Gurjit Sir Drafts

Drafting/Pleading
Syllabus-
In case of Plaints- Format
 Start with Sir, it is respectfully submitted as

 The last three paras will be dedicated to-
o C- Cause of Action
o J- Jurisidiction
o V- Value of Suit for Court Fees
Draft begins after heading/title ends
Permanent Injunction- Module 1
 Unlike Mandatory Injunctions- permanent injunctions are sought in order to restrain the

defendant from doing something
In the Court of Civil Judge (Senior Division), Patiala
Suit No________ of 2020
IN THE MATTER OF:

Ram Lal S/O Sohan Lal, resident of House Number Plaintiffs
Versus
Subash Garg, Son Of Mukesh Garg, resident of Defendants
SUIT FOR PERMANENT INJUNCTION RESTRAINING THE DEFENDANT FROM

ILLEGALLY DISPOSSESSING THE PLAINTIFF FROM HOUSE NUMBER 18, Sirhind
Road, Patiala- 250 Square Feet- 2 Bedrooms..Other Details- Bounded as under
North- Road
South- Road
East- House 17
West- House 19
Sir it respectfully submitted as
1. That the plaintiff is a law abiding and responsible citizen

2. That plaintiff and defendant are neighbours for the last 25 year and common boundary
wall marked A-A-B measuring 30*5 feet and shown in red in the site plan attached-
separates the houses of the plaintiff and the defendant (Copy of site plan is attached).
3. That for the last 2 months the defendant is threatening to illegally and forcibly demolish
the said common boundary wall.
4. That the plaintiff filed an application with the welfare association of Azad Nagar Patiala,
requesting the association to stop the defendant from doing the illegal act. The
Association passed a resolution dated 26/11/2020 asking the defendant to refrain from
demolishing the boundary wall. ( Copy of the application and copy of the resolution is
attached)
5. That the plaintiff served the defendant with legal notice dated 1/2/2020 (copy of legal
notice and postal stamp is attached)
6. That the plaintiff yesterday, that is 13/2/2020 once again requested the defendant from
demolishing the said boundary wall- illegally and forcibly- but the defendant flatly
refused to do so- hence the cause of action has acrrued
7. That, the defendant is a permanent resident of District Patiala, the said boundary wall is
located within District Patiala, hence the Court has jurisdiction to try this suit.
8. That value of the suit for court fee is fixed and the applicable court fee has been affixed
with the plaint.
Prayer
It is therefore prayed
That a decree of permanent injunction for restraining the defendant from demolishing the
boundary wall (described in headnote) be passed in favour of the plaintiff along with the
litigation cost thereof along with any other remedy that is fit and proper.
Submitted by Plaintiff Through Council, at Patiala Dated ________
Verification
Verified that the contents of Para 1-5 are correct to the best of my knowledge and contents of
para 6-8 are true and correct based on my belief.
Suit No________ of 2020
IN THE MATTER OF:

Versus
List of Documents
1. Copy of the Site Plan

2. Copy of Application
3. Copy of resolution
4. Copy of legal notice and postal receipt
Submitted by Plaintiff through Council
Mandatory Injunction-
 Unlike permanent injunctions- mandatory injunctions are meant to force the defendant
to do something
Suit for Mandatory jurisdiction- Draft Begins after this
Suit No________ of 2020
IN THE MATTER OF:

Versus
Subash Garh, Son Of Mukesh Garg, resident of Defendants
Suit for Mandatory Injunction ordering the defendant to hand over vacant position of first
floor- House number XYZ, ABC Colony, Patiala and bounded as under-
North- Road
South- Road
East- House Number 17
West- House Number 19
Sir, it is respectfully submitted that
1. the plaintiff is a respectable and law abiding citizen

2. That, the defendant is the son of the plaintiff and the plaintiff has permitted the defendant
to reside in the 1st floor of House Number XYZ- fully described in the headnote above
with his wife and small daughter. The first floor of House No. 18 is shown in red colour
on site map. (Copy of Site map attached)
3. That, the defendant is not paying any rent to the plaintiff.
4. That, the plaintiff is an old man and has an unmarried who is getting married in the
month of June 2020 and hence the plaintiff needs the first floor of House Number 18,
Azad Nagar for his personal use.
5. That, the plaintiff filed an application with the welfare association of Azar Nagar, Patiala.
to make the defendant vacate the first floor of House Number 18- Azad Nagar, Patiala
and hand over vacant possession of it to the plaintiff. The welfare association passed a
resolution dated 20th January 2020 against the defendant. (Copy of application filed and
resolution is attached)
6. That, the plaintiff served the defendant with a legal notice dated 14/02/20 vide registered
post (copy of legal notice and postal stamp receipt is attached)
7. That, yesterday- 14/2/2020 the plaintiff requested the defendant along with some close
relatives to vacate and hand over vacant position of the house but the defendant refused
to do so. Hence, the cause of action has arisen.
8. That, the defendant is a permanent resident of district, Patiala- the disputed suit property
is situated within its jurisdiction of this Hon'ble Court- hence the court has jurisdiction to
try the suit.
9. That, the value of the suit for the purpose of court fees is fixed and the appropriate court
fees has been affixed on the plaintiff.
Prayer
It is therefore prayed that the decree for mandatory injunction ordering the defendant to vacate
and hand over the vacant property of House No. 18- Azad Nagar, Patiala fully described in the
headnote of the plaint be passed in favour of the plaintiff along with litigation cost thereof and in
the alternative any other appropriate remedy that the court may deem fit and proper be passed in
favour of the plaintiff.
Submitted by Plaintiff Through Council, at Patiala Dated

________
Verification
Verified that the contents of Para 1-6 are correct to the best of my knowledge and belief and
contents of para 7-9 are true and correct based on my belief.
Suit No________ of 2020

IN THE MATTER OF:

Versus
List of Documents-
1. Site Map
2. Copy of Complaint filed with the welfare association and the resolution of the welfare
association
3. Legal Notice and Postal Receipt
Suit for Specific Performance
Suit No________ of 2020
IN THE MATTER OF:

Versus
Suit for Specific Performance of Contract vide written agreement dated 2/11/2019 ordering
the defendant to get sale deed executed in favour of the plaintiff of plot number 18, Azad
Nagar, Sirhind Nagar and bounded as under
North- Road
East- House Number 17
South- Road
West- House Number 19
Sir, it is respectfully submitted as under
1. The plaintiff is a law abiding and respectable citizen

2. That, the plaintiff and defendant entered into a written agreement dated 2/11/2019 vide
which the defendant agreed to sell plot No 18, Azad Nagar Patiala fully described in the
headnote for the consideration of Rs. 10 Lakhs. (Copy of agreement dated 2/11/2019 and
site plan is attached)
3. That the platintiff paid to the defendant Rs. 1 Lakh as earnest money vide money draft
X4342970 dated and agreed to pay the balance amount of Rs. 9 Lakh at the time of
getting the sale of the said plot registered.
4. That. on 1/2/2020 the plaintiff went to the office of the registrar Patiala along with the
balance of Rs 9 Lakh along with bank draft deposit- dated 1/2/2020 and remained present
outside the office of the registrar Patiala and remained there from 10AM-5PM. (Copy of
bank draft is attached)
5. That on 1/2/2020 the plaintiff kept waiting the whole day from 10AM-5PM but the
defendant nor any authorized agent turned up at the office of the registrar Patiala to get
the sale deed executed. The plaintiff also got his presence marked by a duly sworn
affidavit dated 1/2/2020. (Copy of Affidavit is attached)
6. That, on 2/2/2020 the plaintiff served the defendant with a legal notice vide a registered
post (Copy of legal notice and postal receipt- 2/12/2020 is attached)
7. That, the plaintiff is ready and willing to perform his part of the contract but the
defendant is not ready and willing to perform his part of the contract and even after
receiving the legal notice the defendant is not willing to get the sale deed executed.
8. That, yesterday that is 14/2/2020 the plaintiff once again requested the defendant to get
the sale deed of the said plot executed in favour of the plaintiff after receiving the balance
amount of Rs. 9 lakh but the defendant flatly refused. Hence, the cause of action has
accrued.
9. That, the defendant is a permanent resident of district Patiala, the suit property is
registered in District Patiala, the earnest money was paid and received at Patiala- hence
the Hon'ble Court has jurisdiction to try the suit.
10. That, the value of the suit for the purposes of court fees is Rs. 1 Lakh (Not 10
Lakh !) and the appropriate court fees has been affixed in the plaint
Prayer
It is therefore prayed that the decree for specific performance of the contract, ordering the
defendant to get sale deed executed in favour of plaintiff with regard to sale of House No. 18,
Sirhind Road Patiala be passed in favour of the plaintiff along with litigation expenses and in the
alternative- any other appropriate relief that the court deems fit and proper be also passed in
favour of the plaintiff.
Suit No________ of 2020
IN THE MATTER OF:

Versus
List of Documents-
Suit for Declaration- Of Person not having been seen or heard of (Cross-check-Party names )
Suit No________ of 2020
IN THE MATTER OF:

Rakesh Lal S/O Mukesh Lal, resident of House Number 18 Azad Nagar Patiala
Plaintiffs
Versus
General Public
Defendants
Suit for Declaration that Rakesh Lal, son of Mohan Lal has not been seen or heard of by
anyone since 26/07/2012, when he left for a pilgrimage
Sir, It is respectfully submitted that
1. That, the plaintiff is a law abiding and respectable citizen.

2. Rakesh Lal S/O Mukesh Lal is the brother of the plaintiff and his lone legal heir since
father of Rakesh Lal- Mukesh Lal and another Sunita Rani have expired (copy of ration
card and death certificate is attached).
3. That, Rakesh Lal S/O Mukesh Lal from his childhood was of a religious bent of mind and
never got married and also had no children
4. That, on 26/07/2010- Rakesh Lal son of Mukesh Lal had left for Devprayag
(Uttarakhand) in connection with a pilgrimage, there at the Sangam of river Bhagirath
and Alaknanda- while taking a holy dip- Rakesh Lal was carried away by a strong current
of water.
5. That, plaintiff Mukesh Lal went in search of Rakesh Lal- thereafter the plaintiff went to
the police to file a missing complaint about Rakesh Lal, son of Mukesh Lal but the police
refused to entertain the plaintiff.
6. That, the plaintiff got a public notice printed on 30/07/2010- in The Tribune, Chandigarh
informing the general public (Copy of public notice printed in newspaper is attached)
7. That, ever since 20/7/2010 Rakesh Lal S/O Mukesh Lal, has not been seen or heard of by
anyone and the plaintiff is well conversant with the facts of the case and more than 7
years have lapsed since Rakesh Lal, son of Mukesh Lal went missing and hence, the
cause of action has accrued.
8. That, Rakesh Lal, S/O Mukesh Lal was a resident of District Patiala and has moveable
and immoveable property within the jurisdiction of this court and hence the court has
jurisdiction,
9. That, the value of the suit for the purpose of court fee is fixed and the appropriate court
fees has been affixed on the plaintiff.
Prayer
It is therefore prayed that a decree for declaration that Rakesh Lal son of Mukesh Lal has not
been seen or heard of since 26/07/10 be declared as civil dead, along with litigation expenses and
costs and in the alternate any appropriate relief, be also passed.
Verification
contents of para 7-9 are true and correct based on the information received.
Suit No________ of 2020
IN THE MATTER OF:

Versus
List of Documents-
1. Ration Card
2. Death Certificate
3. Copy of Public Notice Printed on
Draft of Suit for Possession by Way of Partition
In the Court of Civil Judge (Junior Division), Patiala
Suit No________ of 2020
IN THE MATTER OF: ( )

1. Paramjeet Singh S/O Narinder Singh R/O 110 Mohan Enclave, Mohali
Plaintiff
2. Gurpreet Singh S/O Narinder Singh R/O Gobind Colony, Rajpura
v.
1. Manjit Kaur W/O Harjeet Singh S/O Narinder Singh R/O 220 Rose Colony Patiala
2. Manpreet Singh S/O Harjeet Singh S/O Narinder Singh R/O 220 Rose Colony Patiala
3. Tegpreet Singh S/O Harjeet Singh S/O Narinder Singh R/O 220 Rose Colony Patiala
4. Ranjit Kaur D/O Narinder Singh R/O 22 Railway Colony, Ambala
Suit for Possession by way of partition that plaintiff has 1/4 share in House No. 220 Rose
Colony, Patiala measuring 250 Sq. Yards comprised of 3 Bedroom, 1 Dining Cum Drawing
Room, Kitchen, 2 Washroom, Bounded as Under-
North- Road
South- Road
East- House Number 219 Rose Colony Patiala
West- House Number 221 New Green Park Colony, Patiala
It is respectfully submitted as
1. That, the plaintiffs are law abiding and respectable citizens

2. That, the plaintiff and the defendants are the legal heirs of Narinder Singh
3. That Narinder Singh got a registered will prepared at 11/2/15 vide which he gave 1/4th
share to his 3 sons by which he gave 1/4 share to Paramjeet Singh, Gurjit and Gurpreet
and also wished that his wife Amar Kaur remain in possession of the suit property till her
death. Narinder Singh died on 5/3/15 and thereafter on 12/4/17-Amar Kaur also died
(death certificates are attached)
4. One son, Harjeet Singh also died on 5/06/19 leaving behind his widow- Manpreet and
Manheet Singh. Plaintiff were posted outside Patiala in connection with business and
defendant is married at Patiala.
5. That the suit property is jointly owned and the plaintiff have 1/4 share and no longer wish
to keep the suit property joined and wait to get their share in the suit property by way of
partition. That the plaintiffs requested D1, D2 and D3 to partition the suit property and
give them their share but of no avail.
6. That Ranjit Kaur has been made a proforma defendant since her interest is not averse to
that of the plaintiff.
7. The plaintiff served the defendants 1-3 with a legal notice dated 1/2/2020 vide a
registered post. (Copy of notice and postal recipt attached)
8. C- That the defendants despite having received the legal notice are not ready to give the
plaintiffs there share in the suit property. Plaintiff requested the defendants to give their
share on 23/12/20. Defendants flatly refused and hence the cause of action has accrued.
9. J- That the defendants reside at Patiala- the suit property is situated within the
jurisdiction of this court and hence the courts has jurisdiction to try this suit.
10. V- The value of this suit for court fee and jurisdiction is Rs. 25 Lakh and appropriate
court fee is affixed.
Prayer
It is therefore prayed that a decree for possession by way of partition and providing the plaintiff's
share of 1/4th share each in the suit property be passed in favour of the plaintiff along with
litigation expenses and costs thereof and in the alternative- any other appropriate relief that the
court deems fit and proper.
Verification- Verified by plaintiff at Patiala
Suit No________ of 2020
IN THE MATTER OF:

List of Documents
1. Death Certificate
2. Copy of Notice and Postal Receipt Dated 1/2/20
Decree for Restitution of Conjugal Rights-
Suit No________ of 2020
IN THE MATTER OF:

Petitioner- Ram Lal S/O Mukesh Lal- resident of
v.
Respondent- Sunita Rani W/O Ram Lal- resident of
Petition under Section 9- Hindu Marriage Act, 1955 for Restitution of Conjugal Rights
It is respectfully submitted that -
1. The petitioner is a law abiding and responsible citizen.

2. Respondent is the legally wedded wife of the petitioner and the marriage took place at
Kali Mata Mandir Mall Road, Patiala according to Hindu rites.
3. That, after the marriage the parties got the marriage registered with the registrar, Patiala.
(Copy of Marriage certificate is attached)
4. That, the status, age and place of residence of the petitioner and respondent at the time of
marriage and the time of the petition is given below-
5. That, the respondent gave birth to give dated at 20/10/19 at government- Rajendra
Hospital (Copy of birth certificate attached)
6. That, after the birth of the girl child the respondent started claiming that she would reside
with her parents till the child attained age of system.
7. That, the petitioner tried to pacify the respondent but to no avail and the petitioner also
sent mails to his father-in-law with respect to the matter (Printout of the emails is
attached,)
8. That, the respondent started dreading the petitioner started dreading the petitioner with
cruelty in order to enforce her demand to leave the matrimonial house along with the
child and her valuable and ever since is residing at her parental house.
9. That on 23/1/2020 the petitioner went to the parental house of the respondent with a
panchayat, consisting of relatives and respectable citizens following which a compromise
was reached between the parties. The respondent agreed to the compromise (Copy of the
compromise deed is attached)
10. That, on 1/2/20 the petitioner served the respondent with a legal notice (Copy of legal
notice and postal receipt attached)
11. That, the respondent after serving the legal notice- petitioner once again requested the
respondent to come back to the matrimonial house and reside with the petitioner and as
such the cause of
12. The respondent resides at Patiala, the parties last resided at Patiala, hence the Honourable
Court has jurisdiction.
13. Value of the suit for Court fee is fixed and the required court fees has been attached with
the plaint.
Prayer
1. It is therefore prayed that a decree for restitution of conjugal rights be passed ordering the
respondent to come and reside with the petitioner along with costs and litigation expenses
and in the alternative any other remedy that the court deems fit and proper.
Verification- Verified by plaintiff at Patiala
Suit No________ of 2020
IN THE MATTER OF:
List of Documents
1. Copy of Marriage certificate

2. Copy of birth certificate
3. Printout of the emails
4. Copy of legal notice and postal receipt
Civil Appeal from an order of the decision of Civil Judge Senior Division- Module 1
In the Court of District Judge, Patiala Under Civil Appellate Jurisdiction
Appeal from Civil Suit No 32 of 2019 from the Court of Shri Rahul Garg PCS (Civil Judge-
Senior Division), Patiala
Ram Lal S/O Sohan Lal, Resident of ........
Appellant-
v
Son of Mukesh Lal, Residents of......-
Respondent
Appeal against judgment and decree dated 27/1/20 passed by Shri Rahul Garg in Civil Suit No
____
Sir, the appellant above named submits as
1. That, the respondent filed a suit for recovering of Rs. 15000 vide a promissary note dated
6/06/1. (Exhibit P1)
2. That, the civil judge Patiala passed a judgment and decree for RS 20000 against the
appellant.
3. That, there has been a grave miscarriage of justice- being aggrieved by the judgment and
decree date 27/1/20 the appellant files an appeal under the grounds given below.
1. That, the promissory note exhibits P-1 is a forged document and hence illegal and
not enforceable No consideration was passed by the respondent/plaintiff as
alleged Hence, the promissary note is illegal.
2. That, the respondent/plaintiff has failed to prove the promissary note P-1 as per
the provisions of law and the respondent has failed to prove his case to the hult.
3. That the appellant, had filed an application requesting the court to summon the
handwriting expert- 20/12/19- Civil Judge, Senior Division dismissed the
application without giving any reason.
4. That, there are glaring descriptions in the stalemate of the respondents PW-1, PW-
2.
5. That, the judgment and decree dated 27/1/2020 is based on conjecture and
surmises and unwarranted by the facts, law and procedure.
6. That, the decree dated 27/1/20 is against the principles of justice/equality and
good conscience.
4. L- That the present appeal is being filed within the period of Limitation after excluding
the time period spent in obtaining the certified copy of the judgment/decree.
5. That, the appellant has not filed any other appeal except the present appeal
Prayer
It is therefore prayed
1. That the records of civil suit No 132/2018 be sent for the judgment/decree dated 27/1/20
is set aside.
2. That, the respondent be stayed from filing execution against the person/property of the
appellant.
3. That, the respondents be ordered to pay costs and litigation expenses to the appellant and
any other remedy that the court deems fit and proper
Verified/Signed
Appellant
Civil Revision Petition- Module 1- Last Topic
In the High Court of Punjab and Haryana, Chandigarh

Civil Revision No ____
SANT RAM S//O RAMLAL, R/O 18 NEW COLONY,RAILWAY ROAD, PATIALA
Petitioner
v.
Respondent
The petitioner above named respectfully begs to file the present revision in the Honourable High
Court of Punjab and Haryana with judicature at Chandigarh against order dated 27/1/20 in Civil
Suit ____/2018 from Court of Shri Rahul Garg PCS (Civil Judge- Senior Division, Patiala)
1. That, the petitioner had filed a civil suit- No ____/18 for the eviction of the
respondent/tenant in the Court of Civil Judge Senior Division, Patiala.
2. That the petitioner filed the said civil suit for the eviction of the tenant on the following 2
grounds
1. For non-payment of rent
2. For personal necessity and requirement.
3. That in the suit the petitioner filed an application under O.6. R.17 Code of Civil
Procedure, 1908 for the amendment of the plaint. Exhibit 15 dated 6/07/2019 have
requested for the following 2 grounds to be ordered.
1. That the respondent has raised a permanent structure on the property without
obtaining permission from the petitioner and thereby impaired the value and itlity
of the premises.
2. That, the respondent is creating nuisance for the petitioner and other residents.
4. That the Honourable, Civil Judge- Senior Division dismissed the application vide order
dated 27/1/20 holding that the amendment was not requreed for arriving at the real cause
of controversy between the parties.
1. That the amendment petition was filed at a belated stage.
2. That the amendment if allowed would change the nature of the proceedings
3. That, the amendment if allowed would cause irreparable loss.
5. That, being aggrieved by the order dated 27/01/20- the petitioner is filing the revision
petition on the following grounds.
1. That the order dated 27/01/20 by the Civil Judge- Senior Divison, Patiala is
unwarranted and based on summises
2. That, the civil judge Senior Division, Patiala has made an error by holding that the
amendment is not required for arriving at the real dispute between the parties.
However, the fact is that the proposed amendment goes into the root of the civil
suit and cannot be ignored.
3. That, the Hon'ble Civil Judge, Patiala has made an error by holding that the
amendment was filed at a later stage. The fact is that the proposed amendment
accrued only after the filing of the suit.
4. That, the Hon'be Civil Judge, Patiala has made an error by holding that the
proposed amendment is likely to change the nature of the proceedings. The fact is
that the relief arriving out of the proposed amendment is eviction of the tenant.
And the petitioner has also filed a suit for eviction of the tenant. Hence, the
procedure is not going to change.
6. That, the Civil Judge Senior Division has made an error in holding that the prejudice will
be caused if the amendment is allowed. The fact is that no prejudice will be caused and
rather the order will check multiplicity of proceedings.
That, the order dated 27/11/2020 is against the principle of justice, equity and good conscience.
That, the petitioner has not filed any revision petition prior to the present petition.
Prayer
It is humbly prayed before the Hon'ble Court that
1. That the records of suit number ____ of 2018 be sent to the Court of Civil Judge, Patiala.
2. Further, proceedings in the suit be stayed and the order dated 27/1/2020 be set aside and
in the alternative any other appropriate remedy.
Signed- Council for appellant
Theoretical Portion- Module 1-
WRITTEN STATEMENT: MEANING:
The term written statement has not been defined under the code. It is a pleading of the defendant.
It is a document on basis of the defense , pleas or counter claim is made to which the suit is
instituted its object is to state the grounds upon which the plaintiff can’t get relief from the court
Particulars: Every written statement contains the following particulars:
1. The name of the court where the suit is filed and the suit number of the suit.
2. The name description and residence of the plaintiff and defendant.
3. Where the plaintiff or defendant is a minor or of unsound mind a statement to this
effect.
4. Where there is one defendant then the written statement is to be addressed as written
statement on behalf of defendant No. 1. But if there are more than one defendant then
the written statement should be specific to mention that it is written statement of say
defendant no 3 and 4 or on behalf of defendant 1 and 2.
5. The defendant should take all possible defenses in the written statement. If the
defendant fails to take a particular defense in the written statement then he is not
allowed to take the defense later on unless the written statement is amended.
6. The written statement should be drafted in the same manner by taking each and every
Para of the plaint. Each fact mentioned in the plaint should be singled out and it should
be either admitted or denied by the defendant.
7. The defendant should not say anything about the relief as claimed by the plaintiff
except that the suit of the plaintiff should be dismissed. There is no need to deny the
relief claimed specifically.
8. If there are some legal defenses to be taken by the defendant for example; limitation,
jurisdiction, Res Judicata, then divide the written statement in to two parts . The first
part about the legal defense should be titled; Preliminary Objections and the second
part should be titled On Merits.
9. The Dilatory pleas should be taken. For this divide the written statement inot three
oarts and title it as ; ‘Additional pleas. ’These pleas delay the suit and are for the
benefit of the defendant. Dilatory pleas include objection to Non Joinder of parties or
not filing the suit on behalf of a minor though a guardian etc. The detail should be
given. For example if there is objection to non joinder then it is not sufficient to
mention that ‘the suit is bad for non joinder ‘ but it should be mentioned that as such
and such person was not included therefore the suit is bad for non joinder .
Compensatory costs under section 35A CPC can be pleaded also
10. The prayer clause at the foot giving details about the relief claimed should be denied
alleging that the suit merits dismissal.
11. Each written statement should be verified and signed by the plaintiff .The verification
is made on basis of knowledge and also on behalf of information got and believed to
be true. Where there is more than one defendant filing the written statement jointly
then all of them should sign it or at least one of them should sign the verification.
12.

PROVISIONS RELATING TO SET OFF:
Set off means a claim set up against another. It is a counter claim and it partly sets off the
original claim. Doctrine of SET OFF; when a plaintiff files a suit for recovery of some amount
and the defendant finds that he also has a claim to settle then this is called set off. Thus it is a
reciprocal claim of debt. In this way the defendant is saved from filing a new suit.
EXAMPLE: A is a manufacturer of biscuits. B is the dealer of his products .A keeps on

supplying goods to B on credit and B keeps on paying for them. After sometime B also starts
some manufacturing of goods. Now A takes the supply of his goods. Later on there is a dispute
between A and B and A files a suit for recovery. Here B also has to recover some amount from A
so he can file a set off in the same suit.
CONDITIONS: A defendant can file a set off but the following conditions apply:
1. The suit must be for recovery of money.
2. The sum of money must be ascertained.
3. The money must be recoverable legally by the defendant and if there is more than one
defendant than by all of them.
4. It must be recoverable from the plaintiff and if there is more than one plaintiff then from
all of them.
5. The set off must not exceed the pecuniary jurisdiction of the court where it is filed.
EFFECT: When a suit is filed by the plaintiff and the defendant claims a set off then there are
two suits going on at the same time. The set off is not given a suit number. But if the suit of the
plaintiff is dismissed in default or he with draws it then this has no effect on the claim or set off.
The defendant has to prove his claim. If the defendant is able to prove his case then it may be
decreed against the plaintiff.
EQUITABLE SET OFF: Under rule 6 set off is called legal set off. It is connected to a
ascertained amount of money. However if the amount of money is not ascertained then the
defendant may also claim a set off this called equitable set off. This dealt under order 29 rule
19[3] of the code.
FOR EXAMPLE:
1. A sues B for recovery of Rs. 50,000. Thus filed under a contract. Now B can file an
equitable set off because A has caused a breach of contract.
2. A files a suit against his master for getting his salary. Now the master can file asset off for
the negligence of duty by the servant.
3. A is a washer man who files a suit for wages against B. Here B may file a set off for the
loss of clothes by A.
LEGAL AND EQUITABLE SET OFF:

1. Legal set off is for ascertained amount of money but equitable set off can be for un
ascertained sum of money.
2. Legal set off is a legal right and the court has to adjudicate upon it where as equitable
set off is not a legal right and the court has discretion to adjudicate on it.
3. In a legal set off it is not necessary that the cross demands arise out of the same
transaction where as in equitable set off it is necessary that the demands arise out of the
same transaction.
4. In a legal set off the claim is passed only if there is a legal right and it is not time
barred, But in a equitable set off the claim may be allowed even if time barred but there
has to be a fiduciary relation between the parties.
5. A legal set requires a court fee bit there is no need of court fee in case of equitable set
off.

More Drafts- From Module 1- As copy/pasted from the emailed material
WRITTEN STATEMENT IN A SUIT FOR RECOVERY- Module 1

IN THE COURT OF --------------------------JUDGE [JR. DIVISION] PATIALA.
Civil Suit no------ of
2020
1. SANT RAM S//O RAMLAL, R/O 18 NEW COLONY,RAILWAY ROAD,

PATIALA -
-----PLAINTIFF.

VERSUS
1. MOHAN SOOD S/O MANOHAR LAL, R/O 22, Indra NAGAR, Ambala .
----------
DEFENDANT,
Suit for Recovery of Rs. 10,000, paid to defendant by the plaintiff
vide a Pro note dated ---- along with interest @ 12 P.A.
WRITTEN STATEMENT ON BEHALF OF DEFENDANT

Sir, It is submitted as:
Preliminary objection;
1. That the suit is barred on grounds of limitation. The suit is not with limitation and hence
merits dismissal.
2.That the Hon’ble court has no jurisdiction to try the suit as the alleged pro note has been
executed in District Ambala as is evident on perusal of the alleged pro note and the defendant
is also a permanent resident of District Ambala .
ON MERITS;
3.That Para no 1 of the plaint is wrong and vehemently denied .The plaintiff never paid Rs.
10,000 to the defendant vide a Pro Note date ---payable along with interest @12P.A as alleged
.The pro note has been thumb marked where as the defendant is an educated and employed
respectable citizen.
4. That Para no 2 of the plaint is wrong and vehemently denied the defendant never executed a
receipt in acknowledgment of having received the amount and promised to pay it back on
demand as alleged .
5. That Para no 3 of the plaint is wrong and vehemently denied the plaintiff never requested the
defendant to pay back the amount along with interest. The plaintiff did not serve the Defendant
with a legal notice dated ---- as alleged.
6. That Para no 4 of the plaint is wrong and vehemently denied. There is no cause of action and
the suit is not within limitation.
7. That para no 5 is legal and hence needs no reply.
8. That Para no 6 of the plaint is wrong and vehemently denied the defendant does not reside at
Patiala, the Pro note was not executed at Patiala and the payment was not made and received
thus the Hon’ble court has no jurisdiction to try the suit.
ADDITIONAL PLEAS;
9. That the suit of the plaintiff is false and frivolous and merits dismissal and the defendant is
entitled to compensatory costs under section 35 [A] CPC.

It is therefore prayed that the suit of the plaintiff be dismissed with costs and any other
appropriate relief that the court deems fit and proper be also granted in favour of the defendant
and against the plaintiff.

VERIFICATION; Verified at Patiala on this 12th day of May
SUBMITTED BY
that facts mentioned in the paras no 3 to 8 are true to the best Plaintiff.
of my knowledge and belief and the facts in the remaining Through counsel.
paras are true on basis of information received and believed true.

Application for Permission to Sue as Indigent Person- Draft - Module III


Suit no -------of 2020
PATAILA
-
-----PLAINTIFF.
VERSUS
1. MOHAN SOOD S/O MANOHAR LAL, R/O 22, AZAD NAGAR, PATIALA.
----------
DEFENDANT,
APPLICATION FOR PERMISSION TO SUE AS INDIGENT PERSON. [Under Order 33 read

with section 151 CPC]
Sir , It is submitted as:
1. That the above titled case is being filed in the Hon’ble Court.
2. That defendant entered into an agreement with the plaintiff/ applicant for sale of Plot
no 209 Azad Nagar for Rs 10,00000[ Ten Lakhs] and the applicant paid Rs 200000
earnest money. The balance of Rs 800000 was to be paid at the time if getting the sale
deed registered [Copy of agreement is attached].
3. That the defendant has sold the said plot to another person and as such has made a
breach of the contract.
4. That the plaintiff/ applicant suffered a heavy loss in his business and now has become
an indigent. He has got no property even worth Rs 1000 apart from his wearing apparel
and utensils.
5. That the applicant is unable to pay the court fee for the purpose of filing the suit.
6. That it is in the interest of justice that the applicant be allowed to sue as an indigent
person without the payment of court fee.
7. That an affidavit in support of this petition is also annexed to this petition
8. That the cause of action accrued on 23-2-20202 when the defendant sold the [lot to
another person and again when the defendant flatly refused to pay back the earnest
money to the applicant.
9. That the Hon’ble court has jurisdiction to try this suit since the defendant is a
permanent resident of District Patiala and the agreement was entered at Patiala the
earnest money was paid and received at Patiala.
It is therefore prayed that the applicant be allowed to sue as an indigent person without the
payment of court fee.
Submitted by Applicant Through Councel
Verification;
Verified at Patiala on this 5th day of March 2020 that facts mentioned in the above are true and
correct to the best of my knowledge and belief
(Please Note; Although this is an application but still it is to be verified in the same manner we
verify a Plaint under Order 6 Rule 14, 15 CPC.)
Suit for Possession

IN THE COURT OF CIVIL JUDGE [JR. DIVISION] PATIALA.
Suit No -----of
2020
1. SANT RAM S//O RAM LAL, R/O 18 NEW COLONY,RAILWAY ROAD,
PATAILA -
-----PLAINTIFF.
VERSUS
----------
DEFENDANT
SUIT FOR POSSESSION.
APPLICATION FOR Dismissal OF SUIT U/S 11 C.P.C
1. That the above titled case has been filed in the Hon’ble Court and is fixed for today that is 23-
3-2020 .
2. That the plaintiff has already filed suit in the court of Sh. M.S Gupta Civil Judge Patiala and
suit no is 4321 of 2007 for possession of House No 3452 Railway Colony Patiala on grounds of
title. However that suit was dismissed by the Hon’ble court.
3. That after the dismissal of the said suit no appeal was preferred by the plaintiff. A copy of the
judgment is attached herewith.
4. That that present suit has been filed by the plaintiff on grounds of adverse possession.
5.That the subsequent suit is liable to be stayed under section 11 CPC as it is between the same
parties with the same title and the ground of attack of adverse possession was not taken by the
plaintiff in the former suit and it ought to have been taken and the Rule of Constructive Res
Judicata is applicable .
6. That an affidavit in support of this application is also annexed to this application
7That it is the interest of justice that the above titled suit be stayed.

It is therefore prayed that the application be accepted and the present suit be dismissed.
date;----------- SUBMITTED
BY
Applicant
Through counsel

APPLICATION FOR APPOINTMENT OF A GUARDIAN- Draft- Module III-

Suit no------of 2020
SANT RAM S//O RAMLAL, R/O 18 NEW COLONY,RAILWAY ROAD, PATAILA
-----PLAINTIFF.
VERSUS
MOHAN SOOD S/O MANOHAR LAL, R/O 22, AZAD NAGAR, PATIALA.
---------- DEFENDANT,
SUIT FOR POSSESSION
APPLICATION FOR APPOINTMENT OF A GUARDIAN.
Sir , It is submitted as:
1. That the above titled case is pending in the Hon’ble Court and fixed for 2-7-2020.
2. That in the above titled the Hon’ble court had allowed the amendment of the plaint and the
name of Roshan Lal was added.
3. That the said Roshan Lal is a minor and a school going kid.[ Copy of birth certificate is
attached ]
4. That it is in the interest of justice that a guardian be appointed to conduct the case in the
court on behalf of the applicant as the interest of a minor is involved .
5. That the application is being filed without any delay.
6. That an affidavit is also attached in support of this application

It is therefore prayed that a guardian be appointed to conduct the case in the court on behalf of
the applicant.

SUBMITTED BY Applicant- Through counsel.

Suit for Permanent Injunction- Stay of Suit Under Section 10 CPC- Draft

Suit no -----of 2020
1.SANT RAM S//O RAMLAL, R/O 18 NEW COLONY,RAILWAY ROAD, PATAILA
------PLAINTIFF.
VERSUS
1.MOHAN SOOD S/O MANOHAR LAL, R/O 22, AZAD NAGAR, PATIALA.
---------- DEFENDANT,
SUIT FOR PERMANENT INJUCTION
APPLICATION FOR STAY OF SUIT U/S 10 C.P.C
1. That the above titled case has been filed in the Hon’ble Court and is fixed for today that
is 23-3-2020.
2. That the Plaintiff has filed the present suit in the Hon’ble court for permanent
Injunction restraining the defendant /applicant from forcibly and illegally dispossessing the
plaintiff from the house No 234 Railway Colony Patiala.
3. That a similar suit is pending in the Court of Sh. M.S Gupta Civil Judge Patiala and suit
no is 4321 of 2009 and the next date in the said suit is 23-9-20 and it is also for Permanent
Injunction restraining the defendant /applicant from forcibly and illegally dispossessing the
plaintiff from the house No 234 Railway Colony Patiala. However the plaintiff has not been able
to get Temporary injunction in that suit.
4. That the plaintiff instead of filing an appeal against the order has preferred to file the
present suit[ Copy of order dismissing application under order 39Rue 1,2 CPC is attached].
5. That as the both suits are between the same parties, for the same cause of action and relief
and as such under section 10 CPC the present suit is liable to be stayed.
6. That an affidavit in support of this application is attached herewith.
Prayer

It is therefore prayed that the application be accepted and the present suit be stayed.

Date;
SUBMITTED BY Applicant Through counsel.
Suit for Permanent Injunction- (Application for appointing a local commissioner to inspect
the existing state of affairs)

Suit no -----of 2020

PATAILA
------
PLAINTIFF.
VERSUS
----------
DEFENDANT,
SUIT FOR PERMANENT INJUNCTION
Application for appointing a local commissioner to inspect the existing state of affairs

Sir it is submitted as;
1. That the plaintiff applicant has filed this suit for permanent injunction in the Hon’ble
court and it is fixed for today that is 23-3-20.
2. That the applicant is possession of the suit property but the defendant has asserted that he
is in possession of the suit property.
3. That both parties are asserting to be in possession of the suit property and it is difficult
for the court to find the truth unless the suit property is visited and the existing state of affairs are
not ascertained.
4. That it is in the interest of justice that a local commissioner be appointed to visit the suit
property to assess the existing state of affairs and submit a report in the Hon’ble court
5. That the applicant is ready and willing to pay the fee for the local commissioner
Prayer

It is therefore prayed that a local commissioner be appointed to visit the suit property to inspect
the existing state of affairs and to submit s report in the Hon’ble Court

Date; SUBMITTED
BY
Applicant
Through counsel.
Module 1- Copy Pasted Drafts- End-

Module II-
Criminal Complaint- Draft-
(Complaints are filed with the Judicial Magistrate regardless of which court has trial
jurisdiction
Section 302 IPC- Complaint Draft Begins-

In the Court of Judicial Magistrate First Class, Patiala
Criminal Complaint ______ 2020
1. Bimla Devi Widow of Sant Ram R/o 18 Azad Nagar Patiala- Complaint
v.
1. Mohan Sood S/O Sohan Sood Resident of 113 Rose Colony, Patiala- Accused
Date of Occurrence
Time of Occurrence
Complaint Under Section 302 IPC
Sir, it is submitted as-
1. That, the Complainant is widow of deceased Sant Ram Son of Ram Lal and a Law
abiding and respectable citizen
2. That, there is civil litigation between deceased Sant Ram and Accused Mohan Suri
regarding a house built on Plot No. 110 New Colony, Railway Road, Patiala in the Court of Civil
Judge- Senior Division Patiala- Civil Suit No 325 of 2018. The next date in the said civil suit is
29/5/20. Copy of Plaint filed by Sant Ram is attached herewith.
3. that, on 24/1/20 the accused committed a breach of peace in the court complex-Patiala
and threatened the deceased Sant ram with dire Consequences. Consequently, a FIR No. 250
dated 24/1/20 was filed under Section 107/151 CrPC for committed breach of Peace. The
accused was arrested and released on bail. The next date in the case is 20-5-20. Copy of FIR No.
250 Attached.
4. That, on Sunday that is 12-4-20 at about 10AM the accused visited the
complainant/deceased on the pretext of compromising the civil dispute. When the complainant
came out of her house the accused asked about the deceased and the complainant called out her
husband. When the deceased came out of the house the accused toook out a pistol and fired two
bullets from the pistol and ran away from the spot. The incident took place in the presence of
Atma Ram and Vinod Gupta- who are respectable citizens of the locality and were passing by the
area of the incident. Site plan is attached herewith.
5. That, Atma Ram and Vinod Gupta chased the accused who got out of the Car PB- 11-AU
2013 and sped away. Thereafter the complainant-Atma Ram and Vinod Gupta. However, the
doctors declared Atma Ram brought dead. On the next day 13/4/20 the dead body of the
deceased Sant Ram was handed over to the complainant after the post-mortem. The complainant
and other relatives consigned the body of Sant Ram to the flames. Copy of MLR and Post-
Mortem report is attached.
6. That, after completing the last rites of Sant Ram, the complainant along with some
respectable members of society went to the police station for filing a FIR against the accused.
However, the police refused to entertain the FIR alleging that there was a delay. Hence, this
complaint is being filed and the reasons for delay have been explained.
7. That, the accused committed the offence at Patiala and hence the Honourable court has
jurisdiction to try the case. It is therefore, prayed that the accused be summoned, tried and
punished for the offences committed.
List of Witnesses Submitted By Through Counsel
1. Bimla Devi, Widow of Ram .Ram, Resident

2. Atma Ram, Son of Mukesh Ram
3. Vinod Gupta Son of Suresh Gupta
4. Doctor Government Hospital Patiala who conducted medical examination and post-
mortem of deceased in Patiala
5. Draughtsmen Sohan Singh Civil Court Complex Patiala
Documents Attached-
1. Copy of FIR dated 24/1/20

2. Attested of Plaint, in civil suit- 2018
3. Site Plan
4. Copy of MLR
5. Copy of Post Mortem Report
Bail Application under Section 167(2) CrPC - Module II
Sessions Court- Ordinarily, The bail must be filed in whichever court has jurisdiction over the
trial- this is in contrast to the situation for complaint
But under 167(2) the bail application in a Murder/Rape Case be filed before the Magistrate
Under 167(2)- Once a period of 60/90 days (depending of Severity of Offence) post the
accused being remanded to police custory then he has a right to file a bail application under
Section 167(2) - Draft Starts after this point

Criminal Case No/425
FIR No. 425
Date- 15/12/19
Police Station
State of Punjab-
Prosecution
Versus
Sohan Lal S/O Mohan Lal R/o 18 Azad Nagar Patiala
Case Headnote- Section 376 IPC
Application for Enlarging Accused on Bail
Sir.
It is submitted as:-
1. That the above title case is pending in the Hon'ble court and fixed for today, that is 15th
May, 2020
2. That, the accused was falsely implicated in the above titled case and a FIR was lodged
No. 425 dated 15/2/19. The Accused was presented in front of the Hon'ble Court on 16/12/19.
3. That, the accused was first remanded to police custody for 10 Days and then on 26/12/19-
he was sent to judicial lockup and ever since that day he has been in judicial lockup.
4. That, the accused have not completed the investigation and filed the police report as per
provisions of law till date and are seeking adjournment.
5. That, since more than 90 days have lapsed and the investigated is still not complete the
accused is entitled to bail under Section 167(2) CrPC.
6. That, the accused is a permanent resident of district Patiala and has deep roots in the
society and it is unlikely that he will escape the hands of law if revealed on bail.
7. That, the accused has urban and rural property in district Patiala- Copy of sale deed of
House Number 18, Azad Nagar Patiala and Farad Jamabandi (2018-19 is attached0
8. Bail is a rule and its refusal an exception.
It is therefore prayed that the accused be released on bail as per provisions of Section 167(7)
CrPC.
List of Documents Submitted by Accused through counsel
1. Copy of FIR dated 15/12/19

2. Copy of Sale deed of House Number 18 Patiala
Complaint Under Section 420 IPC- Draft
If a cheque is dishonoured due to insufficient funds- then the complaint is under NI Act. But if
the issuer already knew that the cheque was going to bounce (he intentionally gave a cheque
which was going to bounce) then it will be dealt with under Section 420- CrPC-
In the Court of Judicial Magistrate, Patiala

Criminal Complaint
Police Station _______
SANT RAM S//O RAMLAL, R/O 18 NEW COLONY,RAILWAY ROAD, PATIALA-
Proprieter of Fresh Products 132 AC Market, Patiala- Complainant
versus
MOHAN SOOD S/O MANOHAR LAL, R/O 22, Indra NAGAR, Ambala- Proprietor New 12,
Grain Market Patiala
Date of Occurence
Time of Occurence
Complaint under Section 420 IPC, Sir it is respectfully submitted as
1. The complainant is a law abiding and respectable citizen and a wholesale dealer in bread,
biscuits and confectionary. The complainant is running his shop and business under the name
and style- Fresh Products, 132 AC Market Patiala,
2. That, the accused is a shopkeeper running a shop in the name and business-new friend
product situated at 12 Grain Market Patiala.
3. That on 2/4/2020 the accused visited the shop of the complainant and placed an order for
biscuits, bread and confectionary for Rs. 23000. Vide receipt number 2356 dated 2/4/20. The
accused issued a cheque No ML 024356 dated 2420 for the said amount payable at SBI Grain
market branch Patiala.
4. That, the complainant ordered his salesman Ramesh KUmar to devlier the goods to the
accused. Delivery Receipt No. 5643 dated 2/4/20 is attached.
5. That, the complainant sent the said cheque to the banker for encashment to the account of
the complainant, however the banker returned the cheque as dishonoured vide memo dated
7/2/20- copy of memo is attached
6. That, the complainant made inquiries from the banker and was informed that the accused
had closed the account only the day before issuing the cheque that is 1/4/20.
7. That, the accused issued a cheque to the complainant with full knowledge that he no
account with the bankers and dishonestly made the complainant deliver the goods.
8. That, the complainant went to the police station to get a FIR lodged. That, the accused
has committed the offence under Section 420 at Patiala witin jurisdiction of this Hon'ble Court
and the Hon'ble court has jurisdiction to try the complainant.
It is therefore prayed that the accused be tried and punished under aforesaid sections.
List of Witnesses `
Submitted By Sant Ram Through Counsel
1. Sant Ram- Complainant

2. Salesman- Ramesh Kumar
3. Clerk- SBI Grain Market Along with -
List of Documents-
1. Copy of Order Dated 2/4/20 receipt 2356

2. Cheque No- ML 024356 dated 2/4/20
3. Delivery Receipt No. 5643 dated 2/4/20
4. Copy of Memo issued by SBI- Grain Market Branch Patiala.
Section 107- Breach of Peace- Draft
Section 107/151 are used by the police to produce the parties before the Executive Magistrate-
The case will go on for 6 months-after which the executive magistrate can ask the two parties to
not indulge in any breach of peace and make them sign bonds to that effect. This is a preventive
remedy not punitive.
In the Court of Executive Magistrate

Criminal Complaint
Police Station

PATIALA - -
Complainant
2. MOHAN SOOD S/O MANOHAR LAL, R/O 19, Azad Nagar, Patiala - Accused
Date of Occurence-
Time of Occurence-
Complaint Under Section 107 CrPC
Sir, it is submitted as:
1. That, the complainant is a law abiding and respectable citizen.

2. That, the complaint and the accused are neighbours for the last 25 years, a common
boundary wall exists between the houses of the complainant and the accused. The accused for the
last 3 months has been trying to demolish the common boundary. (Copy of Site Plan attached)
3. That, on 14/3/20 the complainant filed an application with the welfare committee of the
colony which passed a resolution against the accused restraining him from demolishing the said
wall. Copy of the resolution dated 14/3/20 is attached.
4. That, the complainant filed a civil suit for permanent injunction against the respondent-
Suit No. 234 of 2020 and the Hon'ble court passed an interim injunction order against the
respondent and now the case is fixed for 24/7/20. Copy of Said order is attached.
5. That, yesterday at about 10 PM the respondent came to the house of the complainant on
the pretext of compromising the matter, when the accused came out of his house the accused
started abusing the complainant and asked the complainant to withdraw the. He threatened the
complainant with dire consequences with dire consequences if the suit was not withdrawn. He
threatened to kill the accused. This incident took place i n the presence of Atma Ram and Vinod
Gupta who were passing by the house of the complainant and they intervened and asked the
respondent not to create a breach of peace.
6. That, there is every likelihood of a breach of taking place and the life of the complainant
is in danger.
7. That, in the interest of justice the respondent should be ordered to execute bonds for
maintaining peace and order.
Prayer
It is therefore prayed that the respondent be summoned and ordered to execute bonds for the
maintenance of peace and order.
List of Witnesses Submitted by Complainant
through Counsel
1. Sant Ram
2. Atma Rap- R/O 20 Azad Nagar Patiala
3. Vinod Gupta- R/O 24 Azad Nagar Patiala.
List of Documents-
1. Copy of Resolution dated 14/3/20

2. Copy of Order of Injunction passed by Civil Court

Criminal Complaint
Police Station

PATIALA - -
Complainant
Date of Occurence-
Time of Occurence-

2. That, the complaint and the accused are neighbours for the last 25 years, a common
boundary wall exists between the houses of the complainant and the accused. The accused for the
last 3 months has been trying to demolish the common boundary. (Copy of Site Plan attached)
3. That, on 14/3/20 the complainant filed an application with the welfare committee of the
colony which passed a resolution against the accused restraining him from demolishing the said
wall. (Copy of the resolution dated 14/3/20 is attached.)
4. That, the complainant filed a civil suit for permanent injunction against the respondent-
Suit No. 234 of 2020 and the Hon'ble court passed an interim injunction order against the
respondent and now the case is fixed for 24/7/20. Copy of Said order is attached.
5. That, yesterday at about 10 PM the respondent came to the house of the complainant on
the pretext of compromising the matter, when the accused came out of his house the accused
started abusing the complainant and asked the complainant to withdraw the. He threatened the
complainant with dire consequences with dire consequences if the suit was not withdrawn. He
threatened to kill the accused. This incident took place in the presence of Atma Ram and Vinod
Gupta who were passing by the house of the complainant and they intervened and asked the
respondent not to take the law in his hands.
6. That, the complainant along with Atma Ram and Vinod Gupta went to the police station
to file the FIR but the police refused to entertain the complainant hence the complaint.
7. That, the offence was committed at Patiala, hence the Hon'ble Court has jurisdiction.
8. That, in the interest of justice the respondent should be ordered to execute bonds for
maintaining peace and order.
Prayer
It is therefore prayed that the respondent be summoned, tried and punished for the offence.
List of Witnesses Submitted by Complainant
through Counsel
1. Sant Ram
2. Atma Rap- R/O 20 Azad Nagar Patiala
3. Vinod Gupta- R/O 24 Azad Nagar Patiala.
List of Documents-

2. Copy of Order of Injunction passed by Civil Court
Draft Petition Under Section 125 CrPC- Maintenance Allowance
In the Court of Judicial Magistrate Patiala,

Criminal Complaint
1. Sunita Rani W/O Mohan Sood, R/O 22 Railway Colony, Railway Road, Patiala.
2. Chinki Sood D/O Mohan Sood R/O 22 Railway Colony, Railway Road, Patiala Through
her Mother and natural guardian Sunita Rani.
Petitioner/Applicant/Complainant
v.
1. Mohan Sood S/O Rakesh Kumar Resident Of 18 Azad Nagar Patiala.

Respondent
Petition Under Section 125, CrPC
1. That, the applicant is legally wedded wife of the respondent. The marriage of the
applicant and the respondent took place in the month of July 2016 at Patiala according to Hindu
marriage rites.
2. That, the parties got the marriage registered according to the provisions of law (Copy of
Marriage Certificate is attached)
3. That, after the marriage the applicant and respondent lived as husband and wife and a
daughter was born out of the wedlock on 21/3/2018. (Copy of Birth Certificate is Attached).
4. That, after the birth of daughter the respondent started maltreating the applicant and
treating her with cruelty because the respondent wanted a son to be born.
5. That, in the month of November 2019 the respondent took the complainants to the
parental house of complainant No. 1 and promised to tak them back after a week.
6. That, after a week when complainant tried to contact the respondent on mpobile phone
the respondent did not pick up the phone. The parents of Complainant No 1. went to the house to
inquire about the matter. But the respondent refused to take back the complainant to the
matrimonial house.
7. That, the respondent withdrew from the society of the complainants without any just and
reasonable cause and refused to pay mainteanance. So the complainant 1 and Complainanant no.
2 are forced to stay in the parent house as the complainant have no source of income.
8. That, the respondent is working in the State Power Corporation Limited Head Office
Patiala at a post of Clerk and is drawing a salary of Rs. 40000 per month. (Copy of Salary Slip is
Attached) '
9. That, the complainants are unable to maintain themselves as they have no source of
income and Complainant No. 1 needs maintenance allowance of 10000 and complainant needs
Rs. 5000-total Rs. 15000 per month.
10. That, the complainant requested the respondent to pay the maintenance of Rs. 15000
many times but the respondent has refused to do so, hence this complaint.
11. That, the marriage of the parties took place in Patiala, the parties resided together as
husband and wife in Patiala and the respondent is also living and working for gains in Patiala.
Hence, the Hon'ble Court has jurisdictions to try this complaint.
Prayer-
It is therefore prayed that the respondent be ordered to pay Rs. 10000 per month to Complianant
No and Rs. 5000 per month to Complainant No. 2 from the month of November 2019.
List of Witnesses-
Submitted by Complainant Through Counsel
1. Complainant
2. Ram Lal S/O Mohan Lal R/O _____
List of Documents-
1. Copy of the Marriage Certificate

2. Copy of the Birth Certificate of Complainant 2
3. Salary Slip of Respondent
Draft- Petition- Under Section 133 CrPC- (Removal of Public Nuisance)
In the Court of Executive Magistrate

Criminal Complaint
Police Station
1. SANT RAM S//O RAMLAL, R/O Village Ramgarh Tehsil Patiala, District PATIALA -
Complainant
v.
Complaint Under Section 133 CrPC

2. That, the complainant and the respondent are the residents of the same village in
Ramgarh Tehsil, District Patiala. There is a common Circular Path (Phirni) build around the
village that is used for commuting by the villagers and other citizens.
3. That, on 20/3/20 there was a fair held in the neighbouring village of Ramgarh and the
villagers had gone to the fair and the respondent taking advantage of the villlagers and the
complainant built a wall over the said village phirni. The wall is shown in red colour and marked
AB in the site plan Attached.
4. That, the applicant and other residents of village Ramgarh requested the respondent to
demolish the said wall illegally constructed over the village phirni and to restore the village
phirni to its original position, but all of these have fallen on deaf ears.
5. That, the village Panchayat also passed a resolution on 20/3/20 asking the respondent to
demolish the said wall and to restore the Phirni in its original position but all in vain. (Copy of
Resolution Dated 20/3/20 is attached)
6. That, the applicant also served the respondent with a legal notice, via registered post,
dated 20/4/20. (Copy of legal notice and postal receipt dated 20/4/20 is attached.
7. That, the act of the respondent is illegal unlawful, improper and against all cannons of
justice. Moreover, the said Act on part of the respondent is based on malafide intention and on
ulterior motives.
8. That, respondent is responsible for causing nuisance to the complainant and other
villagers of Village Ramgarh by illegally and forcibly building a wall on public land.
9. That, the respondent flatly refused to demolish the said wall constructed over the village
Phirni yesterday. Hence, the cause of action has accrued and is still accruing.
10. That, the said wall is situated on the village Phirni of village Ramgarh that is in the
jurisdiction of the Hon'ble Court, the respondent also resides in the jurisdiction of the Hon'ble
Court hence the Hon'ble Court has jurisdiction to try the suit.
Prayer
It is therefore, prayed that the respondent be ordered to demolish the said wall and not to cause
public nuisance and to restore the village Phirni to its original position.
List of Witnesses
Submitted by Complainant Through Counsel
1. Complainant
2. Sarpanch or the Village Headman
3. Draughtsman- Sohan Kumar, Civil Court Complex, Patiala
4. Gurdeep Singh, Son of _______ and R/O Village Ramgarh
List of Documents-
1. Site Plan
3. Copy of Legal Notice and Post Receipt Dated 14/4/20
Complaint Section 145- CrPC
When a dispute over land (this includes fisheries, Water, Market) has the potential to
cause a breach of peace then Section 145 application can be applied. The purpose of the
application is decide the the possession over the land-the copy of the order is pasted at a
conspicuous place- the proceedings for determining the title will take place later
In the Court of SDM, Patiala
Criminal Complaint
Police Station
1. Sohan Lal S/O Mohan Lal R/o Village Ramgarh, Tehsil Patiala, District Patiala -
Complainant
v.
1. Anil Kumar S/O Sunil Kumar R/O Village Ramgarh, Tehsil Patiala, District Patiala-
Respondent
Date of Occurrence-
Time of Occurrence-
Complaint under Section 145 CrPC Regarding Agricultural land measuring 22 bighas comprised
in Khewat No. 123 Khataooni No. 23 Khasra No. No. 235, 236, 237, 238, 238 Min situated at
Village Ramgarh- Tehsil, Patiala, District Patiala
It is submitted as-
1. That, the agricultural land measruing 22 bighas comprised in Khewat No. 123 Khataooni
No. 23 Khasra No. No. 235, 236, 237, 238, 238 Min situated at Village Ramgarh- Tehsil, Patiala,
District Patiala is in cultivatory possession of the complainant as a tenant for the last 20 years
under the respondent (Landlord) at a rent payable of Rs 120 only. (Fard and Jamabandi for the
yaer 2018-19 is attached.)
2. That, the agriculture land of the respondent is adjacent to that of the land of the
complainant.
3. That, the land fully described in the headnote has been plowed and prepared by the
complainant for sowing crop of paddy but yesterday the respondent entered upon the land and
sowed the crop illegally and forcibly. The complainant asked the respondent not to dispossess
him and take law into his hands and to stop sowing an to restore the possession of the land to the
petitioner. However, the respondent thereupon threatened the petitioner with dire consequences,
he threatened if the petitioner went near him or the disputed land he would fire at him with his
gun. The respondent was carrying a gun with him. Hearing the hue and cry-Ramesh Lal and Ram
Lal tried to intervene, but they were also scared away by the respondent. The respondent further,
threatened the complainant not to enter the land or else he would have to lose his life.
4. That, the land is quite valuable as it is situated near municipal limits of city Patiala. it is
most suitable for the construction purposes of the expanding city of Patiala. The respondent
wants to dispossess the petitioner forcibly so that he can proprietary rights of the land.
5. That, the respondent has acted forcibly, illegally and unconstitutionally. The act of thee
respondent is likely to cause breach of peace.
6. That, the complainant approached the police station to file a FIR but the police refused to
take any action, hence this complaint.
7. That, the land is situated at village Ramgarh within jurisdiction of this Hon'ble Court and
hence the Hon'ble court has jurisdiction to try and pas orders under Section 145 CrPC.
8. That, there is iminnent threat of breach of peace and requires suitable leagl action against
the respondent under Section 145 CrpC and the possession of the land should be restored to the
complainant.
Prayer
it is therefore prayed that the proceedings under Section 145 CrPC are initiated against the
complainant and the possession land fully described under the headnote of the complaint be got
restored to the petitioner.
List of Witnesses- Submitted by Plaintiff through Counsel
1. Complainant Sohan Lal

2. Patwari- Sham Lal (Village Ramgarh, Tehsil Patiala)
3. Ramesh Kumar- Resident of Villlage Ramgarh
4. Ram Lal-
List of Document
1. Farat and Jamabandi for the year 2018-19
Criminal Revision-
Civil Revision is only to be filed in the High Court BUT- In Criminal Cases-can also go to
the Sessions Court
In the Court of Sessions Judge, Patiala

Under Criminal Revision Jurisdiction
Criminal Revision______ 2020
Criminal Case No. 132 of 2017 from Court of Rahul Garg-Judicial Magistrate First Class Patiala
State of Punjab
Petitioner
v.
SANT RAM S//O RAMLAL, R/O 18 NEW COLONY,RAILWAY ROAD, PATIALA
Opponent
Revision against Order of JMIC, Patiala dated 25/3/20 Convicting opponent in Criminal Case
No. 132 of 2017 under Section 324 IPC
Sir, The petitioner above named respectfully showeth; That, the Hon'ble JMIC Patiala has
convicted the opponent in criminal case No. 132 of 2017 under Section 324 IPC vide order dated
25/3/20 to four months imprisonment and pay a fine of Rs. 100 in default of non-payment to
undergo imprisonment for 15 days more. Copy of Order and Judgment is attached
That, the order dated 25/3/20 is unwarranted by facts, law and procedure and is likely to be set
aside on the following grounds-
Grounds
1. That, the Hon'ble JMIC has committed an error in convicting the opponent for 4 months
imprisonment and to pay a fine of Rs. 100 in default of non-payment to undergo further
imprisonment for 15 days and has failed to appreciate the version of the prosecution which if
flawless.
2. That, the Hon'ble JMIC has failed to notice that the prosecution has 2 independent
witnesses, the defence has cross-examined the independent witnesses at length but they have
stood the cross-examination and us such- no shadow of doubt is left.
3. That, the Hon'ble JIMC has committed an error by holding that there has been an error in
the discrepancy of PW1 and PW2. But, it is a cardinal principle of jurisprudence that the
witnesses are not supposed to give a parrot-like version and minor discrepancies are to be
overlooked.
4. That, the Hon'ble JMIC has committed an error in giving over-due importance to the
version of the defence- which is not reliable and not possible.
5. That, at the hearing of the quantum of sentence the Hon'ble JMIC has committed an error
by announcing a lighter sentence to the accused. This fact is totally wrong as the wife of the
accused is a teacher in a government school Patiala and is drawing salary of more than Rs. 40000
and as such the opoonent is not entitled to compensatory relief. (Payslip of Sunita Rani-Wife of
Sant Ram is attached herewith_
6. That, the Hon'ble JMIC has committed an error by not appreciating the fact that the
accused caused hurt to the victim by giving him Lathi blows repeatedly and the accused arrived
at the place of occurrence armed with a Lathi, as such the accused had acted in well-planned
manner.
7. That, the order/judgment dated 25/3/20 is against the principles of good conscience and
natural justice. It is based on conjectures and surmises.
III. That,the petitioner has not filed any revision prior to this revision petition.
IV. That, there are sufficient and ample grounds for sending for the records of the lower court
and enhancing the sentence of the lower court.
It is therefore pprayed that the records of the lower court be sent for and the order of the JMIC
Patiala, dated 25/3/20 convicting the accused in criminal case No. 132 of 2017 under Section 324
IPC be enhanced.
Submitted by Petitioner,
Patiala
List of Documents
Attested copy and order of JMIC dated 25/3/20
Pay Slip of Sunita Rani wife of Sant Ram
Criminal Appeal
In the Court of Sessions Judge, Patiala

Under Criminal Appellate Jurisdiction
Criminal Appeal______ 2020
Criminal Case No. 132 of 2017 from Court of Shri Rahul Garg-PCS Judicial Magistrate First
Class Patiala
SANT RAM S/O RAMLAL, R/O 18 NEW COLONY,RAILWAY ROAD, PATIALA
Appellant
v.
State of Punjab
Respondent
Appeal Against Oorder of JMIC Patiala dated 25/3/20 convicting appellant in Criminal Case No.
132 of 2017 under Section 25, Arms Act.
Sir,
The appellant above named respectfully showeth
1. That, the Hon'be JMIC Patiala has convicted the appellant in Criminal case No. 132 fo
2017 under Section 25, Arms Act vide hs order dated 25/3/20- Copy of Order and judgment is
attached heredwith.
2. That, the order dated 25/3/20 is unwarranted by facts, law and procedure and its likely to
be set aside on the following grounds.
Grounds-
I. That, the Hon'ble JMIC has committed an error by convicting the appellant and has given
undue importance to the prosecution evidence which is full of discrepancies and flaws.
II. That, the prosecution has failed to include 2 independent witnesses at the time of raid which
took place at the tea stall in the opening market and hence the prosecution has failed to adopt the
rules laid under CrPC.
III. That, there is glaring discrepancies in the version of prosecution witnesses- PW1 and PW2
IV. That, the prosecution has failed to examine the investigating officer and this has created a
dent in the prosecution story.
V. That, the prosecution has failed to get the alleged firearm (pistol) examined by a ballistic
expert and without the report of a ballistics expert it is difficult whether the said weapoin
(exhibit P1) is a firearm or just a a toy.
3. That, the appellant has not filed any appeal in any court prior to the present appeal
4. That, there are sufficient and ample grounds for sending for the reports of the lower court
It is therefore prayed that the records of the lower court be sent for and the order of the JMIC
Patiala, dated 25/3/20 convicting the appellant in Criminal Case 132 under Section 25 of Arm
Act be set aside and the appellant be acquitted.
Date-Place
Submitted by Appellant Through Counsel
Section 482- Petition (For Payrole- Accused must be in jail for more than 1 year- District
Payrole Board Certifies his behaviour)
In the High Court of Punjab and Haryana at Chandigarh-

Under Criminal Jurisdiction
Criminal Misc. No. 2020
Criminal Case No. 132 of 2017 from Court of Sessions Judge, Patiala
1. SANT RAM S//O RAMLAL, R/O 18 NEW COLONY,RAILWAY ROAD, PATIALA
Petitioner
v.
1. State of Punjab, Through its Secretary
Respondent
2. DIG (Prisons) Punjab Police Chandigarh
3. Jail Superintendent, Central Jail Jail Road, Patiala
Petition under Section 482 CrPC for releasing the Petitioner on payrole for 3 weeks undergoing
Sentence for life imprisonment being convicted by Sessions Judge, Patiala vide order dated
25/5/2012 convicting petitioner in Criminal Case No. 132 of 2007 under Section 302, IPC
Sir,
The petitioner above-named respectfully showeth-
1. That, the petitioner is undergoing life imprisonment in a criminal case having been
convicted by Sessions judge Patiala vide order 25/5/2012 convicting the petitioner in Case No.
132 of 2007 under Section 302 IPC.
2. That, the petitioner prays to be released on payrole for 3 months inter-alia the following
grounds
Grounds-
I. That, the petitioner is undergoing life imprisonment in a criminal case under Section 302 IPC
and is in jail since 25/5/2012.
II. That, the petitioner's daughter is getting married on 12/5/2020 and the presence of the
petitioner at the wedding is essential, according to family customs and traditions. (Copy of
invitation is attached)
IV. That, the petitioner is required to be at the wedding of his daughter to perform the ceremony
of Kanya Daan- it is a custom duly recognized by Hindu law and during the time of the marriage
prior to the event of the wedding couple performing Satpadi around the sacred fire-the fire of the
bride performs Kanya Daan- that is a symbolic gesture that the father has handed over the
responsibility of the
V. That, the petitioner is in the good books of the jail authorities and has not created a scene of
lawlessness and there is no adverse remark ever passed by the jail authorities against the
petitioner.
VI. That, the conduct of the petitioner in prison has been uniformly good in the opinion of the
District parole board. (Copy of report is attached
VII. That, in the opinion of the District Board there is a reasonable probability that during the
period of his release the petitioner shall not commit a crime.
VIII. That, the presence of the petitioner at the marriage of his daughter is essential due to the
aforesaid reasons and it is in the interest of justice that the petitioner be released on 3 months on
parole on 10/5/2020
IX. That, the plea of the petitioner to be released on parole is supported by principles of justice,
equity and good conscience.
3. That, the petitioner undertakes to surrender to the jail authorities before the expiry of the
parole and not to commit any cimes during the period outside the jail
4. That, this is the first petition filed under Section 482 CrPC by the petitioner and no
petition has been filed by the petitioner prior to this petition.
5. That, the petitioner is a permanent resident of district Patiala and has urban as well as
rural property and deep roots in society, thus he is unlikely to escape the hands of law, if released
on Parole
It is humbly prayed that the petitioner be released on Parole for 3 weeks undergoing sentence for
life imprisonment vide order 25/5/2012 in criminal case No. 132 of 2007 convicting the
petitioner under Section 302 IPC.
And for this act of kindness the petitioner shall be duty bound forever prayed
6/5/2020, Chandigarh
Council for Petitioner
Section 482- Quashing of FIR in High Court (On the allegation that the FIR has been filed
with ulterior motive
FIR No. 132 dated 23/3/20 filed at Civil Lines Police Station in a Criminal Case U/S. 326, 34
IPC, Pending in Court of Shri Rahul Garg PCS Judicial Magistrate First Class, Patiala
Sohan Lal S/O Mohan Lal R/o 18 Azad Nagar Patiala, Sirhind Road, Patiala
Petitioner
v.
Respondents
2. Inspector General of Police (Prisons), Punjab Police Chandigarh
3. SHO, Police Station, Civil Lines, Patiala
Petition under Section 482 CrPC for Quashing FIR No. 132 dated 20/3/20 filed at Civil Lines
Police Stations, Patiala in a criminal case under Section 324/34 IPC and pending in the Court of
Shri Rahul Garg, PCS Judicial Magistrate First Class, Patiala
Sir, The petitioner respectfully showeth-
1. That, the petitioner is a law-abiding and respectable citizen and has been wrongly,
arbitrarily and illegally named in the FIR No. 132 dated 20/3/30 filed at Civil Lines, Police
Station Patiala in a criminal case-Section 326/34 IPC and pending in the court of Shri Rahul
Garg PCJ
2. That, the FIR No. 132 dated 20/3/20 is unwarranted by facts, aw and procedure, It is
illegal, unconstitutional and arbitrary and filed with an ulterior motive. It merits to be quashed
inter-alia the following grounds-
Grounds
I. That, in the FIR 132 dated 20/3/20 the petitioner has been wrongfully impleaded and it has
been attributed that he caused inury to the victim with a lathi. However, the petitioner is a
physically handicapped person and has lost both his arms in an attack of polio. (Medical
Certificate is attached herewith)
II. That, the FIR is wrongly and arbitrarily lodged against the petitioner with an ulterior motive
as it is unlikely that the handicapped person can cause injury through lathi blows to the victim.
III. That, the police have not investigated the case thoroughly before filing the FIR and have
wrongly, arbitrarily and illegally impleaded the petitioner in the FIR.
3. That, this is the first petition filed under Section 482, CrPC and no petition has been filed
by the petitioner prior to the petition.
4. That, the FIR No. 132 dated 20/3/20 filed at Civil Lines Police Stations, Patiala in a
criminal case under Section 324/34 IPC and pending in the Court of Shri Rahul Garg, PCS
Judicial Magistrate First Class, Patiala merits to be quashed.
Prayer
The petitioner most humbly prays that the Hon'ble Court be pleased to-
A. Quash FIR No. 132 dated 20/3/20 filed at Civil Lines Police Stations, Patiala in a criminal
case under Section 324/34 IPC.
B. Issue any other further order or direction as this Hon'ble Court may deem fit and appropriate
in the facts and circumstances of the case
and for this act of kindness the petitioner shall as in duty bound forever pray
Chandigarh- Date-
482- For Enforcement Of Article 21

1. Sohan Lal S/O Mohan Lal R/o 18 Azad Nagar Patiala, Sirhind Road, Patiala
Petitioner
2. Vimla Devi Sohan Lal R/o 18 Azad Nagar Patiala, Sirhind Road, Patiala
v.
Respondents
2. Inspector General of Police (Prisons), Punjab Police Chandigarh
3. SHO, Police Station, Civil Lines, Patiala
4. Vinod Mishra son of Rakesh Mishra Resident 2020 Green Park Colony, Patiala
5. Rani Mishra wife/of of Vinod Mishra Resident 2020 Green Park Colony, Patiala
Petition for directing respondents No. 1 to 3 to provide personal security for protecting life and
liberty of petitioners.
1. That, the petitioners are law abiding and respectable citizens of India and have
solemsnished their marriage according to Hindu culture and rites dated 12/4/2020
2. That, petitioner No. 1 is a Schedule caste and petitioner No.2 is a Brahmin by birth and as
such parents of petitioner No. 1- namely Vinod Mishra and Rani Mishra-Respondents No. 4 and
5 respectfully are opposed to the marriage and have become inimical to the petitioners.
3. That, the life and property of the petitioners is not safe and the petitioners are entitled to
protection of life and liberty inter-alia the folowing grounds.
Grounds-
I. That, the petitioners are both majors and have performed the said marriage with their free
consent and without any force or threat.
II. That, the petitioners and some other relatives of petitioner No. 2 are opposed to the marriage
and have become inimical and hostile towards the petitioners.
III. That, the petitioners have solemnised the marriage according to Hindu marriage rites by
performing Satpadi around the scared fire at Kali Mata Mandir, Mall-Patiala (Copy of receipt
issued is attached herewith)
IV. That, the petitioners have also got the marriage registered online with registrar of marriages
as per provisions of law. Copy of Marriage Certificate is attached herewith.
V. That, the marriage of the petitioner is valid and under the provisions of law, as such the
petitioners are husband and wife in the eyes of the law and have all rights and duties of a legal
marriage and that of a husband and wife
V. That, on 23/33/20 when the petitioner had gone to Bus-stand Patiala in order to catch a bus to
Chandigarh, Respondent No. 4 along with some agents armed with lathis threatened the
petitioner with dire consequences and pushed petitioner No. 1 who fell on the floor and got hurt.
The timely intervention of some passengers saved him from the Clutches of respondent No. 4
who escaped seizing suitable opportunity.
VI. That, the petitioners went to government hospital Patiala, to get medical attention. (Copy of
Medical Report is attached)
VII. That, after getting medical attention the petitioners went to the police station to file a FIR
but the police refused to take any action.
VIII. That, the life and property of the petitioners is at stake and they fear that respondents No. 4
and 5, parents of petitioner No. 2 would cause them and their property injury.
IX. That, parents of petitioner No. 2 are threatening the petitioners with dire consequences if they
catch site of them and hence the liberty of the petitioners has been taken away by the
respondents.
That, the petioners need personal security to lead a fair and fearless life to which they have the
legal right under Article 21 of the Constitution.
4. That, this is the first petition that the petitioners have filed and prior to this petition they
have not filed any petition before the Hon'ble Court.
Prayer
It is humble prayed that the respondents 1, 2 and 3 be directed to provide the petitioners with
personal security enabling them to lead a safe and secure life and the life and property of the
petitioner be also secured and made safe.
And for this act of kindness the petitioner shall as in duty bound forever pray.

Chandigarh Date
Module IV-
Draft of Sale Deed- Sir has used the term vendor/vendee- primafacie these terms are only
used in moveable property
Sale Deed
This deed of sale is made between Sohan Lal S/O Mohan Lal R/o 18 Azad Nagar Patiala,
hereinafter called the Vendor-the first party and Rakesh Gupta S/O Mukesh Gupta R/O 110
Railway Colony, Railway Road Patiala, (hereinafter called the Vendee- the second party.
Whereas the vendor is absolute owner of the house hereinafter called the property, built on Plot
34, New Green Park Colony, Patiala, measuring 250 Sq. Yards comprised of 2 bedrooms, 1
Dining-cum-drawing room, 2 washrooms, a kitchen and courtyard and bounded as under-
North- Road
South- Road
East- House Number 35 New Green Park Colony, Patiala
West- House Number 33 New Green Park Colony, Patiala
And whereas the site plan of the property is attached in the schedule.
Whereas the said property fully described above is free from all encumberances whatsoever.
And whereas the vendor has agreed to the sale of the said property to the vendee on the
following terms and conditions.
1. That, in consideration of Rupees 10 Lakhs, which will be paid by the vendee in cash at
the time of execution of the sale deed.
2. That, the vendee has transferred possession of the property to the vendee and the vendor
has no right, title or interest left in the said property.
3. That, the said property is free from all encumbrances whatsoever.
4. That, the vendor has a clear and free title in the said property.
5. That, the vendor has handed the title deed to the vendee.
In Witness whereof the vendor and the vendee had put their signatures on the sale deed after
being read over the contents of this gift deed and after understanding the contents of the gift deed
and put their signatures in presence of the following witnesses and the witnesses have put their
signatures on this gift deed in acknowledgment whereof.
Witness No. 1 Vendor Vendee Witness No. 2

Gift Deed- Draft
This deed of gift is made on the 8th Day of May, 2020 at Patiala between Sohan Lal S/O Mohan
Lal R/o 34 Church Road Patiala, hereinafter called the Doner-the first party and Rakesh Gupta
S/O Mukesh Gupta R/O 110 Railway Colony, Railway Road Patiala, hereinafter called the
donee- the second party.
Where as the Donor is absolute owner of house (hereinafter called the property) built on Plot 34,
Church Road Patiala, measuring 250 Sq. Yards and Comprised of two bedrooms- a drawing cum
dining room, a kitchen, two washrooms, courtyard and bounded as under-
North- Road
South- Road
East- House Number 33 Church Road Patiala
West- House Number 35 Church Road Patiala
And whereas the site plan of the site property is attached in the schedule-
Whereas the said property fully described as above is free from all encumberances whatsoever.
And whereas the doner has agreed with the donee for gift of the said property on the following
terms and conditions.
1. That the donor is the maternal uncle of the donee and is making the gift out of natural
love and affection.
2. That, the donor has transferred the possession of the said property to the donee and now
the donor has left no right/title or interest in
3. That, the said property is free from all encumberances whatsover.
4. That, the donor has a clear and free title in the said property.
5. That, the donor has handed the title deed of the property to the donee.
In Witness whereof the donor and the donee had put their signatures on the sale deed after being
read over the contents of this gift deed and after understanding the contents of the gift deed and
put their signatures in presence of the witnesses and the witnesses have put their signatures on
this gift deed in acknowledgment whereof.
Witness No. 1 Donor Donee Witness No. 2
Lease Deed
This deed of lease is made at Patiala on this 30th day of April , 2020 between Sohan Lal
S/O Mohan Lal R/o 34 Church Road Patiala, hereinafter called (the Lessor) the first party-
the first party and Rakesh Gupta S/O Mukesh Gupta R/O 110 Railway Colony, Railway
Road Patiala, hereinafter called (the Lesee) the second party.
Whereas the lessor is absolute owner of the house hereinafter called the house
hereinafter called (the House) situated at 34 Church Road Patiala measuring 250 square
yards comprised of 2 bedrooms, 1 dining-cum-drawing room, a kitchen, 2 washrooms
and courtyard and bounded as under:
North- Road
South- Road
And whereas the site plan of the house is attached in the Schedule
And whereas the lessor has agreed to lease the said house on rent for the period of 11
months at Monthly rent of Rs. 5000 per month on the following terms and conditions.
1. That, the lesee shall pay the rent on the 1st of each calendar month.
2. That, the lessee shall us the said house for residential purpose and for no other purpose
whatsoever.
3. That, the lessee shall not change or alter the condition of the house without prior written
permission of the lessor.
4. That, the lessee shall not materially impair tehe value and utility of the house.
5. That, the lessee shall be liable to pay the charges for the electricity, water consumed and
sewerage, house tax etc for the house.
In Witness, whereof the lessor and the lessee have been read over the contents of this lease deed
and afe having understood the contents of the lease deed they have put their signatures in
presence of the witnesses and the witnesses have also put their signatures on this lease deed in
acknowledgement thereof.
Signatures-
Witness No. 1 Lessor
Lessee Witnesses No. 2
Place- Patiala- Date
Mortgage Deed
This deed of Mortgage is made at Patiala on this 30th day of April , 2020 between Sohan
Lal S/O Mohan Lal R/o 34 Church Road Patiala, hereinafter called (the Mortgagor) the
first party-the first party and Rakesh Gupta S/O Mukesh Gupta R/O 110 Railway Colony,
Railway Road Patiala, hereinafter called (the Mortgagee) the second party.

Whereas the Mortgagor is absolute owner of the house hereinafter called the house
hereinafter called (the House) situated at 34 Church Road Patiala measuring 250 square
yards comprised of 2 bedrooms, 1 dining-cum-drawing room, a kitchen, 2 washrooms
and courtyard and bounded as under:
North- Road
South- Road
And whereas the Morgator has requested the mortgagee to lend him a sum of Rs. Five
Lakh which the mortgagee has agreed to on the mortgagor mortgaging the house on
the following terms and conditions.
1. That, on pursuance to the said agreement and in consideration of the sum of Rs. 5 Lakh
the mortgagor will pay the sum of Rs. 25000 with interest at the rate of 12%/pa every
four months till the repayment of the said interest
2. That, the first installment shall be paid on the 2nd Day of August 2020 and each
subsequent installment on the 7th of December April and August of each succeeding year
until the said sum is repaid in full.
3. That, if the mortgagor does not pay the said mortgage amount with interest when it shall
become due and payable the mortgagee shall be entitled to sell the house through any
competent court and realize the pending mortgage amount and interest thereon, out of the
sale proceeds of the house.
4. If the mortgage amount is not paid then the said house shall remain as security for the
mortgage amount and interest thereon.
5. That, the mortgagor shall insure the said house and take out an insurance policy in the
joint name of the mortgagor and the mortgagee.
6. The, premium paid by the mortgagee shall be added to the mortgage amount if not paid
by the mortgagor on demand.
7. That, the mortgagor can demand lease of the said house with consent of the mortgagee in
writing.
8. That, the mortgagor shall bear stamp duty, registration charges and other out of pocket
expenses for the execution and registration of this deed.
In Witness, whereof the Mortgagor and the Mortgagee have been read over the contents of this
lease deed and aftee having understood the content of the mortgage deed they have put their
signatures in presence of the witnesses and the witnesses have also put their signatures on this
lease deed in acknowledgement thereof.
Signatures-
Witness No. 1 Lessor
Lessee Witnesses No. 2
Place- Patiala- Date
Agreement for Sale
This agreement for sale is made at Patiala on this 30th day of April , 2020
between Sohan Lal S/O Mohan Lal R/o 34 Church Road Patiala , hereinafter called (the
Vendor) the first party-and Rakesh Gupta S/O Mukesh Gupta R/O 110 Railway Colony,
Railway Road Patiala, hereinafter called (the Vendee) the second party.

Whereas the Vendor is absolute owner of the house hereinafter called (the House)
situated at 34 Church Road Patiala measuring 250 square yards comprised of 2
bedrooms, 1 dining-cum-drawing room, a kitchen, 2 washrooms and courtyard and
bounded as under:
North- Road
South- Road
Whereas the said house fully described above is free from all encumberances whatsoever.
And whereas the Vendor has agreed with the Vendee for sale of the said property on the
following terms and conditions.
1. That, in consideration of Rupees 10 Lakhs (Ten Lakhs), which will be paid by the vendee
in cash at the time of execution of the sale deed.
2. That, the Vendee has agreed to pay earnest money of Rs. 1 Lakh and the balance of Rs. 9
Lakh shall be paid by the Vendee in cash at the time of execution of the sale.
3. That, the said property is free from all encumbrances whatsoever.
4. That, the vendor has a clear and free title in the said property.
5. That, the vendor shall deliver the title deed of the house to the vendee at the time of
execution of the sale deed.
6. That, the vendor shall deliver the possession of the said house to the vendee.
7. That, the parties have agreed to get the sale deed executed on 10th June 2020.
8. That, in case the vendee does not turn up at the office of the Registrar, Patiala to get the
sale deed executed he shall lose the amount oof Rs. 1 Lakh paid as earnest money and if
the vendor does not get the sale deed executed he shall pay Rs. 2 Lakh that is double the
amount of earnest money received by him.
In Witness whereof the vendor and the vendee had put their signatures on the sale deed after
being read over the contents of this gift deed and after understanding the contents of the gift deed
and put their signatures in presence of the following witnesses and the witnesses have put their
signatures on this gift deed in acknowledgment whereof.
Witness No. 1 Vendor Vendee Witness No. 2
Place-Date
Exchange Deed
This deed of exchange is made at Patiala on this 30th day of April , 2020 between Sohan
Lal S/O Mohan Lal R/o 18 Azad Nagar Patiala, hereinafter called the first party-and
Rakesh Gupta S/O Mukesh Gupta R/O Plot No 34 Church Road Patiala, hereinafter called
the second party.
Whereas the Vendor is absolute owner of the house hereinafter called Property No. 1
situated at 18 Azad Nagar Patiala measuring 250 square yards comprised of 2
bedrooms, 1 dining-cum-drawing room, a kitchen, 2 washrooms and courtyard and
bounded as under:
North- Road
South- Road
East- House Number 17 Azad Nagar Patiala
West- House Number 19 Azad Nagar Patiala
Whereas the Vendor is absolute owner of the house hereinafter called the house
hereinafter called Property No. 2 situated at Plot No 34 Church Road Patiala measuring
150 square yards comprised of 2 bedrooms, 1 dining-cum-drawing room, a kitchen, 2
washrooms and courtyard and bounded as under:
North- Road
South- Road
And whereas the site plan of Property No. 1 and Property No. 2 is attached in the
Schedule
Whereas the two houses fully described above are free from all encumbrances whatsoever.
And whereas the parties have agreed for the exchange of property No. 1 for Property No. 2 on
the following terms and conditions.
1. In exchange of Property No. 1 with Property No. 2 the Second party shall pay in cash Rs.
10 Lakhs (Ten Lakhs)
2. That, the second party has transferred the possession of Property No. 2 to the first party
and the second party has no right, interest or title in Property No. 2.
3. That, the first party has transferred the possession of Property No. 1 to the second party
and the first party has no right, interest or title in Property No. 1.
4. That, the said properties are free from all encumberances.
5. That, Party No. 1 and Party N. 2 has a clear and free title in the said properties.
6. That, the parties have delivered the title deeds of the said properties to each other.
In Witness whereof the first party and the second party have put their signatures on the sale deed
after being read over the contents of this gift deed and after understanding the contents of the
exchange deed and put their signatures in presence of the following witnesses and the witnesses
have put their signatures on this exchange deed in acknowledgment whereof.
Witness No. 1 First Party Second Party Witness No. 2
Place-Date
Supreme Court Guidelines-

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Drafting/Pleading

 Start with Sir, it is respectfully submitted as

Draft begins after heading/title ends

Permanent Injunction- Module 1

 Unlike Mandatory Injunctions- permanent injunctions are sought in order to restrain the

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

SUIT FOR PERMANENT INJUNCTION RESTRAINING THE DEFENDANT FROM

Sir it respectfully submitted as

1. That the plaintiff is a law abiding and responsible citizen

Submitted by Plaintiff Through Council, at Patiala Dated ________

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

Ram Lal S/O Sohan Lal, resident of House Number Plaintiffs

1. Copy of the Site Plan

Submitted by Plaintiff through Council

Suit for Mandatory jurisdiction- Draft Begins after this

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

Sir, it is respectfully submitted that

1. the plaintiff is a respectable and law abiding citizen

Submitted by Plaintiff Through Council, at Patiala Dated

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

Ram Lal S/O Sohan Lal, resident of House Number Plaintiffs

Suit for Specific Performance

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

Sir, it is respectfully submitted as under

1. The plaintiff is a law abiding and respectable citizen

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

Sir, It is respectfully submitted that

1. That, the plaintiff is a law abiding and respectable citizen.

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

Ram Lal S/O Sohan Lal, resident of House Number Plaintiffs

Draft of Suit for Possession by Way of Partition

In the Court of Civil Judge (Junior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF: ( )

It is respectfully submitted as

1. That, the plaintiffs are law abiding and respectable citizens

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

Decree for Restitution of Conjugal Rights-

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF:

1. The petitioner is a law abiding and responsible citizen.

In the Court of Civil Judge (Senior Division), Patiala

Suit No________ of 2020

IN THE MATTER OF: