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    Draft of Civil Pleading

    Uploaded by

    Amol
    S. Janardhana Naidu borrowed Rs. 25,000 from G. Srinivasa Yadav on 26th February 2008 agreeing to pay 24% interest. Naidu executed a promissory note but failed to repay the loan. Yadav sent a lawyer's notice on 4th January 2011 demanding repayment which Naidu ignored. Yadav is now filing a suit against Naidu for recovery of the debt which with interest amounts to Rs. 39,000. Yadav prays that the court pass a judgement directing Naidu to pay Rs. 39,000 with further interest till date of realization and awards costs.

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    Draft of Civil Pleading

    Uploaded by

    Amol
    678 views4 pages
    S. Janardhana Naidu borrowed Rs. 25,000 from G. Srinivasa Yadav on 26th February 2008 agreeing to pay 24% interest. Naidu executed a promissory note but failed to repay the loan. Yadav sent a lawyer's notice on 4th January 2011 demanding repayment which Naidu ignored. Yadav is now filing a suit against Naidu for recovery of the debt which with interest amounts to Rs. 39,000. Yadav prays that the court pass a judgement directing Naidu to pay Rs. 39,000 with further interest till date of realization and awards costs.

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    S. Janardhana Naidu borrowed Rs. 25,000 from G. Srinivasa Yadav on 26th February 2008 agreeing to pay 24% interest. Naidu executed a promissory note but failed to repay the loan. Yadav sent a lawyer's notice on 4th January 2011 demanding repayment which Naidu ignored. Yadav is now filing a suit against Naidu for recovery of the debt which with interest amounts to Rs. 39,000. Yadav prays that the court pass a judgement directing Naidu to pay Rs. 39,000 with further interest till date of realization and awards costs.

    Copyright:

    © All Rights Reserved
    Download as DOCX, PDF, TXT or read online from Scribd
    Download as docx, pdf, or txt
    678 views4 pages

    Draft of Civil Pleading

    Uploaded by

    Amol
    S. Janardhana Naidu borrowed Rs. 25,000 from G. Srinivasa Yadav on 26th February 2008 agreeing to pay 24% interest. Naidu executed a promissory note but failed to repay the loan. Yadav sent a lawyer's notice on 4th January 2011 demanding repayment which Naidu ignored. Yadav is now filing a suit against Naidu for recovery of the debt which with interest amounts to Rs. 39,000. Yadav prays that the court pass a judgement directing Naidu to pay Rs. 39,000 with further interest till date of realization and awards costs.

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    © All Rights Reserved
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    CIVIL PLEADINGS

    EXERCISE-I

    FACTS

    S. Janardhana Naidu, S/o. Krishnaiah residing at D.No. 249, Netaji


    th
    Road, Tirupati, borrowed Rs. 25,000 agreeing to pay 24% on 26 Feb, 2008
    from G. Srinivasa Yadav, S/o. Ramaiah at D.No. 247, Netaji Road and
    executed a promissionary note. The promissionary note was scribed by
    K. Venkatasubbaiah a document writer in Tirupati and attested by a
    K. Damodhar Reddy and M. Subramanyam Naidu.

    G. Srinivasa Yadav made demands for the Repayment of the loan and
    also caused a lawyers notice dated 04.01.2011 to be send to S. Janardhana
    Naidu.

    S. Janardhana Naidu who received the notice on 27.01.2011 neither paid


    th
    the amount nor did he respond to the notice on 20 February, 2011. G.Srinivasa
    Yadav filed a suit for the recovery of the debt Draft the plaint.

    1
    PLAINT
    ORDER-6, RULE-17, SECTION-
    26
    In the court of the Junior Civil Judge of
    Tirupati.
    O.S. No …………………/2011
    G. Srinivasa Yadav …….. Plaintiff
    Vs.
    S. Janardhan Naidu ……. Defendant
    Plaint filed on behalf of the plaintiff under order VII Rule-10 and long cause
    title.
    (1) Plaintiff

    G. Srinivasa Yadav, S/o. Ramaiah aged 45 years, Hindu business,


    residing at D.No. 247, Netaji Road, Tirupati, within jurisdiction of this
    honourable court.

    The address for services of notices etc. on the plaintiff is as stated above
    and come of ……………… advocate, Tirupati.

    (2) Defendant

    S. Janardhan Naidu, S/o. Krishnaiah, 40 years, Hindu, Business, residing


    at D.No. 249, Netaji Road, Tirupati within jurisdiction of honourable court.

    The address for service of process etc. on the defendant as stated above.

    (3) Defendant borrowed a sum of Rs. 25,000 on 26.02.2008 and is


    consideration there of executed a promissory note the like sum in favour of the
    plaintiff, agreeing to pay interest at 24% per annum.

    (4) The plaintiff made several demands on the defendant for the repayment of
    the debt. The plaintiff also caused a registered lawyer‟s notice dated
    04.01.2011 to be sent to the defendant did not respond.

    (5) The plaintiff submits that the defendant is not an agriculturist and he is not
    entitled to the benefits under any of the debt relief of law.

    (6) Cause of Action: For this suit arose on 26.02.2008 at Tirupati, within the
    jurisdiction of this honourable court.
    (7) The plaintiff values this suit for the purpose of court fee and jurisdiction of
    39,000/- and pays a court fee of 1.666 under section 20 of A.P. Court fee and
    suits valuation Act.

    (8) Particulars of Valuation


    Principal borrowed 25,00
    0
    Interest 24% p.a from 26.02.2008 to 20.02.2011 14,00
    0
    39,00
    0
    Court fee paid there on relief 1,66
    6
    Prayer

    (9) It is therefore, prayed that the honourable court may be pleaded to pass a
    judgement and decree against the defendant and in favour of the plaintiff

    (10) Directing the plaint defendant to pay the plaintiff the sum of Rs.39,000 on
    with further interest at the contact rate till the date of realization.

    (11) Awarding the plaintiff the cost of this suit and

    (12) Passing such further or other order as the honourable court may deem. Fit
    and proper in the circumstance of the case.

    xxxx xxxx

    Advocate for the plaintiff Plaintiff

    Verification

    I the plaintiff, to hereby declared that the facts stated above true and
    correct to the best of my knowledge, information and belief.

    List of document filed

    (1) Documents original promissory note executed by the defendant.

    Special plaints in suits by a licensor against his licencee by a notice as


    per the licence agreement.

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