1.

That the instant Plaint is being filed for the grant of a permanent injunction against
Defendant No. 1 from making and publishing any defamatory statement against the
Plaintiff and for the payment of Rs. _________ as damages for the defamatory
statement made against the Plaintiff which was widely published by the Defendant
through various modes including marking letters containing defamatory statement
against the Plaintiff to several person known to the Plaintiff and also orally
canvassing the defamatory statement against the Plaintiff which has undermined the
reputation of the Plaintiff in the eyes of the public known to the Plaintiff.
2. The the Plaintiff is a ____________________________________working at _____.
Plaintiff is considered to be a model businessman and has umblemished service
record of__________. It is stated that the Plaintiff has not met with any allegation in
his working career. The Plaintiff has set up a benchmark for the travel in maintaining
integrity’ and discharging the duty with all sincerity and competence.
3. That the Defendant No. 1 is a local __________
4. That the expose of the fact leading to the filling of the instant suit is as under:-
a. ___
b. ____
5. That from the aforesaid fact, it is clear that the Defendant No. 1 has made defamatory
allegation against the Plaintiff, which has adversely affected the goodwill and the
image of the Plaintiff. The Defendant has failed to tender his apology to the Plaintiff
despite notice and as such the Plaintiff is left with no other option to initiate suit for
claiming damages to the tune of Rs._______
6. That the Plaintiff is a very reput______. The false and frivolous allegations made by
the Respondent has caused significant hardship to the Plaintiff. Due to the allegation
of the Respondent, the reputation of the Plaintiff has been tarnished before the People
known to him. Moreso, the allegation has also resulted in the Plaintiff suffering from
significant mental anguish.
7. That the cause of action of the instant suit arises within the territorial jurisdiction of
this Hon’ble Court when the Defendant No. 1 wrote the letter dated ….. The cause of
action still continues till date as the Defendant has failed to issue any public apology
after maligning the image of the Plaintiff by making false and defamatory allegation,
the adverse impact of which continues till date.
8.