เคฌिเคฒเคुเคฒ! เคจीเคे เคเค 1500 เคถเคฌ्เคฆों เคे เคเคธ-เคชाเคธ เคा เคกिเคेเคฒ्เคก เคก्เคฐाเคซ्เคिंเค เคซॉเคฐ्เคฎेเค เคฆिเคฏा เคเคฏा เคนै। เคฏเคน เคเค “Civil Suit for Recovery of Money” เคा เคซॉเคฐ्เคฎेเค เคนै, เคो เคि เค เค्เคธเคฐ เคเคกเคตोเคेเค्เคธ เคฆ्เคตाเคฐा เคช्เคฐเคฏोเค เคฎें เคฒाเคฏा เคाเคคा เคนै, เคเคฌ เคोเค เคต्เคฏเค्เคคि เค เคชเคจा เคฌเคाเคฏा เคชैเคธा เคตाเคชเคธ เคฒेเคจा เคाเคนเคคा เคนै:
๐ Civil Suit for Recovery of Money
(Under Order VII Rule 1 of the Code of Civil Procedure, 1908)
IN THE COURT OF THE CIVIL JUDGE, [District Court Name]
Civil Suit No. ___ of 20__
IN THE MATTER OF:
[Your Client’s Full Name],
S/o/D/o/W/o [Father’s/Mother’s/Husband’s Name],
Residing at: [Complete Address],
[Occupation],
... Plaintiff
VERSUS
[Debtor’s Full Name],
S/o/D/o/W/o [Father’s/Mother’s/Husband’s Name],
Residing at: [Complete Address],
[Occupation],
... Defendant
SUIT FOR RECOVERY OF MONEY
The Plaintiff respectfully submits as under:
1. That the Plaintiff is a resident of [City, State] and is engaged in the business/profession of [brief description]. The Plaintiff is well known and has good financial and social standing.
2. That the Defendant is also a resident of [City, State] and known to the Plaintiff for the past several years. On the basis of trust and mutual understanding, the Plaintiff had given a sum of ₹[Amount in figures] (₹[Amount in words]) to the Defendant on [Date] as a friendly loan/advance/business transaction.
3. That the said amount was given through [Cash/Cheque/Bank Transfer] bearing transaction ID/Cheque No. [details], drawn on [Bank Name].
4. That the Defendant had assured and promised to repay the said loan within a period of [time period], but has miserably failed to do so. Despite repeated oral and written requests made by the Plaintiff, the Defendant has neither responded nor returned the amount.
5. That on several occasions, including but not limited to [mention dates], the Plaintiff approached the Defendant for repayment. However, the Defendant kept delaying the repayment on one pretext or another.
6. That the cause of action first arose on [initial date of loan], and continued thereafter on each date the demand for repayment was made, and lastly on [last demand date], when the Defendant finally refused to make the payment.
7. That due to the deliberate default and non-payment of dues by the Defendant, the Plaintiff has suffered financial loss, mental agony, and distress.
8. That the Defendant is liable to repay the principal sum of ₹[Amount] along with interest at the rate of [10%/12%/18%] per annum from the date of loan till the date of actual payment.
9. That the total amount due and payable by the Defendant is as follows:
| Particulars | Amount (in ₹) |
|---|---|
| Principal Loan Amount | [amount] |
| Interest @ __% p.a. | [amount] |
| Legal Notice Charges | [amount] |
| Miscellaneous Expenses | [amount] |
| Total | [amount] |
10. That the Plaintiff had also issued a Legal Notice dated [Date] to the Defendant through his advocate, which was duly served on [Date of Service], but the Defendant did not respond or make any payment.
11. That the present suit is being filed within limitation as per Article [relevant] of the Limitation Act, 1963.
12. That the Plaintiff is entitled to costs of the suit, interest pendent lite and future interest at the rate of [12% or other appropriate rate] per annum till final realization.
13. That the cause of action arose within the jurisdiction of this Hon’ble Court, and hence, this court has the jurisdiction to try and decide the present suit.
PRAYER
It is, therefore, most respectfully prayed that this Hon’ble Court may graciously be pleased to:
a) Pass a decree in favour of the Plaintiff and against the Defendant for recovery of ₹[Amount] along with interest @ [rate]% p.a. from [start date] till realization;
b) Award cost of the present suit to the Plaintiff;
c) Grant such other and further reliefs as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case.
Place: [City]
Date: [DD/MM/YYYY]
[Plaintiff’s Signature]
[Name]
[Phone/Email]
Verification
I, [Plaintiff’s Name], the above-named Plaintiff, do hereby verify that the contents of paragraphs 1 to 13 are true and correct to my knowledge and belief and nothing material has been concealed therefrom.
Verified at [City] on this ___ day of [Month], 20__.
[Plaintiff’s Signature]
VAKALATNAMA
I, the above-named Plaintiff, hereby appoint [Advocate’s Name], Advocate, to represent me in the above matter. I empower him to take all necessary steps, file documents, engage counsel, and do all acts necessary on my behalf.
Date:
Signature of Plaintiff
๐ Anticipatory Bail Application
(Under Section 438 of the Code of Criminal Procedure, 1973)
IN THE COURT OF THE HON’BLE SESSIONS JUDGE, [Name of District/City]
Bail Application No. ______ of 20__
IN THE MATTER OF:
[Applicant’s Full Name],
S/o/D/o/W/o [Father’s/Mother’s/Husband’s Name],
Age: __ years, Occupation: ___________,
Resident of: [Full Residential Address]
… Applicant/Accused
VERSUS
The State of [State Name]
… Respondent
APPLICATION UNDER SECTION 438 Cr.P.C. FOR GRANT OF ANTICIPATORY BAIL TO THE APPLICANT IN CASE FIR NO. ___ DATED ____, U/S [Section numbers] REGISTERED AT P.S. [Police Station Name], DISTRICT [District Name]
TO,
THE HON’BLE SESSIONS COURT AT [Place]
The humble application of the Applicant above-named:
MOST RESPECTFULLY SHOWETH:
1. That the Applicant is a law-abiding and respectable citizen of India and has never been involved in any criminal case in the past.
2. That the Applicant has reasons to believe that he may be falsely implicated and arrested by the police in the above-mentioned case bearing FIR No. ___ dated ____, registered under Sections [mention Sections] of IPC/BNS/other laws at [Police Station], even though he has committed no offence.
3. That the allegations made against the Applicant in the said FIR are false, frivolous, concocted and baseless, and have been leveled with the sole intention to harass, humiliate, and exert pressure upon the Applicant due to [mention the motive, e.g., personal enmity, property dispute, matrimonial discord, business rivalry, etc.].
4. That the Applicant has not committed any offence and is ready to fully cooperate with the investigating agency and join the investigation as and when required.
5. That the Applicant submits that the alleged offences are not of such a nature that custodial interrogation is necessary. All relevant facts and documents, if any, can be produced and investigated without arresting the Applicant.
6. That the Applicant is a permanent resident of [address] and there is no chance of his absconding or fleeing from justice. He undertakes to be present before the Investigating Officer or Court as and when directed.
7. That the Applicant undertakes not to tamper with prosecution witnesses or destroy any evidence. The Applicant also undertakes not to leave the country without prior permission of the Court.
8. That the Applicant has a clean antecedent and no criminal case or FIR is pending or registered against him except the present false case.
9. That the Hon’ble Court has wide powers under Section 438 of the Cr.P.C. to grant anticipatory bail to protect the liberty of innocent individuals who apprehend arrest on false charges.
10. That if the anticipatory bail is not granted to the Applicant, he shall suffer irreparable injury to his life, reputation, and liberty.
11. That the Applicant is willing to abide by any condition imposed by this Hon’ble Court while granting anticipatory bail.
PRAYER
In the facts and circumstances stated hereinabove, the Applicant most respectfully prays that this Hon’ble Court may be pleased to:
a) Grant anticipatory bail to the Applicant in connection with FIR No. ___ dated ___, u/s [mention sections] registered at P.S. [Name], District [Name], in the interest of justice;
b) Direct the Investigating Officer not to arrest the Applicant during the course of investigation;
c) Pass any other or further orders as this Hon’ble Court may deem fit and proper in the facts and circumstances of the case.
AND FOR THIS ACT OF KINDNESS, THE APPLICANT SHALL EVER PRAY.
Place: [City]
Date: [DD/MM/YYYY]
[Applicant’s Signature]
[Full Name of Applicant]
AFFIDAVIT
IN THE COURT OF THE HON’BLE SESSIONS JUDGE, [District Name]
I, [Full Name of Applicant], aged about __ years, S/o/D/o/W/o [Parent/Spouse’s Name], presently residing at [Address], do hereby solemnly affirm and state on oath as under:
-
That I am the Applicant in the above Anticipatory Bail Application and am well conversant with the facts and circumstances of the case.
-
That the accompanying application has been drafted under my instructions and the contents thereof are true and correct to my knowledge and belief.
-
That the statements made herein are true and correct and nothing material has been concealed therefrom.
DEPONENT
(Signature of Applicant)
VERIFICATION
Verified at [City] on this ___ day of [Month], 20__ that the contents of this affidavit are true and correct to the best of my knowledge and belief.
DEPONENT
(Signature)
VAKALATNAMA
Know all to whom it may concern that I, [Applicant’s Name], the Applicant in the above case, do hereby appoint Advocate [Name], enrolled with [Bar Council name], having Chamber at [Address], to be my Advocate to conduct the above-mentioned case on my behalf in this Hon’ble Court.
Date:
Signature of the Applicant
(Full Name)
Accepted:
(Signature of Advocate)
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