SAMPLE OF WRONGFUL DISMISSAL

A.B., the above named plaintiff, states as follows:–
1. On the ……. day of……. 19……., the plaintiff and defendant mutually agreed that the plaintiffs should serve
the defendant as [an accountant, or in the capacity of foreman, or as the case may be], and that the
defendant should employ the plaintiff as such for the term of [one year] and pay him for his services….
rupees [monthly].
2. On the …….. day of ……. 19….., the plaintiff entered upon the service of the defendant and has ever since
been, and still is, ready and willing to continue in such service during the remainder of the said year
whereof the defendant always has had notice.
3. On the …….. day of ……19….., the defendant wrongfully discharged the plaintiff, and refused to permit him
to serve as aforesaid, or to pay him for his services.
[As in paras 4 and 5 of Form No. 1, and relief claimed.]


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