IN THE DISTRICT COURT OF MOHALI

SUIT NO.48 OF 2022

Rajat Arora (a resident of Gauraun, house no. 76, near park colony ,140301).

………………. Plaintiff

Versus

Himanshi bank Pvt. Ltd. Gauraun, Mohali, Punjab

…………………Defendant

SUIT FOR THE CANCELLATION OF CONTRACT UNDER ORDER OF CODE OF

CIVIL PROCEDURE 1908

MOST RESPECTFULLY SHWETH:

That my client Rajat Arora (a resident of Gauraun, house no. 76, near park colony ,140301).
had taken a loan from your respective bank on dated 1st Dec 2014. The object for taking loan was to
purchase a new car.

• That the Principal amount was Rs 20,00,000 (Rs 20 lakh).

• That According to loan Agreement the interest rate was @10% per annum for 5 years.
• That as per the loan Agreement the EMI was Rs 36,666 per month.
• That the1st installment started on 1st Jan 2015 which was duly deposited.
• Further the Last installment date was 31st December,2020.

Further we would like to state here that all the installment including interest rate were duly paid
except the last one which was delayed by 2 days by my client.

Besides all above mentioned facts, my client has received a legal notice on 1st Feb 2021 from the
bank where they are demanding Rs 20,000 extra interest for the late payment. According to the any
Bank policy if there is a delay of 3 days on any payment no extra interest is to be charged , after 3
days only fine can be put and also there was no provision while the agreement was made.

Further it is stated that my client has already replied to bank through letter on dated 5 th Feb 2021
stating that the principal amount along with interest was already cleared by my client. After two
days of my client’s reply, the bank again sent a notice regarding the known payment of Rs 20,000 (Rs
twenty thousand) along with the RBI notice.

PRAYER:
It is, therefore most respectfully prayed that this Honourable Court may be pleased
 to :-
1. Pass a decree for non-payment of any extra interest.
2. Pass the order for rescission of the agreement.
3. award cost of the suit in favour of the Plaintiff and against the Defendant;
4. Pass such other and further order(s) as may be deemed fit and proper on the
facts and in the circumstances of this case.

Plaintiff
Place: Through
Date:
Advocate

VERIFICATION:
Verified at Punjab on this 24thof January 2022 that the contents of paras 1 to 4 of
the plaint are true to my knowledge derived from the records of the Plaintiff
maintained in the ordinary course of its business and last para is the humble prayer to
this Honourable Court.

Plaintiff

[NOTE: The above plaint must be supported by an Affidavit]