Civil Suit Draft for Recovery of Goods or Damages

 

IN THE COURT OF [COURT NAME]

AT [PLACE]

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Suit No.: ___________ of 20__

Plaintiff:
[Your Name]
[Address]
[Contact Details]

Vs.

Defendant:
[Bailee’s Name]
[Address]
[Contact Details]

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SUIT FOR RECOVERY OF GOODS / DAMAGES FOR BREACH OF BAILMENT

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The Plaintiff respectfully submits:

1. Parties:
   The Plaintiff is the lawful owner and bailor of certain goods described as [brief description of goods].
   The Defendant is the bailee who received the goods under a bailment contract on [date].

2. Facts of the Case:
   a) On [date], the Plaintiff delivered the goods to the Defendant for the purpose of [state purpose, e.g., safekeeping, repair, etc.].
   b) The Defendant undertook to take due care and return the goods after fulfilling the purpose.
   c) Despite repeated requests and reminders, the Defendant has failed to return the goods / has misused / damaged the goods causing loss to the Plaintiff.

3. Cause of Action:
   The Defendant’s failure to return the goods / damage to the goods amounts to a breach of bailment and a violation of contractual obligations.

4. Reliefs Sought:
   The Plaintiff prays for the following relief(s):
   a) Recovery of the goods described as [description], or in the alternative,
   b) Compensation / damages of Rs. __________ for the loss suffered due to breach of bailment.
   c) Interest on the amount at the prevailing rate from the date of breach till realization.
   d) Costs of the suit.
   e) Any other relief the Hon’ble Court deems fit and proper in the interest of justice.

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Verification:
I, [Plaintiff’s Name], do hereby verify that the contents of paragraphs 1 to 4 are true to my knowledge and belief. No part of it is false, and nothing material has been concealed.

Date: ___________
Place: ___________

(Signature of Plaintiff / Advocate)
Name: _______________