suit of the Plaintiff was
decreed / dismissed.

2. That the certified copy of the impugned judgment and decree is filed herewith.
3. That the impugned judgment and decree are contrary to law, facts, and evidence on record, and
are liable to be set aside.

GROUNDS OF APPEAL

a. Because the Ld. Trial Court failed to appreciate the pleadings and evidence in their correct
perspective.

b. Because the findings recorded are perverse, contrary to the material on record, and based on
misreading of evidence.

c. Because the Ld. Trial Court failed to apply the correct principles of law and has caused grave
miscarriage of justice.

d. Because the judgment and decree under challenge are otherwise unsustainable in law.

PRAYER

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

a. Admit the appeal;

b. Call for the record of the trial court;

c. Set aside / modify the judgment and decree dated __________ passed in Civil Suit No. ____ of
20__;

d. Decree / dismiss the suit in terms of the Appellant’s case; and

e. Pass such other order(s) as this Hon’ble Court may deem fit.

APPELLANT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

Respondent side

IN THE COURT OF THE HON’BLE __________ AT __________

First Appeal No. ____ of 20__

[NAME OF APPELLANT]
 ...Appellant

VERSUS

[NAME OF RESPONDENT]
...Respondent

REPLY / OBJECTIONS ON BEHALF OF THE RESPONDENT

The Respondent most respectfully submits as under:

1. That the present appeal is devoid of merit and liable to be dismissed.

2. That the impugned judgment and decree dated __________ have been passed after proper
appreciation of pleadings, evidence, and applicable law.

3. That the findings of the Ld. Trial Court are findings of fact and law based on the record, and no
ground for interference in appeal is made out.

4. That the grounds raised in the memorandum of appeal are vague, general, and contrary to the
record.

5. That the appeal is filed only to delay the operation and execution of the lawful decree.

PRAYER

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

a. Dismiss the appeal with costs;

b. Affirm the impugned judgment and decree dated __________; and

c. Pass such other order as this Hon’ble Court may deem fit.

RESPONDENT
Through Counsel
[Advocate Name]

Place: __________
Date: __________

5.

Below are five kinds of writ petitions—Habeas Corpus, Mandamus, Prohibition, Certiorari,
and Quo-Warranto—each from both sides (petitioner and respondent) in proper legal-format
style you can adapt for filing. In India, writs are filed under Article 226 (or Article 32) of the
Constitution and must clearly state jurisdiction, cause-title, facts, breach of legal right, and the
specific relief sought.

1. Writ of Habeas Corpus

Usually filed to challenge unlawful detention or custody of a person by the State or any authority.

(a) Petitioner side – Habeas Corpus petition

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
(Next friend / Legal guardian / Himself / Herself, as applicable)
R/o __________________________
…Petitioner

VERSUS

[NAME OF RESPONDENT / STATE AUTHORITY]

e.g., State of Maharashtra / Police Inspector / Jail Superintendent
…Respondent

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

FOR A WRIT OF HABEAS CORPUS

The Petitioner most respectfully submits as under:

1. That the Petitioner is a citizen of India and is competent to invoke the writ jurisdiction of this
Hon’ble Court under Article 226 of the Constitution of India.

2. That the person in detention, namely [Name], aged ____, is the __________ of the Petitioner,
and is presently lodged in custody / under detention at [Jail / Police Station] under [Act / Section /
Case No. / Order No.].

3. That the detention of the said person is without lawful authority, or is in violation of the
provisions of [relevant statute / procedure], and is therefore illegal and unconstitutional.

4. That the Petitioner has not been furnished with proper reasons for the detention, and the
detention order / warrant is either non-existent, defective, or passed without following the
mandatory procedure.
5. That the detention amounts to a violation of the fundamental right of the detainee under Article
21 of the Constitution of India, and the Petitioner is entitled to seek the writ of Habeas Corpus.

6. That the Petitioner has no other efficacious remedy except to approach this Hon’ble Court.

PRAYER

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

a. Issue a writ of Habeas Corpus commanding the Respondent to produce the body of [Name]
before this Hon’ble Court;

b. Declare the detention illegal and issue an immediate order for the release of the said person;

c. Pass such other or further orders as this Hon’ble Court may deem fit and proper in the interest of
justice.

PETITIONER
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

(b) Respondent side – Reply / Affidavit-in-opposition to Habeas Corpus

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
…Petitioner

VERSUS

[NAME OF RESPONDENT]
…Respondent

AFFIDAVIT-IN-OPPOSITION TO WRIT OF HABEAS CORPUS

I, [Name], holding the office of __________ (e.g., Superintendent of Police / Jail Superintendent),
presently working at __________, do hereby solemnly affirm and state:

1. That I am the Respondent / deponent in the above writ petition and am competent to depose in
the matter.
2. That the person in question, namely [Name], is presently in lawful custody under the order of
[Magistrate / Court / Authority] passed in [Case No. / Order No.] dated __________, under
Section ______ of [Act].

3. That the detention is neither arbitrary nor illegal, and has been carried out in strict compliance
with the statutory provisions and procedural safeguards.

4. That the detention order is supported by sufficient material, and there is a legitimate ground for
preventive / punitive custody as per the provisions of law.

5. That the Petitioner’s application is misconceived and premature, and the detention is in
accordance with the law and not in violation of Article 21 of the Constitution.

6. That if the Petitioner desires, the matter is already pending before the competent court, and the
proper forum for challenge is the appropriate judicial remedy.

PRAYER

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

a. Dismiss the Habeas Corpus petition; and

b. Uphold the legality of the detention proceedings.

DEPONENT
[Name]

Place: __________
Date: __________

2. Writ of Mandamus

Usually filed to direct a public authority to perform its legal duty that it has refused or failed to
discharge.

(a) Petitioner side – Mandamus petition

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
R/o __________________________
…Petitioner
VERSUS

[NAME OF RESPONDENT]
(State / Authority / Officer Title)
…Respondent

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

FOR A WRIT OF MANDAMUS

The Petitioner most respectfully submits as under:

1. That the Petitioner is a citizen of India and is aggrieved by the failure and refusal of the
Respondent to perform a public / statutory duty under __________ [Act / Rule / Notification].

2. That the Respondent is duty-bound under the said provisions to [grant license / pass order /
register document / release dues / grant promotion / issue certificate, etc.], and the said duty is
ministerial and non-discretionary in nature.

3. That despite repeated representations and requests, the Respondent has failed and neglected to
pass the necessary order / perform the statutory duty, thereby causing substantial prejudice to the
Petitioner.

4. That the Petitioner has no adequate alternative remedy except to seek the writ of Mandamus
from this Hon’ble Court under Article 226 of the Constitution.

5. That the Petitioner is therefore entitled to a writ of Mandamus directing the Respondent to
perform the said legal duty within a reasonable time.

PRAYER

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

a. Issue a writ of Mandamus directing the Respondent to perform the duty of [describe duty]
without further delay;

b. Direct the Respondent to pass the necessary order / decision in terms of the said duty;

c. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper.

PETITIONER
Through Counsel
[Name of Advocate]

Place: __________
Date: __________
(b) Respondent side – Reply / Affidavit-in-opposition to Mandamus

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
…Petitioner

VERSUS

[NAME OF RESPONDENT]
…Respondent

AFFIDAVIT-IN-OPPOSITION TO WRIT OF MANDAMUS

I, [Name], holding the office of __________, presently working at __________, do hereby affirm:

1. That I am the Respondent in the above writ petition, and the allegations against me are false,
misconceived, and ex-parte.

2. That the matter is pending consideration / the Petitioner has not approached the authority with
clean hands and has not fulfilled the necessary conditions for the grant of relief.

3. That the authority in question has not failed to perform any duty; the matter is either under
processing or is covered by a valid decision / policy, which is subject to normal review/remedy, if
any.

4. That the Petitioner has an adequate alternative remedy, such as appeal / revision / regular civil
proceeding, and the writ of Mandamus is not maintainable or not warranted in this case.

5. That the Petitioner’s claim is premature, and the authority is entitled to take a final decision
only after due procedure and verification.

PRAYER

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

a. Dismiss the writ petition for Mandamus; and

b. Hold that the Respondent has not failed to perform any legal duty.

DEPONENT
[Name]

Place: __________
Date: __________

3. Writ of Prohibition

Usually filed to prevent a lower court or tribunal from acting beyond its jurisdiction or with a
violation of natural justice.

(a) Petitioner side – Prohibition petition

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
R/o __________________________
…Petitioner

VERSUS

[NAME OF RESPONDENT]
(Lower Court / Tribunal / Authority)
…Respondent

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

FOR A WRIT OF PROHIBITION

The Petitioner most respectfully submits as under:

1. That the Respondent, being a subordinate / quasi-judicial authority, was acting in exercise of its
jurisdiction in [Case No. __________] involving the Petitioner.

2. That the Respondent has exceeded its jurisdiction / acted in violation of the principles of natural
justice / without following the mandatory procedure, and its order is liable to be nullified.

3. That during the pendency of the proceedings, the Respondent intends to pass another order /
continue proceedings, which would be in excess of its jurisdiction, and therefore, an immediate
writ of Prohibition is necessary to prevent the exercise of such jurisdiction.

4. That failure to grant the writ will cause irreparable injury to the Petitioner, and the Petitioner
has no other adequate remedy.

5. That the Petitioner is therefore entitled to a writ of Prohibition restraining the Respondent from
proceeding further in the said matter.

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

a. Issue a writ of Prohibition commanding the Respondent to stay / cease all further proceedings in
[Case No. / Matter] pending before it;

b. Hold that the Respondent has no jurisdiction to proceed with the said matter in its present
posture;

c. Pass such other or further order as this Hon’ble Court may deem fit and proper.

PETITIONER
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

(b) Respondent side – Reply / Affidavit-in-opposition to Prohibition

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
…Petitioner

VERSUS

[NAME OF RESPONDENT]
…Respondent

AFFIDAVIT-IN-OPPOSITION TO WRIT OF PROHIBITION

I, [Name], holding the office of __________ (e.g., Presiding Officer / Magistrate / Tribunal
Member), currently working at __________, do hereby affirm:

1. That the allegation that this Hon’ble Court issued a writ of Prohibition against the Respondent is
false and misconceived, and the Respondent is exercising only such jurisdiction as conferred by
law.

2. That the proceedings are being conducted in accordance with the law, rules of natural justice,
and the statutory provisions, and therefore, there is no basis for the issue of Prohibition.
3. That the Petitioner has not approached the proper forum for redressal and is attempting to
bypass the normal appellate / revisional remedy, which is not maintainable by way of writ.

4. That the writ of Prohibition is not warranted, because the Respondent is not acting in excess of
jurisdiction but in the proper exercise of its lawful powers.

5. That the Petitioner has not suffered any material prejudice, and the continuation of the
proceedings will not cause irreparable harm.

PRAYER

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

a. Dismiss the writ petition for Prohibition; and

b. Hold that the Respondent is within its jurisdiction and entitled to continue the proceedings.

DEPONENT
[Name]

Place: __________
Date: __________

4. Writ of Certiorari

Usually filed to quash an illegal order/order passed without jurisdiction of a lower court,
tribunal, or authority.

(a) Petitioner side – Certiorari petition

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
R/o __________________________
…Petitioner

VERSUS

[NAME OF RESPONDENT]
(Lower Court / Tribunal / Authority)
…Respondent

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

FOR A WRIT OF CERTIORARI

The Petitioner most respectfully submits as under:

1. That the Respondent passed an order / judgment dated __________ in [Case No. / Matter],
which is challenged in the present writ petition.

2. That the said order is illegal, arbitrary, and passed:

(a) in excess of the jurisdiction of the Respondent;
(b) in violation of the principles of natural justice;
(c) without proper consideration of the material and evidence;
(d) based on mis-reading / non-application of the law;
(e) in an unreasonable and perverse manner.

3. That the order adversely affects the Petitioner’s fundamental or legal rights and cannot be
sustained in law.

4. That the Petitioner has no other efficacious remedy except to invoke the writ jurisdiction of this
Hon’ble Court under Article 226 of the Constitution.

5. That the Petitioner is therefore entitled to a writ of Certiorari quashing the impugned order and
remitting the matter, if necessary, to the Respondent / competent authority.

PRAYER

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

a. Issue a writ of Certiorari quashing the impugned order dated __________ passed by the
Respondent in [Case No. / Matter];

b. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper;

c. Award costs of the petition to the Petitioner.

PETITIONER
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

(b) Respondent side – Reply / Affidavit-in-opposition to Certiorari

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
…Petitioner

VERSUS

[NAME OF RESPONDENT]
…Respondent

AFFIDAVIT-IN-OPPOSITION TO WRIT OF CERTIORARI

I, [Name], holding the office of __________, presently working at __________, do hereby affirm:

1. That I am the Respondent in the above writ petition, and the impugned order dated __________
was passed in the exercise of the lawful jurisdiction of this office.

2. That the order has been passed strictly in accordance with the provisions of [relevant Act,
Procedure, Rules] and after due application of mind and consideration of the material.

3. That the Petitioner has not been prejudiced by the impugned order, and the Petitioner has
alternate remedies, such as appeal / revision, if any, which ought to have been pursued.

4. That the Petitioner has not made out a case of excess of jurisdiction, illegality, or violation of
natural justice, and the writ of Certiorari is not maintainable.

5. That the Petitioner has approached the Court without clean hands and has suppressed material
facts relevant to the order.

PRAYER

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

a. Dismiss the writ petition for Certiorari;

b. Uphold the legality of the impugned order dated __________;

c. Pass such other order as this Hon’ble Court may deem fit.

DEPONENT
[Name]

Place: __________
Date: __________

5. Writ of Quo-Warranto
Usually filed to challenge the legality of a person’s claim to a public office or post he is
holding.

(a) Petitioner side – Quo-Warranto petition

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
R/o __________________________
…Petitioner

VERSUS

[NAME OF RESPONDENT]
(Alleged office-holder)
…Respondent

WRIT PETITION UNDER ARTICLE 226 OF THE CONSTITUTION OF INDIA

FOR A WRIT OF QUO-WARRANTO

The Petitioner most respectfully submits as under:

1. That the Respondent is claiming to hold the public office of __________, without being duly
qualified / lawfully appointed, and is exercising the powers of the said office.

2. That the Respondent does not possess the necessary qualifications, experience, or statutory
requisites required for the said post, and the appointment is in violation of [relevant Act / Rule /
Notification].

3. That the appointment / continuance of the Respondent in the said office is in excess of the legal
authority of the appointing authority, and therefore, the Petitioner is entitled to challenge such
illegal claim.

4. That the Petitioner is either an affected person or a citizen having locus standi to question the
usurpation of a public office, and public interest is involved.

5. That the Petitioner is therefore entitled to the writ of Quo-Warranto to enquire into the
Respondent’s authority to hold the said office and to remove the Respondent from the said post if
found ineligible.

PRAYER

It is therefore most respectfully prayed that this Hon’ble Court may be pleased to:
a. Issue a writ of Quo-Warranto directing the Respondent to show the authority under which he
holds the office of __________;

b. Declare the Respondent’s continuance in the said office illegal and unlawful, and direct the
Respondent to vacate the same;

c. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper.

PETITIONER
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

(b) Respondent side – Reply / Affidavit-in-opposition to Quo-Warranto

IN THE HIGH COURT OF __________ AT __________

Writ Petition No. ____ of 20__

[NAME OF PETITIONER]
…Petitioner

VERSUS

[NAME OF RESPONDENT]
(Office-holder)
…Respondent

AFFIDAVIT-IN-OPPOSITION TO WRIT OF QUO-WARRANTO

I, [Name], holding the office of __________, presently working at __________, do hereby affirm:

1. That I am the Respondent in the above writ petition, and the allegations against my appointment
and continuance in office are false, misconceived, and ex-parte.

2. That my appointment to the post of __________ was made in accordance with the provisions of
[relevant Act / Rule / Notification], and the appointing authority followed due procedure and
published the notification / order dated __________.

3. That I possess the requisite qualifications, experience, and conditions required for the said post,
and the same were duly verified and recorded before my appointment.
4. That the Petitioner has no locus standi to challenge my appointment, and the Petitioner is
merely a private individual with no special interest in the matter, and the writ of Quo-Warranto is
not maintainable.

5. That the Petitioner has approached the Court without clean hands and has suppressed material
facts, including the legality of the appointment order and the due process followed.

6. That my continued tenure in office is in the public interest and is not illegal or ultra vires, and
the Petitioner has no legal basis to claim otherwise.

PRAYER

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

a. Dismiss the writ petition for Quo-Warranto; and

b. Hold that the Respondent has been lawfully appointed and is entitled to continue in office.

DEPONENT
[Name]

Place: __________
Date: __________

Quick recap of the five writ-types

For each of the five writs you asked for, we now have both sides in proper legal-format style:

1. Habeas Corpus – Petitioner seeking release of a detainee; Respondent defending the

legality of detention.
2. Mandamus – Petitioner asking a public authority to perform a duty; Respondent opposing
because duty is not ministerial or petitioner has an alternative remedy.
3. Prohibition – Petitioner asking to stop a lower court/tribunal from acting beyond
jurisdiction; Respondent saying it is within jurisdiction.
4. Certiorari – Petitioner seeking to quash an illegal order; Respondent defending the
legality and regularity of the order.
5. Quo-Warranto – Petitioner challenging legality of a person’s claim to a public office;
Respondent defending the appointment and qualifications.

6.

Below is a proper legal-format draft of a Revision Petition, suitable for filing under Section
115 of the Code of Civil Procedure, 1908 (or analogous revision provisions in State Civil
Procedure Codes, e.g., Maharashtra). A revision petition challenges the jurisdictional or legal
error of a lower court’s order, not merely factual disagreement.

Revision Petition Format

IN THE COURT OF THE HON’BLE ________ AT ________

Revision Petition No. ____ of 20__

[NAME OF PETITIONER / REVISION-PETITIONER]

R/o __________________________
…Revision-Petitioner

VERSUS

[NAME OF RESPONDENT / REVISION-RESPONDENT]

R/o __________________________
…Revision-Respondent

IN THE MATTER OF:

[Civil Suit No. ____ of 20__ / I.A. No. ____ of 20__ / Order dated __________]

REVISION PETITION UNDER SECTION 115 CPC

The Revision-Petitioner most respectfully submits as under:

1. That the present Revision Petition is filed under Section 115 of the Code of Civil Procedure,
1908, read with the provisions of [State Civil Procedure Code / special enactment, if any],
challenging the legality of the order dated __________ passed by the learned [Additional Civil
Judge / Judicial Magistrate / Asst. Commissioner / other authority] in ________ in [Case No. / Suit
No. / Application No.].

2. That the impugned order does not involve the exercise of jurisdiction in the sense of a decided
case, but rather suffers from a clear error apparent on the record, namely:
(a) The learned Court / Authority has exercised jurisdiction which it does not possess, or has
refused to exercise jurisdiction which it clearly possesses;
(b) The Court has violated the principles of natural justice / failed to record necessary findings;
(c) The order is based on a material mis-reading of the pleadings, evidence, or applicable law;
(d) The order is so arbitrary, capricious, or perverse that it cannot be sustained in law.

3. That the Revision-Petitioner has no other efficacious remedy except to approach this Hon’ble
Court in revision, and the Petitioner is therefore entitled to the exercise of the revisional
jurisdiction.
4. That the revision is within the prescribed period, having been filed within the limitation period
provided under the applicable civil procedure law / rules.

5. That the Petitioner has annexed:

(a) Certified copy of the impugned order dated __________;
(b) Certified copy of the judgment / order below (if any);
(c) List of dates and proceedings in the court below;
(d) Relevant documents, if necessary.

PRAYER

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

a. Admit the present Revision Petition;

b. Call for the record of the lower court / authority in [Case No. / Suit No. / Application No.];

c. Set aside / modify the impugned order dated __________ passed by the learned __________;

d. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper in the interest
of justice.

REVISION-PETITIONER
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Verification (if required by local rules)

VERIFICATION

I, [Name of Revision-Petitioner], the above-named Petitioner, do hereby verify that the contents of
paragraphs 1 to __ of the present revision petition are true and correct to my knowledge, and the
remaining paragraphs are believed to be true on legal advice.

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

Revision-Petitioner

6.
Below is a proper legal-format draft of a Review Petition / Review Application in a civil
matter. Under Section 114 CPC read with Order XLVII Rule 1 CPC, review lies before the
same court that passed the decree or order, generally on limited grounds such as discovery of new
and important matter, mistake or error apparent on the face of the record, or any other sufficient
reason; it is not an appeal in disguise.

Review petition draft

IN THE COURT OF THE HON’BLE __________ AT __________

Review Petition / Review Application No. ____ of 20__

In
[Original Suit / Appeal / Misc. Case] No. ____ of 20__

[NAME OF REVIEW PETITIONER / APPLICANT]

S/o / D/o / W/o __________
R/o __________________________
...Review Petitioner / Applicant

VERSUS

[NAME OF RESPONDENT]
S/o / D/o / W/o __________
R/o __________________________
...Respondent

REVIEW PETITION UNDER SECTION 114 READ WITH

ORDER XLVII RULE 1 OF THE CODE OF CIVIL PROCEDURE, 1908

The Review Petitioner / Applicant most respectfully submits as under:

1. That the present Review Petition is being filed by the Applicant, being a person aggrieved by
the judgment / decree / order dated __________ passed by this Hon’ble Court in [Case No.
__________], whereby __________ [briefly describe what was decided].

2. That the Applicant is filing the present petition before the same Hon’ble Court which passed the
impugned judgment / order, as required under the provisions governing review jurisdiction.

3. That no appeal has been preferred against the said judgment / decree / order / or the impugned
order is of such nature that review is otherwise maintainable in law, subject to the limitations
prescribed under Section 114 and Order XLVII Rule 1 CPC.

4. That the present review petition is maintainable on the following grounds:

a. That there is a mistake / error apparent on the face of the record inasmuch as __________. The
error is patent, self-evident, and does not require a long-drawn process of reasoning to establish it.
 b. That the Applicant has discovered new and important matter / evidence, namely __________,
which, after exercise of due diligence, was not within the knowledge of the Applicant or could not
be produced at the time when the judgment / order was passed.

c. That there exists other sufficient reason warranting review of the impugned judgment / order,
namely __________.

5. That the error / omission in the impugned order has resulted in grave prejudice and miscarriage
of justice to the Applicant.

6. That the present petition is being filed within the prescribed limitation period / or is
accompanied by an application for condonation of delay, if required.

7. That the Applicant craves leave of this Hon’ble Court to rely upon the certified copy of the
impugned judgment / order and such other documents as may be necessary at the time of hearing.

## Grounds for review

A. Because the impugned judgment / order suffers from an error apparent on the face of the
record.

B. Because relevant statutory provisions / binding documents / material pleadings were

overlooked while passing the judgment / order.

C. Because new and important material has been discovered, which could not be produced earlier
despite due diligence.

D. Because failure to review the impugned judgment / order would result in manifest injustice.

E. Because the review petition is bona fide and maintainable under Section 114 read with Order
XLVII Rule 1 CPC.

## Prayer

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

a. Review and recall / modify / set aside the judgment / decree / order dated __________ passed in
[Case No. __________];

b. Re-hear the matter to the limited extent necessary in accordance with law;

c. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper in the facts
and circumstances of the case.

APPLICANT / REVIEW PETITIONER

Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Verification

VERIFICATION

I, [name of applicant], the above-named Applicant / Review Petitioner, do hereby verify that the
contents of paragraphs 1 to __ of the present review petition are true and correct to my knowledge
and belief, and nothing material has been concealed therefrom.

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

Applicant / Review Petitioner

Drafting notes

A review petition is narrower than an appeal and cannot be used to reopen the case merely because
another view is possible; courts repeatedly stress that an “error apparent” must be patent and self-
evident, not something requiring elaborate reasoning. The safest structure is to plead one of the
recognized review grounds clearly, attach the impugned order, and avoid arguing the matter as if
the court were hearing a full appeal again.

7.

Below is a proper legal-format set of criminal pleadings from both sides for (1) Application
for Bail and (2) Application under Section 125 CrPC. A bail application under the CrPC
typically states the FIR, custody details, nature of accusation, antecedents, and undertakings not to
abscond or tamper with evidence. A Section 125 CrPC petition is a social-justice remedy for wife,
children, or parents who are unable to maintain themselves and must plead neglect/refusal plus the
respondent’s sufficient means.

1. Application for Bail

Bail applications are commonly filed before the Magistrate under Section 437 CrPC or before the
Sessions Court / High Court under Section 439 CrPC, depending on the nature of the offence and
forum.

Applicant / accused side

IN THE COURT OF THE HON’BLE __________ AT __________

Bail Application No. ____ of 20__

IN THE MATTER OF:

STATE
...Respondent

VERSUS

[NAME OF ACCUSED / APPLICANT]

S/o / D/o / W/o __________
R/o __________________________
...Applicant / Accused

APPLICATION FOR GRANT OF BAIL

UNDER SECTION 437 / 439 CrPC

The Applicant most respectfully submits as under:

1. That the Applicant has been arrested in FIR No. __________ dated __________ registered at
Police Station __________ under Sections __________.

2. That the Applicant was arrested on __________ and is presently in judicial / police custody.

3. That the Applicant is innocent and has been falsely implicated in the present case, and the
allegations are false, exaggerated, or motivated.

4. That the investigation is complete / substantially complete, and no useful purpose will be served
by keeping the Applicant in further custody.

5. That the Applicant is a permanent resident of __________, has deep roots in society, and is not
likely to abscond or evade the process of law.

6. That the Applicant has no previous criminal antecedents / or the same are explained as follows:
__________.

7. That the Applicant undertakes not to tamper with prosecution evidence, not to influence
witnesses, and to appear before the Investigating Officer / Court as and when required.

8. That the Applicant is ready and willing to furnish bail bonds and sureties to the satisfaction of
this Hon’ble Court.

PRAYER

It is therefore most respectfully prayed that this Hon’ble Court may be pleased to:
a. Release the Applicant on bail in FIR No. __________ dated __________, Police Station
__________;

b. Pass such other or further order(s) as this Hon’ble Court may deem fit and proper.

APPLICANT / ACCUSED
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

State / prosecution side

IN THE COURT OF THE HON’BLE __________ AT __________

Bail Application No. ____ of 20__

STATE
...Respondent / Prosecution

VERSUS

[NAME OF ACCUSED / APPLICANT]

...Applicant / Accused

REPLY / OBJECTIONS ON BEHALF OF THE STATE

TO THE BAIL APPLICATION

The Respondent / State most respectfully submits as under:

1. That the present bail application is misconceived and liable to be dismissed in view of the
seriousness and gravity of the allegations against the accused.

2. That the accused is involved in FIR No. __________ dated __________ under Sections
__________, and the accusations disclose commission of a grave offence.

3. That the investigation is still pending / material recoveries are yet to be effected / crucial
witnesses are yet to be examined, and release of the accused at this stage may prejudice the
investigation.

4. That there is every likelihood that the accused may tamper with evidence, influence prosecution
witnesses, or abscond if enlarged on bail.

5. That keeping in view the nature of accusation, role attributed to the accused, and overall facts
and circumstances, the accused is not entitled to the discretionary relief of bail.
PRAYER

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

a. Dismiss the bail application; and

b. Pass such other order as this Hon’ble Court may deem fit in the interest of justice.

STATE / PROSECUTION
Through APP / Prosecutor

Place: __________
Date: __________

2. Application under Section 125 CrPC

Section 125 CrPC permits a wife, legitimate or illegitimate minor child, major child unable to
maintain itself due to infirmity, and father or mother to claim maintenance where the person with
sufficient means neglects or refuses to maintain them.

Applicant side

IN THE COURT OF THE HON’BLE JUDICIAL MAGISTRATE / FAMILY COURT AT

__________

Maintenance Petition No. ____ of 20__

[NAME OF APPLICANT]
W/o / D/o / S/o __________
R/o __________________________
...Applicant

VERSUS

[NAME OF RESPONDENT]
S/o __________
R/o __________________________
...Respondent

APPLICATION UNDER SECTION 125 OF THE CODE OF CRIMINAL PROCEDURE, 1973

FOR GRANT OF MAINTENANCE

The Applicant most respectfully submits as under:

1. That the Applicant is the legally wedded wife / minor child / father / mother of the Respondent
and is entitled to claim maintenance under Section 125 CrPC.

2. That the marriage between the Applicant and Respondent was solemnized on __________ at
__________ according to lawful rites and ceremonies, and out of the wedlock the following child /
children were born: __________, if applicable.

3. That after some time, the Respondent started neglecting and refusing to maintain the Applicant
without any just or lawful cause, and the Applicant has been compelled to live separately due to
__________.

4. That the Applicant has no independent sufficient source of income and is unable to maintain
herself / himself / themselves, including food, clothing, residence, medical expenses, and day-to-
day needs.

5. That the Respondent has sufficient means and earns approximately Rs. __________ per month
from __________ [service / business / rent / profession / agriculture / other source], yet has
wilfully neglected to maintain the Applicant.

6. That despite repeated requests and demands, the Respondent has failed to provide any
reasonable maintenance.

7. That the Applicant is therefore entitled to monthly maintenance of Rs. __________, or such
amount as this Hon’ble Court may deem fit and proper.

8. That the Applicant also seeks interim maintenance and litigation expenses during pendency of
the petition, if applicable.

PRAYER

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

a. Direct the Respondent to pay monthly maintenance of Rs. __________ to the Applicant from
the date of application / order;

b. Grant interim maintenance of Rs. __________ per month during pendency of the present
petition;

c. Award litigation expenses of Rs. __________; and

d. Pass such other or further order as this Hon’ble Court may deem fit and proper.

APPLICANT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Respondent side

IN THE COURT OF THE HON’BLE JUDICIAL MAGISTRATE / FAMILY COURT AT

__________

Maintenance Petition No. ____ of 20__

[NAME OF APPLICANT]
...Applicant

VERSUS

[NAME OF RESPONDENT]
...Respondent

REPLY / WRITTEN STATEMENT ON BEHALF OF THE RESPONDENT

TO THE APPLICATION UNDER SECTION 125 CrPC

The Respondent most respectfully submits as under:

PRELIMINARY OBJECTIONS

1. That the present application is false, frivolous, and not maintainable in the manner alleged.

2. That the Applicant has suppressed material facts and has not approached this Hon’ble Court
with clean hands.

3. That the Respondent has never neglected or refused to maintain the Applicant and has always
been ready and willing to provide maintenance subject to lawful conditions.

4. That the Applicant is independently earning / has sufficient means / is living separately without
sufficient reason, and therefore is not entitled to maintenance to the extent claimed.

5. That the amount claimed is excessive, arbitrary, and beyond the actual income and means of the
Respondent.

REPLY ON MERITS

1. That paragraph 1 of the application is admitted / denied to the extent of the relationship.

2. That paragraph 2 relating to marriage / relationship is admitted / denied in the manner stated
herein.
3. That paragraph 3 alleging neglect and refusal is specifically denied; the Applicant left the
matrimonial home / residence voluntarily and without sufficient cause, or the Respondent was
prevented from maintaining the Applicant due to the Applicant’s own conduct.

4. That paragraph 4 relating to lack of income is denied; the Applicant is earning approximately
Rs. __________ per month from __________ / has support from family / has independent means.

5. That paragraph 5 relating to the Respondent’s income is denied as exaggerated; the

Respondent’s actual monthly income is Rs. __________ and he has liabilities including
__________.

6. That paragraph 6 is denied; the Respondent has made payments / offered maintenance / sought
reconciliation, as detailed below: __________.

7. That the Applicant is not entitled to interim maintenance or litigation expenses as claimed, or
only to a reasonable amount as this Hon’ble Court may determine.

PRAYER

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

a. Dismiss the application under Section 125 CrPC; or in the alternative,

b. Fix only such reasonable amount, if any, as may be justified on the actual income and liabilities
of the Respondent; and

c. Pass such other order as this Hon’ble Court may deem fit and proper.

RESPONDENT
Through Counsel
[Name of Advocate]

Place: __________
Date: __________

Drafting note

For bail, courts usually focus on gravity of accusation, stage of investigation, need for custody,
antecedents, flight risk, and likelihood of witness tampering. For Section 125 CrPC, the central
issues are the existence of the relationship, inability of the claimant to maintain themself, neglect
or refusal, and the respondent’s actual means and liabilities.

8.
Below are general legal-format templates for the eight documents you listed, adapted to
common Indian drafting structure. For property and transfer instruments in India, the core drafting
pattern usually includes title, date, parties, recitals, operative clause, schedule of property,
execution, and witness attestation, while documents like gift deeds and many property transfers
also require registration and compliance with the Transfer of Property Act and Registration Act.

1. General Power of Attorney

A General Power of Attorney usually identifies the principal, the attorney, the property or affairs
covered, and the specific acts the attorney is authorized to do on the principal’s behalf.

GENERAL POWER OF ATTORNEY

THIS GENERAL POWER OF ATTORNEY is made on this ___ day of __________, 20__ at
__________.

BY

[NAME OF EXECUTANT / PRINCIPAL]

S/o / D/o / W/o __________
Aged about ___ years
R/o __________________________
(hereinafter called the “Principal”)

IN FAVOUR OF

[NAME OF ATTORNEY]
S/o / D/o / W/o __________
Aged about ___ years
R/o __________________________
(hereinafter called the “Attorney”)

WHEREAS:

1. The Principal is the absolute owner / lawful holder / person interested in respect of the
property / business / affairs described in the Schedule hereunder.
2. The Principal is unable to personally manage / attend / supervise the said matters and desires to
appoint the Attorney to act on his / her behalf.

NOW THIS DEED WITNESSETH AS UNDER:

1. The Principal hereby appoints and constitutes the Attorney as his / her true and lawful attorney
to do and execute the following acts, deeds, and things in the name and on behalf of the Principal:

a. To appear before all government, semi-government, municipal, revenue, registration, banking,

and other authorities;
 b. To sign, execute, present, and admit documents, applications, affidavits, declarations, receipts,
and forms;
c. To manage, supervise, protect, lease, license, or otherwise deal with the property / affairs
described in the Schedule;
d. To appoint advocates, sign vakalatnama, file cases, defend proceedings, compromise matters,
and take all legal steps;
e. To pay taxes, charges, cesses, dues, and obtain certificates, permissions, and sanctions;
f. To do all lawful acts incidental and necessary for proper management of the said affairs.

2. The Attorney shall act in good faith and in the best interest of the Principal.

3. The Principal agrees to ratify all lawful acts done by the Attorney pursuant to this Power of
Attorney.

4. This Power of Attorney shall remain in force until revoked in writing / shall be irrevocable to
the extent permissible by law [choose as applicable].

SCHEDULE OF PROPERTY / SUBJECT MATTER

[Full description]

IN WITNESS WHEREOF, the Principal has signed this Deed on the day, month, and year first
above written.

Signature of Principal: __________

Signature of Attorney (in token of acceptance): __________

Witnesses:
1. Name & Address: __________ Signature: __________
2. Name & Address: __________ Signature: __________

2. Will

A will should clearly identify the testator, revoke prior wills, declare sound mind and free consent,
appoint an executor, and specify how the estate will devolve.

LAST WILL AND TESTAMENT

I, [NAME OF TESTATOR], S/o / D/o / W/o __________, aged about ___ years, residing at
__________________________, do hereby declare this to be my Last Will and Testament.

1. I am of sound mind and health and I am making this Will voluntarily and without coercion or
undue influence.

2. I hereby revoke all former wills and codicils made by me.

3. My family details are as follows:
[Spouse, children, other legal heirs]

4. I appoint [NAME OF EXECUTOR], residing at __________, as the Executor of this Will. In

his / her absence, [alternate executor] shall act.

5. I own the following movable and immovable properties:

[Describe properties]

6. I bequeath my estate in the following manner:

a. [Property / asset] to [beneficiary]
b. [Property / asset] to [beneficiary]
c. Residue of my estate to [beneficiary / beneficiaries]

7. All my debts, taxes, funeral expenses, and lawful liabilities shall first be paid out of my estate.

8. If any beneficiary predeceases me, his / her share shall devolve as follows: __________.

IN WITNESS WHEREOF, I have signed this Will on this ___ day of __________, 20__ at
__________ in the presence of the witnesses named below.

Signature of Testator: __________

Witnesses:
1. Name & Address: __________ Signature: __________
2. Name & Address: __________ Signature: __________

3. Agreement to Sell

An agreement to sell generally records the promise to transfer property in future on stated terms,
including price, earnest money, title assurances, and time for execution of sale deed.

AGREEMENT TO SELL

THIS AGREEMENT TO SELL is made on this ___ day of __________, 20__ at __________.

BETWEEN

[NAME OF VENDOR / SELLER]

R/o __________________________
(hereinafter called the “Vendor”)

AND

[NAME OF PURCHASER / BUYER]

R/o __________________________
(hereinafter called the “Purchaser”)

WHEREAS the Vendor is the lawful owner of the property described in the Schedule hereunder
and has agreed to sell the same to the Purchaser on the following terms:

1. The total sale consideration is Rs. __________.

2. Out of the said consideration, the Purchaser has paid Rs. __________ as earnest / advance
money, receipt whereof the Vendor hereby acknowledges.

3. The balance consideration of Rs. __________ shall be paid on or before execution and
registration of the Sale Deed.

4. The Vendor assures that the property is free from encumbrances, charges, claims, liens,
disputes, and acquisition proceedings.

5. The Vendor shall execute and register the Sale Deed in favour of the Purchaser / nominee on or
before __________.

6. Possession of the property shall be delivered on execution / registration of the Sale Deed / as
otherwise agreed.

7. In case of default by the Vendor, the Purchaser shall be entitled to specific performance / refund
/ damages.
8. In case of default by the Purchaser, the earnest money shall stand forfeited / other agreed
consequence.

SCHEDULE OF PROPERTY
[Full description]

IN WITNESS WHEREOF, the parties have signed this Agreement on the date first above written.

Vendor Signature: __________

Purchaser Signature: __________

Witnesses:
1. __________
2. __________

4. Sale Deed

A sale deed is the operative conveyance transferring ownership for consideration and usually
contains title recital, receipt of consideration, transfer clause, possession, indemnity, and schedule.

SALE DEED
THIS SALE DEED is made on this ___ day of __________, 20__ at __________.

BETWEEN

[NAME OF SELLER]
R/o __________________________
(hereinafter called the “Seller”)

AND

[NAME OF PURCHASER]
R/o __________________________
(hereinafter called the “Purchaser”)

WHEREAS the Seller is the absolute owner of the property described in the Schedule hereunder
and has agreed to sell the same to the Purchaser for a total consideration of Rs. __________.

NOW THIS DEED WITNESSETH AS UNDER:

1. In consideration of Rs. __________ paid by the Purchaser to the Seller, receipt whereof the
Seller hereby admits, the Seller hereby grants, conveys, transfers, and assigns unto the Purchaser
the property described in the Schedule.

2. The Seller assures that the property is free from all encumbrances, claims, charges, liens,
mortgages, litigation, and acquisition proceedings.

3. The Seller has delivered vacant and peaceful possession of the property to the Purchaser on
execution of this Deed.

4. The Seller transfers all rights, title, interest, easements, and appurtenances attached to the
property in favour of the Purchaser.

5. The Seller shall indemnify the Purchaser against any defect in title or any prior claim arising out
of acts of the Seller.

SCHEDULE OF PROPERTY
[Full description, boundaries, area, survey no., etc.]

IN WITNESS WHEREOF, the parties have signed this Sale Deed on the date first above written.

Seller Signature: __________

Purchaser Signature: __________

Witnesses:
1. __________
2. __________
5. Lease Deed

A lease deed generally states the property, term, rent, security deposit, permitted use, repairs,
termination, and possession [Link].

LEASE DEED

THIS LEASE DEED is made on this ___ day of __________, 20__ at __________.

BETWEEN

[NAME OF LESSOR]
R/o __________________________
(hereinafter called the “Lessor”)

AND

[NAME OF LESSEE]
R/o __________________________
(hereinafter called the “Lessee”)

WHEREAS the Lessor is the lawful owner of the property described in the Schedule and has
agreed to lease the same to the Lessee.

NOW THIS DEED WITNESSETH AS UNDER:

1. The Lessor hereby lets and the Lessee hereby takes on lease the property described in the
Schedule for a term of ___ months / years commencing from __________.

2. The monthly rent shall be Rs. __________ payable on or before the ___ day of each month.

3. The Lessee has paid a security deposit of Rs. __________, refundable subject to deductions, if
any.

4. The premises shall be used only for __________ purpose.

5. The Lessee shall keep the premises in good condition, subject to normal wear and tear, and shall
not make structural alterations without written consent.

6. Electricity, water, maintenance, and other charges shall be borne by __________.

7. Either party may terminate the lease by giving ___ days / months prior written notice.

8. On expiry or termination, the Lessee shall hand over vacant possession of the premises to the
Lessor.
SCHEDULE OF PROPERTY
[Full description]

IN WITNESS WHEREOF, the parties have signed this Lease Deed on the date first above written.

Lessor Signature: __________

Lessee Signature: __________

Witnesses:
1. __________
2. __________

6. Partnership Deed

A partnership deed usually records firm name, business, capital contribution, profit sharing, duties,
bank operation, retirement, dissolution, and dispute handling.

PARTNERSHIP DEED

THIS DEED OF PARTNERSHIP is made on this ___ day of __________, 20__ at __________.

BETWEEN

1. [NAME OF PARTNER NO. 1], R/o __________

2. [NAME OF PARTNER NO. 2], R/o __________
[Add more if required]

WHEREAS the parties have agreed to carry on business in partnership on the following terms:

1. The name of the partnership firm shall be M/s __________.

2. The principal place of business shall be at __________, and branch offices may be opened as
mutually agreed.

3. The nature of business shall be __________.

4. The partnership shall commence from __________ and shall be a partnership at will / for a
fixed term.

5. The capital contribution of the partners shall be:

Partner 1 – Rs. __________
Partner 2 – Rs. __________

6. The net profits and losses of the firm shall be shared as follows:
Partner 1 – ___%
Partner 2 – ___%
7. Proper books of account shall be maintained and shall be open to inspection by all partners.

8. Bank account(s) of the firm shall be operated by __________.

9. No partner shall, without consent of the others, borrow money, create charge, admit new
partner, or transfer his share.

10. Any partner may retire upon giving written notice of __________ days / months.

11. On dissolution, accounts shall be taken and assets and liabilities shall be adjusted according to
law.

12. Disputes, if any, shall be resolved by arbitration / mutual settlement / court jurisdiction at
__________.

IN WITNESS WHEREOF, the partners have signed this Deed on the date first above written.

Partner 1 Signature: __________

Partner 2 Signature: __________

Witnesses:
1. __________
2. __________

7. Mortgage Deed

A mortgage deed generally secures repayment of a debt by creating an interest in specific

immovable property and should specify amount, interest, repayment, default, and rights of
mortgagee.

MORTGAGE DEED

THIS MORTGAGE DEED is made on this ___ day of __________, 20__ at __________.

BETWEEN

[NAME OF MORTGAGOR]
R/o __________________________
(hereinafter called the “Mortgagor”)

AND

[NAME OF MORTGAGEE]
R/o __________________________
(hereinafter called the “Mortgagee”)
WHEREAS the Mortgagor has borrowed / agreed to secure a sum of Rs. __________ from the
Mortgagee and has agreed to mortgage the property described in the Schedule hereunder as
security.

NOW THIS DEED WITNESSETH AS UNDER:

1. In consideration of the loan of Rs. __________, the Mortgagor hereby mortgages the property
described in the Schedule in favour of the Mortgagee.

2. The loan shall carry interest at the rate of ___% per annum.

3. The loan amount together with interest shall be repaid on or before __________.

4. In default of repayment, the Mortgagee shall be entitled to enforce the mortgage in accordance
with law.

5. The Mortgagor declares that the property is free from encumbrances except as disclosed herein.

6. The Mortgagor shall not create any subsequent charge or transfer the property without consent
of the Mortgagee during subsistence of the mortgage.

7. On full repayment, the Mortgagee shall release / reconvey / discharge the mortgage.

SCHEDULE OF PROPERTY
[Full description]

IN WITNESS WHEREOF, the parties have signed this Mortgage Deed on the date first above
written.

Mortgagor Signature: __________

Mortgagee Signature: __________

Witnesses:
1. __________
2. __________

8. Deed of Gift

A gift deed for immovable property should identify donor and donee, state that the transfer is
voluntary and without consideration, describe the property, record acceptance, and be attested by
two witnesses; registration is mandatory for immovable property.

DEED OF GIFT

THIS DEED OF GIFT is made on this ___ day of __________, 20__ at __________.
BY

[NAME OF DONOR]
S/o / D/o / W/o __________
R/o __________________________
(hereinafter called the “Donor”)

IN FAVOUR OF

[NAME OF DONEE]
S/o / D/o / W/o __________
R/o __________________________
(hereinafter called the “Donee”)

WHEREAS the Donor is the absolute owner of the property described in the Schedule and is
desirous of gifting the same to the Donee out of natural love and affection / affection and regard,
without any monetary consideration.

NOW THIS DEED WITNESSETH AS UNDER:

1. The Donor hereby voluntarily and absolutely gifts, conveys, and transfers the property
described in the Schedule to the Donee, free from all encumbrances.

2. The Donee hereby accepts the gift and takes the same with all rights, title, interest, and
appurtenances attached thereto.

3. The Donor declares that the gift is made of his / her own free will and without coercion, fraud,
or undue influence.

4. Possession of the gifted property is hereby delivered / shall be deemed to have been delivered to
the Donee.

5. The Donee shall henceforth enjoy, possess, use, transfer, lease, mortgage, or otherwise deal with
the gifted property as absolute owner, subject to law.

SCHEDULE OF PROPERTY
[Full description]

IN WITNESS WHEREOF, the Donor and Donee have signed this Gift Deed on the date first
above written.

Donor Signature: __________

Donee Signature: __________

Witnesses:
1. __________
2. __________