IN THE COURT OF CIVIL JUDGE (J.D.

), DEHRADUN

Civil Suit No.: _______of 2018

Abhishek Gupta

...................Plaintiff

Vs.

Ashish Kumar
..............Defendants

Sir,

The plaintiffs most respectfully submit as under:-

1. That a lease agreement was entered by defendant with plaintiff for a house
situated at Ballupur, Dehradun on 1 October 2017 for eleven months (11
months).
2. That Mr. Abhishek Gupta is absolute owner of property i.e. house no. 3 consisting a
fully furnished 2BHK house with khasra no. 124/6, situated at Devi colony, Prayag
Road, Ballupur, Dehradun.
3. That the tenant i.e. defendant has to give 7000/month to plaintiff as rent including all
other charges like electricity and water bills etc.
4. That Mr. Abhishek Gupta being a responsible citizen warned defendant not to carry
out any illegal activity in property premises otherwise he will not renew the
agreement for lease.
5. That defendant has carried out few illegal activities like drug peddling and acting as a
pimp.
6. That defendant’s agreement has expired on 31 august 2018 and he has not paid 4
months’ rent till 31 august 2018. Also, defendant is not vacating property and residing
there for 2 months more without renewing agreement.
7. That plaintiff has warned defendant many times orally and through notice, for
vacating property and not to carryout any illegal activity there, for which plaintiff did
not received any reply in either form from defendant.
8. That the defendant is liable to pay Rs. 33600/- alongwith interest @ 6% per annum for
arrears of rent.
9. Particulars of Claim :
Rs. 28,000/-_ Arrears of Rent.
Rs. 5,600/-_ interest rate on arrears.
Rs. 1,000/- _ Notice Charges.
Rs. 34,600/- _ Total Amount Due and Claimed
10. That the cause of action for the present suit first arose when the defendant refused to
vacate the suit premises, and the same has since then been arising every day
thereafter, and hence, the suit filed today is well within limitation.
11. That the property is situate within the local limits of the jurisdiction of this court, and
hence, this Hon'ble Court has jurisdiction to try and decide this suit.
12. That the proper court fee is paid herewith.
13. That the plaintiff, therefore, prays that -
(A) It be ordered that the defendant should vacate the suit
premises;
(B) The arrears of rent be recovered from the defendant;
(C) Vacant possession of the suit premises be restored to the
plaintiff;
(D) The defendant be ordered to pay unto this plaintiff the amount of money claimed;
(E) The costs of this plaintiff be paid from the defendant; and
(F) Any other orders in the interest of justice be kindly passed.

Dated Plaintiff

I, Abhishek Gupta do hereby verify that the contents of the above plaint in paras 1 to
13 are partly true to my own knowledge and partly true on the basis of documents
and partly on the basis of information and legal advice received, which I believe to be
true. Verified at Dehradun on day of , 2018.

Plaintiff