SUIT FOR EVICTION ON THE GROUND OF DENIAL OF TITLE

SUIT FOR EVICTION ON THE GROUND OF DENIAL OF TITLE

IN THE COURT OF THE………………..

Suit No………………… of 19………………..

CD………………………………………………………….. Plaintiff

versus

C. F……………………………………………………….. Defendant

The abovenamed plaintiff most respectfully submits as under: —

1. That the plaintiff let out a portion of his house No………………… situate at……………….. street, in town……………….. containing three rooms and one kitchen in the second floor thereof, at a monthly rent of Rs…………………. on……………….. 19……………….. through a written rent note.

2. That the plaintiff fell in arrears of rent for the last many years and did not pay a single paisa towards rent even at written requests; and ultimately the plaintiff gave a registered notice dated……………….. 19……………….. which was received by the defendant on……………….. 19……………….. and in reply to that notice the plaintiff alleged that he has become the owner of the house by adverse possession, and that the plaintiff has no title to the said portion of the house.

3. That the plaintiff has given another registered notice terminating his tenancy on the ground of denial of title of the plaintiff, which notice is received by the defendant on……………….. 19………………..

4. That the cause of action arose on……………….. when the defendant through his reply in writing denied the title of the plaintiff to the said portion of the house, and further on……………….. 19……………….. when the defendant received another notice of the plaintiff determining his tenancy, and this Court has jurisdiction to try the suit.

5. The suit is valued at Rs………………… the amount of twelve times the monthly rent of the accommodation let out, for the purpose of court fee and Rs. ……………….. for the purpose of court fee according to the reliefs claimed.

RELIEFS CLAIMED:

The plaintiff claims the following reliefs:

(1) the defendant be evicted from the portion of the house aforesaid and possession thereof be delivered to the plaintiff;

(2) Rs………………… as arrears of rent for the last three years be got paid from the defendant prior to the date of denial of title;

(3) mesne profits from the date of denial of title till delivery of possession of the accommodation be granted to the plaintiff from the defendant.

Plaintiff

Through Advocate

VERIFICATION

I, abovenamed plaintiff, do hereby verify that the contents of paras ……………….. to……………….. of the plaint are true to my personal knowledge and those of paras……………….. and……………….. thereof are based on legal advice which I believe to be true.

Verified on this…………….. day of……………….. 19………………. at………………..

Plaintiff