IN THE COURT OF C1 :: PL1
O.S.No. of y1
Between:
p1 p3
... Plaintiff
And
d1 d3
... Defendant
PLAINT PRESENTED BY THE PLAINTIFF UNDER ORDER 7 RULES 1 AND 2 AND SECTION 26 OF
CODE OF CIVIL PROCEDURE 1908.
1. PLAINTIFF:
p2
2. DEFENDANT:
d2
The address for service of all notices on the plaintiff is that of his advocates Sri Add7, Add8
Advocates, Pl1 and that of the defendant is as stated above
3. The plaintiff is the owner of the plaint schedule property. The defendant is a tenant of the
plaint schedule property on a monthly rent of r1 which is payable every month. There is a
practice of passing receipts. The defendant never paid the rent without a receipt. The defendant
agreed not to sub-lease the plaint schedule property to any body. The defendant is a month to
month tenant.
4. The plaintiff submits that the A. P. Buildings [Lease, Rent and Eviction] Control Act will not
apply to the tenancy of the defendant.
5. The plaintiff further got issued a registered notice on dt1 terminating the tenancy by the end
of m1 month. Inspite of the notice the defendant failed to vacate and hand over the plaint
schedule property to the plaintiff. Therefore the plaintiff files the suit for eviction of the
defendant and also for recovery of arrears of rent.
6. The plaintiff submits that if the plaint schedule property is leased out he will get a sum of r2/-
considering the present rents prevailing in the area. Since the lease is terminated the defendant
is liable to pay damages for use and occupation at Rs.r2/-
7. The cause of action for the suit arose when the defendant took the property on lease and on
dt1 when the plaintiff got issued a notice terminating the tenancy by the end of m1 month at
Pl1 where the plaint schedule property is situated within the jurisdiction of the Hon’ble Court.
8. Value of the suit:
Relief of eviction valued under Sec.40 of Andhra Pradesh Court Fees and Suits Valuation Act on
an yearly rent Rs.r1/- x
.. Rs. r3
A court fee of Rs. cf1 /- is paid under Schedule (I) Article (I)(c) of Andhra Pradesh Court Fees and
Suits Valuation Act.
9. The plaintiff therefore prays that the Hon'ble Court may be pleased to grant a decree for
vacant possession of the plaint schedule property after ejecting the defendant from the plaint
schedule property and award future profits and award costs and such other relief as the Hon'ble
court deems fit and proper in the circumstances of the case.
Be pleased to consider,
Plaintiff:
The contents stated above are read over and explained to me in Telugu and having perfectly
understood the same and I declare that the contents stated above are true to best of my
knowledge, information, belief and I signed/affixed thumb mark on this plaint at Pl1 on d5.
Plaintiff:
LIST OF DOCUMENTS FILED:
1.
Advocate for the plaintiff
