SUIT FOR MONEY RECOVERY

IN THE COURT OF CIVIL JUDGE,

TIS HAZARI

Civil Suit No.: 44 OF 2021

(Under Order XXXVII of the Code of Civil Procedure 1908)

Mr. A S/O Raj Kumar R/O 44B Vasant Vihar, New Delhi …
Plaintiff

Versus

Mr. B S/o Rahul Kumar R/o H. 33/1 Vasant Vihar, new Delhi …
Defendant

Suit for the recovery of Rs. 6,58,560 along with cost of electricity and water.

Plaint under Order XXXVII of the Code of Civil Procedure 1908 as mentioned in the suit

Respectfully Sheweth :

1. That the present suit is being filed under the specific provisions under Order XXXVII of
the Code of Civil Procedure, 1908.

2. That no relief, which does not fall within the ambit of this rule, has been claimed in the
plaint.

3. That the plaintiff is the owner of house where the defendant was a tenant .

4. That the defendant paid rupees 13,66,080_ dated till June 201 to the plaintiff towards the
consideration as rent of the house by the Defandant.

5. That the lease agreement was made between the plaintiff and defendant for entering into
the contract as lessor and lessee on 10.03.2015
5. That other necessary particulars are as under for the convenience of this Hon'ble court:-

(a) Date of Agreement : 10.03.2015

[b] Duration of lease : 10 years ending on 31.03.2025

[c] Date till payment was made : 31.06.2019

[d] Date of sending of Notice : 1.04.2021

[e] Date when cause of action : 16.04.2021

7. That the defendant has apparently duly paid the amount till the date of 31.06.2019 of
13,66,080

8. That the present suit is regarding the non-payment of the rent after 30.06.2019 even though
the plaintiff has made various demand for the money since 1.07.2019

9. That the defendant is now liable to pay to the plaintiff an amount of 6,58,560 as per the
agreement along with charge of electicity water and other neccesities costing upto to
1,00,000.

10. That the cause of action arose in this case was on 10.03.2015 when gthe defendant
approach the plaintiff and on the time of non-payment as well as on time when demand for
payment was made.

11. That the suit is not barred by limitations and the court fees has been duly paid.

12. That the suit is filed for the purpose under order xxxvii of C.P.C and no relief has been
claimed outside the ambit of the court.

PRAYER

It is humbly prayed that the court:

1. Passes a decree in favour of the plaintiff for the repayment of the amount along with
other cost.
2. Reward cost of litigation in favour of plaintiff and against the defendant.
3. Pass any other order as the court dim fit in the interest of justice.

Verification:

I, Shubhanshu , do hereby verify that the contents of the above plaint from paras 1 to 12 are
true and correct to the best of my knowledge and belief of my client , and no part of it is false
and nothing material has been concealed therein.