POINTERS ON HOW TO EFFECTIVELY WRITE A PLEADING

1. Pleading shall contain and contain only statement in a concise form of

the material fact on which the party pleading relies for his claims or

defense as the case may be.

2. Pleading must use proper legal terms, words and expressions.

3. Dates, sums and figures or numbers shall be expressed in words and

figures.

4. Point to considered in drafting plaint, the legal issue whether the suit

is within limitation? What would be the proper court and suit valuation?

Which court of jurisdiction? The nature of suit or case of action and

relief and determination of parties.

5. Before drafting the plaint, scrutinize the facts properly with legal point

of view.

6. The content of the plaint should be verified with the clear statement

that such and such paragraphs number are true to his personal

knowledge. Verification of the plaint should be duly signed by the

plaintiff mentioning date and place of verification.

7. 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.

8. The pleading shall specify the relief sought, but it may add a general

prayer for such further or other relief as may be deemed just or

equitable.

9. Every pleading shall be dated.

10. Every pleading must be signed by the party or counsel representing

him, stating in either case his address which should not be a post office

box

11. Pleading shall be divided into paragraphs so numbered to be readily

identified, each of which shall contain a statement of a single set of

circumstances so far as that can be done with convenience. A

paragraph may be referred to by its number in all succeeding

pleadings.

12. Pleading should use simple words that can be understand easily.

13. Pleading shall contain in a methodical and logical form, a plain, concise

and direct statement of the ultimate facts on which the party pleading

relies for his claim or defense, as the case may be, omitting the

statement of mere evidentiary facts.

14. Name of parties and address should be expressed

15. In all averments of fraud or mistake the circumstances constituting

fraud or mistake must be stated with particularity. Malice, intent,

knowledge, or other condition of the mind of a person may be averred

generally

16. Avoid vague statement when writing pleading. It will defeat the

purpose of clearly presenting the information in pleading.

17. Read and adhere to the standard rules regarding the font size,

margins requirement and spacing.

18. Pleading should be short and plain statement of claims and defense.

19. Pleading should show strong arguments.

20. Every statement in the pleading should be direct and straight to the

point.