IN THE COURT OF _______________
CS NO________ OF ___20__
IN THE MATTER OF :
___________________________________
...PLAINTIFF
VERSUS
___________________________________
...DEFENDANT
PLAINT UNDER ORDER VII RULE 1 FOR COMPENSATION FOR DEFAMATION
MOST RESPECTFULLY SHOWETH:
1. That the present Suit is being preferred by the above named
Plaintiff against the Defendant for making
defamatory remarks against the Plaintiff while making false and defamatory
statements on _____ around _____ A.M.
2. That the Plaintiff is a respectable man and a Doctor of repute of at ____________.
3. That the Defendant is a ward member at __________ and a Politician.
4. That the Defendant approached the Plaintiff for donation of Rs. _____ for his political party. The Plaintiff refused to pay the amount which caused anger to the Defendant. The Defendant waned the Plaintiff that he will teach the Plaintiff a lesson.
5. That on ______ the Defendant published an article in the Social Media that the Plaintiff is giving substandard medicine to the patients. The Defendant has lakhs of followers in the social medial, who read the post and passed comments harming the reputation of the Plaintiff.
6. That after posting the article the Defendant filed a complaint against the Plaintiff. An enquiry was conducted against the Plaintiff and it was found that the claim of the Defendant was wrong.
7. That the report and the complaint of the Defendant were based on absolutely false allegations and the Defendant acted maliciously and without reasonable or probable cause in lodging the same.
8. That many persons, including a large number of the Plaintiff's patients, hearing of the prosecution of the Plaintiff for cheating, and supposing the Plaintiff to be a criminal, have ceased to be treated by and have dealings with the Plaintiff, whereby the Plaintiff has suffered considerable and substantial monetary loss.
9. That in consequence of the said allegations and complaint, the Plaintiff suffered physical pain and mental shock and was prevented from transacting his business and profession besides being injured in his credit and reputation.
10. That the Plaintiff incurred an expenditure of Rs______ in defending himself against the defendant's said complaint.
11. That the Plaintiff is entitled to recover from the Defendant as damages the amounts detailed below:
On account of loss of income from profession Rs_____________
On account of loss of reputation and credit Rs____________
On account of bodily and mental pain Rs ____________
On account of expenses of defense Rs_________
Total Rs ___________________
12. That the Plaintiff sent a legal notice to the Defendant demanding
payment of the aforesaid amount of Rs _____. The notice was served on the
defendant on ______ but he sent no reply.
13. That the cause of action arose on____ the date on which the Plaintiff was acquitted, at ______ Within the jurisdiction of this Court which has jurisdiction to try this suit.
14. That the valuation of the suit for the purposes of jurisdiction and payment of court-fee is Rs _____ and ad valorem court-fee has been paid accordingly.
PRAYERS
In view of the above it is most respectfully prayed that his Hon'ble Court
may graciously be please to:-
i) Pass a decree for Rs ______in favour of the Plaintiff and against the Defendant;
ii) Pass order of Pendent lite and future interests to be awarded to the Plaintiff;
iii) Pass order
directing to pay the Plaintiff costs of the suit by the Defendant;
iv) Pass any other or further order/s as this Hon'ble Court may deem fit and
proper in the facts and circumstances of the case.
PLAINTIFF
THROUGH
__________Advocate
Place:_________
Date:__________
IN THE COURT OF _______________
CS NO________ OF ___20__
IN THE MATTER OF :
___________________________________
...PLAINTIFF
VERSUS
___________________________________
...DEFENDANT
AFFIDAVIT
I, ___________________ S/O ___________________ R/O _________________ do hereby solemnly affirm and declare as under:
1. That I am the Plaintiff of the instant Suit and being conversant with the facts and circumstances of the case, am competent to swear this Affidavit.
2. That the accompanying Suit has been drafted under my instructions, the contents of which are true and correct on the basis of records maintained by me. No part of it is false and nothing material has been concealed therefrom.
DEPONENT
VERIFICATION:
I, the above named Deponent, do hereby verify that the contents of the above
affidavit are true and correct to my knowledge, no part of it is false and
nothing material has been concealed therefrom.
Verified at New Delhi on this ____ day of _____, 20__
DEPONENT
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