CIVIL TRIAL ADVOCACY- PREMISE

 

PART-II

IN THE COURT OF JR.CIVIL JUDGE, MEDCHAL

AT: MEDCHAL: RANGA REDDY DISTRICT

O.S.no       /2011

Between:

Ram S/o: Late Shankar,

Age:26, Occ: Law Attorney,

R/o: ShameerPet Village, ShameerPet Mandal,

Ranga Reddy District.                                                     ………..Plaintiff

And

Krish S/o Naryana

Age:26, Occ: Advocate,

R/o: ShameerPet Village, ShameerPet Mandal,

Ranga Reddy District                                                               ………..Defendant
Plaint filed u/s.26 OVII R.1 Civil Procedure code

Claim: Suit for recovery of Money

The plaintiff respectfully submits as follows:

      1) It is respectfully submitted that plaintiff and defendant are native of shameerpet village. They are childhood friends.

   2) It is submitted that out of such acquaintance, the defendant on 02.10.2009 at shameerpet village requested the plaintiff to lend a hand loan amount of Rs.50,000/-(Rupees Fifty thousand only) in order to perform the marriage of his sister. As such plaintiff lent the same to the defendant.

  3) It is submitted that at that time defendant executed a demand promissory note in favour of the plaintiff covering the above said amount with a promise to repay the same @2% interest per month.

      4) It is submitted that defendant despite repeated requests including by way of notice 11.11.2011 to repay the amount, but of no avail. On the contrary, he replied by way of legal notice stating that above transaction as false, which is untrue. Hence, the present suit is recovery for an amount of Rs.50000/-(Rupees Fifty thousand only).

5) The suit is filed within three years from date of execution of promissory note date: 02.10.2009. As such suit is filed within the period of limitation under Article 113 of the limitation Act.

 6) This being a suit for recovery money, the Plaintiff values the relief of injunction at Rs.1,00,000/-(Rupees One Lakh) as such an amount of Rs.3426/-(Rupees Three thousand four hundred twenty six only) is paid as per schedule-I of A.P.Court Fee and Suit valuation Act.

Prayer: To grant a decree for recovery of an amount of Rs1,00,000/-(Rupees One Lakh) with interest. To order costs of the suit.

 List of Documents:

 1) Promissory Note executed by Krish in favour of ram dated: 02.10.2009.

 2) HDFC Bank Account Statement of Ram

 3) Wedding Card of Krish sister dated:

   4) Legal notice notice dated:11.11.2011

5) Registered post Acknowledgement

 

 

 

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