SUIT AGAINST SURETY FOR PAYMENT OF RENT

IN THE COURT OF THE………………..

Suit No………………… of 19………………..

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

versus

C. F……………………………………………………….. Defendant

The abovenatned plaintiff most respectfully submits as under: —

1. On the……………….. day of……………….. 19………………… C. F. hired from the plaintiff for the term of……………….. years, (house No…………………. street), at the annual rent of……………….. rupees, payable (monthly).

2. The defendant agreed, in consideration of the letting of premises to C. F., to guarantee the punctual payment of the rent.

3. The rent for the months of……………….. 19………………… amounting ……………….. rupees, has not been paid.

4. By terms the agreement aforesaid, the required notice is also served on the Surety/defendant for payment of the rent fallen due as aforementioned, but the surety has not cared even to reply the notice.

5. On the……………….. day of……………….. 19………………… the plaintiff also gave a notice to C. F., tenant for payment of the rent fallen due as mentioned above, but the defendant No. 2 replied vide his letter dated……………….. 19……………….. to the plaintiff that no rent is due to him, this reply was received by the plaintiff on………………..

6. The liability of the defendants is joint as well as several.

7. Neither of the defendants has paid the rent fallen due as aforesaid.

8. Cause of action arose within the jurisdiction of this Court against defendant No. 1 on……………….. 19……………….. when he received the notice of demand of the plaintiff and against defendant No. 2 on…………. 19…….. when he received notice of demand of the plaintiff and lastly when they refused to pay anything to the plaintiff, through a registered letter received by the plaintiff on……………….. 19………………..

9. The valuation of the suit is……………….. rupees, the amount of the arrears of rent fallen due against defendant No. 2 plus interest at the rate of

……………….. % per annum up to the date of filing the suit, and court fee is paid thereon.

RELIEFS CLAIMED:

The plaintiff claims the following reliefs:

(i) A decree for Rs………………… be passed against the defendants No. 1 and 2 jointly as well as severally.

(ii) Interest pendente lite may be awarded on the amount of arrears rent fallen due.

Plaintiff

Through Advocate

VERIFICATION

I, abovenamed 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……………….. 19……………….. at………………..

Plaintiff