IN THE CITY CIVIL COURT AT DINDOSHI, MUMBAI
IN
SUIT NO. 43 OF 2015
Bhavesh Shah,
Age: Adult
Currently residing at 603
Belscout Apartments,
Saint George Road,
Andheri (west)
Mumbai 400 053 Plaintiff
Versus
Nitin Masand
Age: Adult
Residing at Windermere Apartments
Lokhandwala, Andheri (west)
Mumbai- 400 053 Defendant
THE PLAINTIFF ABOVE NAMED BEGS TO STATE AS UNDER:
1. I say that the my client had been a tenant of the premises situated at 103, Illa Towers, V.
S. Road, Dindoshi Mumbai- 400 097 and the defendant is the owner of the said house.
The schedule of the Property is annexed herewith as Annexure –I. The plaintiff was in
juridical possession of the property as a tenant up to 27 th June, 2015 and even thereafter
legal possession belongs to him since the plaintiff is wrongfully dispossessed from the
tenanted premises by the defendant. The Lease Agreement dated 26 th July, 2013 is
annexed herewith as Annexure- II.
2. I say that on 20th July, 2015, the defendant dispossessed the plaintiff (my client) forcibly
without following the due course of law. The plaintiff has fulfilled all the conditions of
tenancy, and therefore, the defendant has no legal right to physically dispossess the
plaintiff from the tenanted house.
3. I say that my client (plaintiff) is entitled to recover the peaceful possession of the
premises to which he is the tenant and the defendant is liable to restore such possession to
the plaintiff without delay.
4. I say that the cause of action accrued to the plaintiff against the defendant as on 20 th July,
2015 on which date the defendant wrongfully dispossessed the plaintiff from the premises
in suit without following the legal course for the eviction of a tenant.
5. I say that this court has jurisdiction to entertain this suit as the cause of the action accrued
to the plaintiff against the defendant within the local jurisdiction of this court.
6. I say that the valuation of this suit for the purposes of jurisdiction and court fees is fixed
at Rs. 1,20,000 (as is the annual rental value of the premises under tenancy), on which a
which a court fee Rs. ________ has been duly aid herewith.
7. I say that the suit of the plaintiff is within limitation.
Prayer
The plaintiff prays that this Hon’ble Court be pleased to pass the following orders :
(a) A decree in favor of the plaintiff and against the defendant may be passed for the
delivery of the possession of the premises in suit to the plaintiff.
(b) The costs of the suit be awarded to the plaintiff.
(c) Any other relief which this court may deem fit under the circumstances of the case
please be awarded to the plaintiff.
Dated- 28th July, 2015
Plaint drawn by :
Sd/- Sd/-
(Advocate for Plaintiff) (Plaintiff)
Verification
I, the plaintiff named above, do hereby state that what is stated in the foregoing paragraphs No.1-
4 is true to my own knowledge and what is stated in paragraphs No. 5, 6, and 7 are believed by
me to be true as per the legal advice received by me.
Signed, understood and verified by me )
This 28th day of July, 2015 )
Solemnly Affirmed at Mumbai ) Sd/-
(Plaintiff)
Signed, and verified by me on
This 28th day of July, 2015 Sd/-
(Advocate for Plaintiff)
DOCKET
IN THE CITY CIVIL COURT AT
DINDOSHI, MUMBAI
IN
SUIT NO. 43 OF 2015
Bhavesh Shah … Plaintiff
Versus
Nitin Masand… Defendant
PLAINT
Solemnly Affirmed at Mumbai )
This 28th day of July, 2015 )
Sd/-
(Advocate for Plaintiff)
Sd/-
(Plaintiff)