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Original Suit No. . of

Sameera Plaintiff


Arvind Defendant


The above named plaintiff states as follows:-

1. Sameera, the plaintiff is the proprietor of M/s. Suma Emporium, aged 42 years

residing in Blue Bird, in Tripunithara Village, Kottayam Taluk, Kottayam District, Kerala

State and is the son of Mathews.

The address of the plaintiff for service of all notices and processes is that of his

councel Sri Tom Jones, M. A. LL. B., Advocate, Kaloor, Ernakulam.

2. Arvind, the defendant is an agriculturalist, aged about 38 years, residing in Laila

Nivas in in Tripunithara Village, Kottayam Taluk, Kottayam District, Kerala State and is the

son of Mohammad.

All notices and processes on the defendant may be served on him in his address

noted above or on his advocate, if and when engaged.

3. The plaintiff was served with a cheque of Rs. 1,00,000/- on 20th March 2016. The

plaintiff presented the cheque at the bank on 25th March 2016. The cheque was returned by

the bank stating insufficient balance.

4. The defendant, during the period from 26th March 2016 has remained untraceable.

5. On 6th May 2016 the plaintiff, through his advocate, has sent a registered notice to

the defendant demanding the amount, for which the defendant has caused a reply to be sent

raising false and frivolous contentions.

6. An amount of Rs.1,00,000/- being the amount to be paid to the plaintiff and an

amount of Rs. 50000/- being the interest thereon at the rate of 12% percent per annum

according to the usage of trade is now due from the defendant to the plaintiff. The plaintiff is

thus entitled to realize Rs. 1,50,000/- from the defendant.

7. The cause of action for the suit arose on _____ when the cheque was served to the

defendant, and thereafter on each date of subsequent transaction at Kottayam within the

jurisdiction of this Court.

8. The plaintiff estimates the value of the reliefs sought by him at the sum of Rs.

4000/- for the purpose of Court Fees under Section 22 of the Kerala Court Fees and Suits

Valuation Act, and at the same amount for purposes of jurisdiction.

9. The plaintiff prays that this Honourable Court may be pleased to pass a decree in

favour of the plaintiff:-

a. For the amount of Rs. 50000/- and interest thereon at the rate of 12 percent per

annum from this date to the date of the plaint till the date of realization.

b. For the plaintiffs costs of the suit; and

c. Awarding such other reliefs as are deemed fit and proper in the interest of justice

and which may be prayed for hereafter.


1. Valuation for the purpose of jurisdiction and Court Fees

for relief (a)
Principal amount ________________________
Interest from _____ to ____ ________________________
Total ________________________

2. Court Fees thereon under Section 22, read with Schedule I,

Article 1 of the Kerala Court Fees and Suits Valuation Act, __________________
Court Fees paid under Section 4A of the Kerala Court
Fees and Suits Valuation Act __________________
Balance of Court Fees payable
Date this, _______the day of _______
Sameera Plaintiff

Tome Jones, Advocate
I, Sameera, the plaintiff above named, do hereby declare at Ernakulum, that what

is stated above is true to the best of my knowledge, information and belief.

Sameera- Plaintiff