SUIT FOR RECOVERY OF MONEY LENT FROM THE SALE OF PLEDGED PROPERTY.

IN THE COURT OF THE ......................

Suit No..............of 20.....

C.D.............................................Plaintiff

versus

C.F.........................................Defendant

The above named plaintiff most respectfully submits as under :-

1. That on ..................20 .................... the defendant borrowed Rs........... from the plaintiff by pawning his .......................with the latter, its R.C. No. being ................ and executed a deed of pledge to that effect. 

2. That on ........... 20 ............... the plaintiff sent a registered notice to the defendant demanding the principal money aforesaid with interest as settled @12 per cent per annum, and that if he failed to tender the said amount the plaintiff would sell the pledged article aforesaid, and adjust the proceeds thereto.

3. That the defendant did not pay the amount due or any part thereof.

4. That the plaintiff sold the pledged property for Rs................. adjusted these proceeds towards his amount aforesaid, and still Rs................. remains towards the loan amount and interest. and

5. The cause of action arose on ................. 20 .................... when the defendant received the notice of demand and failed to pay the amount aforementioned.

6. That the suit is valued at Rs............... the amount remaining due even after adjustment from the sale of the pledged property aforesaid and court fee is paid accordingly.

RELIEF CLAIMED :

The plaintiff claims payment of Rs....................... towards the remaining principal amount and interest due upto date of filing the suit, and interest thereafter till payment thereof.

Plaintiff

Through

Advocate

VERIFICATION

I, above named plaintiff, do hereby verify that the contents of paras............... to ..................... of the plaint are true to my personal knowledge and those of paras .................. and ................. thereof are based on legal advice which I believe to be true. 

Verified on this .............. day of.................. 20 ........... at................

Plaintiff