IN THE COURT OF THE………………..
Suit No………………… of 19………………..
C. D………………………………………………………….. Plaintiff
versus
C. F……………………………………………………….. Defendant
The abovenamed plaintiff most respectfully submits as under: —
1. That on……………….. the plaintiff appointed the defendant as their commission agent for the District of………………… for the sale of books published by the plaintiffs, through a letter of appointment as such.
2. That the defendant agreed that he would sell the books of the plaintiffs and would render to the plaintiffs true and full account at three months’ intervals, of all the sales so effected, and would pay over to the plaintiffs all moneys received by him for such books.
3. That the plaintiffs sent a stock of books worth Rs………………… (…………………………………. ) on……………….. through Railway Parcel on a mere advance of Rs………………… (…………………………………. ) received on……………….. through bank draft from the defendant.
4. That the defendant has not, rendered any accounts to the plaintiffs or paid over to the plaintiffs the moneys received by him for the books sold, even at repeated reminders sent to the defendant, and lastly a registered notice also was served on the defendant on………………..
5. That the plaintiffs have been kept in ignorance as to the sales effected by him, the particulars of the purchasers and the books still unsold, nor has returned the unsold books so far.
6. That the cause of action arose within the jurisdiction of this Court on ……………….. 19……………….. when the defendant received the registered notice of the plaintiffs, but did not reply to it. According to the Agreement of Commission on Agency with the defendant, which was executed at………………… and the books were sent per order by post to the defendant from………………… this court has jurisdiction to try this suit.
7. The suit is valued at……………….. and court fee is paid according to the relief claimed.
8. That the plaintiff claims the following reliefs:
(1) To have full and true account of sales effected by the defendant.
(2) Payment of the moneys received by such sales minus Rs………………… already paid and the commission @……………….. % on the printed price of the books sold.
(3) Interest on such moneys, by way of damages at……………….. per cent per annum or at such rate as the Court considers fit, uptodate.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