SAMPLE OF FORECLOSURE OR SALE

A.B., the above named plaintiff, states as follows:–
1. The plaintiff is mortgagee of lands belonging to the defendant.
2. The following are the particulars of the mortgage:–
(a) (date);
(b) (names of mortgagor and mortgagee);
(c) (sum secured);
(d) (rate of interest);
(e) (property subject to mortgage);
(f) (amount now due);
(g) (if the plaintiffs title is derivative, state shortly the transfers or devolution under which he claims.–
(If the plaintiff is mortgagee in possession, add).
3. The plaintiff took possession of the mortgaged property on the …………. day of …………… and is ready to account as mortgagee in possession from the time.
[As in paras 4 and 5 of Form No. 1.]
6. The plaintiff claims–
(1) payment, or in default [sale or] foreclosure [and possession];
[Where Order 34, and of Form No. 1]
(2) in case the proceeds of the sale are found to be insufficient to pay the amount due to
the plaintiff, then that liberty be reserved to the plaintiff to apply for an order for the balance.


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