Drafting a plaint

 Format for drafting of plaint is described in Order 6 of CPC. A plaint when accepted by the court and notice issued to the opposite party becomes a suit. The following point numbers do not match with the actual point number in Order 6. The actual point numbers in Order 6 are called "Rules". So a term like "order 6 Rule 8" means 8th point in the list under Order 6.

1) CPC says that you only need to specify the statements/facts on which you're going to rely to either show your losses or as a defense. You need not put evidence.

"It should contain statements in a concise form of the material facts on which the party pleading relies for his claim or defence as the case may be, but not the evidence by which they are to be proved."

2) Every pleading shall, when necessary, be divided into paragraphs, numbered consecutively, each allegation being, so far as is convenient, contained in a separate paragraph.

3) Dates, sums and numbers shall be expressed in a pleading in figures as well as in words.

4) Specify the necessary facts in plaint:

Any condition precedent, the performance or occurrence of which is intended to be contested, shall be distinctly specified in his pleading by the plaintiff or defendant

5) You cannot raise any new ground of claim or make additional allegations inconsistent with previous pleadings.

"No pleading shall, except by way of amendment, raise any new ground of claim or contain any allegation of fact inconsistent with the previous pleadings of the party pleading the same."

6) If you've to rely on or cite an external document, you can just cite the relevant line/para without repeating the whole document.

"Wherever the contents of any document are material, it shall be sufficient in any pleading to state the effect thereof as briefly as possible, without setting out the whole or any part thereof, unless the precise words of the document or any part thereof are material."

7) Allege without giving details on circumstance/inference. It is the job of court to determine if your allegations are correct or not:

"Wherever it is material to allege malice, fraudulent intention, knowledge or other condition of the mind of any person, it shall be sufficient to allege the same as a fact without setting out the circumstances from which the same is to be inferred."

8) pleader's address for service as required by rule 32 of Order V 

Every pleading, when filed by a party, shall be accompanied by a statement in the prescribed form, signed as provided in rule 14, regarding the address of the party.

9) The person verifying shall specify, by reference to the numbered paragraphs of the pleading, what he verifies of his own knowledge and what he verifies upon information received and believed to be true.

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