Plaint on Ejectment, Arrears of Rent and Mesne Profits

Suit for Ejectment and Arrears of Rent In the Court of Small Cause, ………….

Suit for Ejectment, Arrears of Rent and Mesne Profits

AB S/o CD Age….. Resident of ………… Plaintiff

Versus

 

 

PQ S/o RS Age….. Resident Of ………… Defendant

 

 

 

The above-named plaintiff states as follows: –

  1. That the plaintiff is the owner of the house no. ……. Situated at ……… and bounded as below: –

Boundaries of the Houses

* * * * * * * *

  1. That under verbal agreement made on ….. 20 ….. the defendant became a monthly tenant to the

plaintiff in respect to the house described in paragraph I above at the rent of Rupees ………. Per month

and has been in occupation of the said house as such tenant since the above mentioned date of the

agreement.

  1. That the defendant has not paid the rent from June 1, 20.. or any part thereof.
  2. That the plaintiff duly determined the said tenancy by serving on the defendant, by registered post on

October 1, 20.. a notice to quit the said house within thirty days of the receipt of the notice and pay the

entire arrears f rent from June 1, 20… That the said notice was served upon the defendant on October

7, 20.. yet the defendant has not vacated the house, nor has he paid the said arrears of rent or any part

thereof. Hence the defendant is liable to Ejectment under section 20 of the U.P. Act No. XIII of 1971.

  1. That now a total sum of Rupees ….. is due to the plaintiff as against the defendant, that is Rupees

……….. on account of arrears of rent from June 1, 20.. to November 7, 20.. , and Rupees ……. On

account of damages for use and occupation from November 8, 20.., to 20.., the date of filing the suit.

  1. That the cause of action for the said arose on November 8, 20.., when the period stipulated in the said

notice expired.

  1. That the defendant resides at …. within the jurisdiction of the court.
  2. That the valuation of the suit for purpose of jurisdiction and payment of court-fee is Rupees …….. , has

been paid.

Wherefore the plaintiff claims –

  1. a) That the decree for Ejectment of the defendant from the house described in paragraph 1 above be

passed in favour of the plaintiff.

  1. b) That the decree of Rupees on account of arrears of rent from June 1, 20.. to November 7, 20.. be

passed in favour of the plaintiff.

  1. c) That a decree for Rupees …. On account of damages for use and occupation at the rate of Rupees

…… per month from June 1, 20.. , to November 7, 20.. , the date of suit, be passed in favour of the

plaintiff as against the defendant.

  1. d) That a decree for further damages for use and occupation at the aforesaid rate till the Ejectment of the

defendant be passed in favour of the plaintiff as against the defendant on payment of additional court-fee.

  1. e) That cost of the suit be allowed to the plaintiff.

Place: ……..                                                                                                                            AB

Date: ……..                                                                                                                             Plaintiff

Through

Advocate

 

 

Verification

I, AB, he aforesaid, plaintiff, do hereby verify the contents of paragraphs …… and …….. of the above plaint are true to my personal knowledge nd the contents of the paragraphs ………. And ……., I believe to be true on information received.

Signed and verified this …… day of . 20.. ….., at ……

AB

Plaintiff

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