In the Court of the .................. at..........
O.S No. .............of 20
ABC.
.. Plaintiff
[1] XYZ Editor .......
[2] MNO.
...Defendants;
Plaint filed by the Plaintiff O.VII R.1 to 6 C.P.C.
1. Plaintiff: ABC........ S/o. .......aged about.........years, Roads and Building Department Residing at, ................
Address of the plaintiff stated as above
2. Defendants: - XYZ is S/o. ............ aged about..... years, Editor of Daily............., having its office at... The second defendant is MNO, S/o.................. years local reporter residing at.............
Address of the Defendant stated as above
1. The plaintiff is the Executive Engineer in the department of Roads and Buildings, having its office at ........................... As Chief Executive Engineer, he called for tenders for the construction of at ................ Subsequently the contract was given to Mr ............ for construction work. The first defendant is the Editor and publisher of local ................. by name ................. and the second defendant is its local reporter.
2. On ......... an article appeared in the said .................. daily under the Heading "Corruption in the office of Executive Engineer" wherein it was alleged that the plaintiff took bribes from the said contractor relating the construction work of Housing ............................ It was also alleged in the said article that the plaintiff is not honest and that he was a corrupt man and that he is getting huge amount as bribes and remuneration from various persons. The said article was subscribed by the second defendant. who is the local reporter.
3. The plaintiff is very honest and sincere. He is working in the Housing Department for the last 25 years and is having good reputation from public as sincere officer. The article appeared in the said paper referred above is scandalous and full of lies. There are no bona fides in the said article. The said article was published with an evil intention to defame the plaintiff. After the said article, the prestige of the plaintiff was very much damaged in the eye of the public, co-employees, officers, relatives and friends. It also hurt the personal feelings of the plaintiff and the plaintiff is suffering mental agony.
4. The plaintiff also wrote a letter to the first defendant on ................ asking him to give unconditional apology for publishing such scandalous and defamatory matter against him. But so far the first defendant did not come forward with an apology. The Senior Superintendent of the Housing Department also issued a memo dated ............ asking the plaintiff to give explanation for the article published in the said magazine. The above said article is very defamatory and damaged the prestige of the plaintiff. The plaintiff is estimating the damage caused to him at Rs. 1 lakh.
5. The plaintiff also got issued a registered notice to both the defendants on .......... through his Advocate demanding the defendants to pay him Rs. 10 Lakh as damages. The defendants received the same but did not choose to pay the amount. They also not cared to give a reply even. Both the defendant are jointly and severally liable to pay the amount. Hence this suit.
6. Cause of action:- Cause of action of the suit arose when the first defendant published an article dated ............. in his ................ Daily subscribed by the second defendant and subsequently when the said article damaged the prestige of the plaintiff and when the Superintendent of the Housing Department issued a memo on ........... at ........... where the defamatory article was published and the plaintiff reside within the jurisdiction of this Hon'ble Court.
7. Valuation:- This being a suit for defamation the plaintiff values the damage caused to him as Rs. 10 lakh over which a court fee of Rs................ is paid herewith under Section .............. of ........... Court Fees and Suits Valuation Act.
8. Value for the purpose of jurisdiction is same as above.
9. The plaintiff therefore prays that this Hon'ble Court may be pleased to pass a decree jointly and severally against both the defendants:
[a] for suit amount;
[b] for costs;
[c] for such other reliefs that this Hon'ble Court deems fit and proper in the circumstances of the suit.
Plaintiff
ABC.
Advocate for the plaintiff.
Verification
Plaintiff
ABC.
List of documents:
Verification
Plaintiff
ABC.
Advocate of Plaintiff