IN THE HON’BLE COURT OF MR.

SHIVANSH LAL,
TIS HAZARI COURTS, RAJPUR ROAD, NEW DELHI
CIVIL SUIT NO. 112 OF 2021

IN THE MATTER OF:-

S.K. PRIVATE LIMITED ..............................................PLAINTIFF

VERSUS

MISS. K ....................................................................... DEFENDANT

SUIT CONCERNING COMPENSATION REGARDING

BREACH OF CONTRACT

HUMBLY SHEWETH :-
1. That the Plaintiff herein S.K Private Limited is a Company incorporated under the
provisions of the Companies Act,2013 and applicable provisions and rules of Companies
Act,2013 having registeredoffice at Central Hope Town, Bayakhala, Selaqui, Dehradun
– 248011 andis engaged in the business of selling pipes, taps and supply logistics. It is
one of the biggest and renowned plumbing companies in India. They have been in the
business of selling high-quality water taps, pipes which are widely put to use across Pan-
India since 2015. The Plaintiffis having Pan India presence and is having branch offices
in 12 other cities.
2. That the defendant herein Miss K, aged 24 years, former employee of S.K. Private
Limited, having post graduate business administration degree in Human Resource,
residing in Vidhi Colony, Delhi.
3. That the Plaintiff had posted on LinkedIn for hiring a person as a receptionist in
Ahmedabad who had completed his or her M.B.A. in Human Resource. The job
conditions were clearly stated in the post.

4. That in January 2021, the Defendant applied for the job position as she was in urgent
need of money and agreed to the terms and conditions of the job as well as accepted the
agreement.

5. That the defendant started with a training period of 21 days from January 3, 2021, to
 January 25, 2021, where she was trained regarding her job position with the intention
that she will be utilizing the skills acquired throughout her training period for the
betterment of S. K. Private Limited. The Plaintiff incurred the cost of INR 70,000 for
providing her training.
6. That the Defendant worked for the Plaintiff for a period of 6 months i.e., January 2021
to June 2021 where her responsibility included dealing with MRF, Apollo and other
suppliers of the industry.
7. That the Defendant on account of the festival of Raksha Bandhan, took a leave of 3
days from 21/08/2021-23/08/2021 stating the reason that she wishes to visit her brother
who stays in Jaipur.
8. That the Defendant on 23/08/2021, Monday morning, wrote an email to the HR of the
Plaintiff’s company posting her resignation.
9. That the Defendant stated the reason for her resignation to the Plaintiff that she was not
assigned the asked post.
10. That the Defendant voluntarily applied for the said post and agreed to the terms and
conditions of the agreement. In the terms and conditions of the agreement, the role
which the Plaintiff offered along with the designated place and salary was clearly
mentioned.
11. That the Defendant’s reason of resignation is completely not acceptable. Had the
Defendant not satisfied with the assigned job, she should have not accepted the job offer
at the first place.
12. That the Defendant also possesses numerous confidential files of the company as well
as passwords which can only be opened by her fingerprint. She have not surrendered
the confidential information to the Plaintiff and also have sold them for a hefty amount
of INR 6,00,000 to the competitor company.
13. That the Defendant, moreover, has violated the terms of the contract which includes the
exit clause as well. The exit clause states, “If the employee wishes to resign from his/her
post, he must serve the Company in writing his/her resignation for a period of 3 months
prior, or in case employee wish to leave the company immediately, he/she must
handover the salary of the 3 months to the Company.”
14. That the Plaintiff in good faith and promoting young talent, gave this opportunity to the
Defendant who was a complete fresher in this field. Now, the defendant had decided to
leave the Plaintiff’s company without any prior information. Thus, violating the terms
and conditions of the Contract.
15. That the abrupt resignation by the defendant have led to loss to the company and the
supplier of INR 3,00,000 and INR 14,00,000 respectively.
 PRAYER
It is respectfully prayed that this Hon’ble Court may be pleased to grant the following
reliefs in favor of the Plaintiff and against the Defendant:

• An order that the Defendant must surrender the confidential information to the
plaintiff and follow the terms and conditions of the contract with the Plaintiff
and follow the exit clause as mentioned in it.

• An order for cost in the proceedings in favour of the Plaintiff against the
Defendants.

• Pass any further order as this Hon’ble Court may deem fit and proper under the
facts and circumstances of the present case.

AND FOR THIS ACT OF KINDNESS PLAINTIFF AS IS DUTY BOUND AND

SHALL EVER PRAY.

PLAINTIFF
THROUGH
SHRAILEEN KAUR
ADVOCATE
A -112, Vihaan Colony,
New Delhi - 110029
PLACE: NEW DELHI
DATED:

VERIFICATION

I, S.K. Private Limited, plaintiff, do hereby verify that the above mentioned
content is true to the best of my knowledge.
Verified at – Dehradun on the 13th day of August 2022.
DEPONENT