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Format of a Plaint claiming compensation for Defamantion

Important points to remember-

Format of all Civil suits are pretty much the same. They are governed by Order VI (Pleading) and Order VII (Plaint) CPC. Please see this for theory part.
Suit for compensation for things like Defamation, Malicious Prosecution can be filed in the court as determined by Section 19 and 20 of CPC.

IN THE COURT OF CIVIL JUDGE, [[DISTRICT OR PLACE]].

Suit no . . . . . . . . .  of 20. . .

IN THE MATTER OF:

[[Name of the Plaintiff]] S/O or D/O or W/o [[Name of the Father/Husband/Guardian]],

aged about . . . . years,

R/O [[Complete address of the Plaintiff]].

Mobile: [[Mobile No. of the Plaintiff]].

Or

M/s ABC Pvt. Ltd.

A Company Incorporated Under the Companies Act, 2013

Having Its Registered Office At [[Address as per Registration]],

Through its Director, Shri……………………

. . . Plaintiff

Versus

[[Name of the Defendant/Respondent]] S/O or D/O or W/o [[Name of the Father/Husband/Guardian]],

aged about . . . . years,

R/O [[Complete address of the Defendant/Respondent]].

Mobile: [[Mobile No. of the Defendant/Respondent]].

Or

M/s XYZ Ltd.

A Company Incorporated Under The Companies Act, 2013

Having Its Registered Office At [[Address as per Registration]],

Through its Director, Shri…………………

. . . Respondent/Defendant

                                                 PLAINT UNDER ORDER 7 RULE 1 FOR COMPENSATION FOR DEFAMATION

The plaintiff respectfully states as follows : –

Brief Description of the case:
(1) The respondent publicly accused the plaintiff of selling watered down milk, which has caused immense harm to the reputation of the plaintiff. The present suit is meant for compensation for the harm done to the plaintiff’s reputation.

Matters of Inducement:
(2) Plaintiff is a milk man and sells milk in many colonies of Indore including MG Road, AB Nagar.
(3) Respondent is the president of an informal residents association of MG Road.

Facts constituting cause of action:
(4) In a residents association meeting held on 10/10/2015, the respondent publicly accused the plaintiff of selling milk mixed with water. A tape record of the respondent making the accusation is attached with this petition.
(5) The said speech made by the respondent was heard by hundrends of residents of MG Road, where the plaintiff sells goods.
(6)  The said speech has caused the plaintiff a lot of embarrament and loss of business.
(7) The plaintiff denies that he sells watered milk and claims that the statement made by the respondent was completely baseless.

Jurisdiction:
(10) The meeting where the defamatory statement was made by the respondent happened in Indore, which is under this court’s jurisdiction.
(11) The plaintiff claims, on account of the loss of business as well as mental agony, an amount of 40,000/- which is under this court’s jurisdiction.

Relief Claimed: 
(12)  The plaintiff prays that the court be pleased to order the respondent to pay sum of Rs 4,00,000 on account of the loss of business because of his baseless and false speech.  The plaintiff further prays that the respondent be ordered to pay compensation for mental harassment and cost of this litigation.

Date: [[mention the date of filing]]

Place: [[Name of the Place]]

[Signature of the Plaintiff]

[Name of the Plaintiff]

Through

[[Signature of the Advocate]]

[[Name of the Advocate]]

[[Name of the Law Firm: LawDocs Associates]]

[[Address, e-mail & mobile no. of the Advocate]]

VERIFICATION

Verified at [[Place]] on this [[Date:1st day of January 20…]] that the contents of paras 1 to … of the plaint are true to my knowledge derived from the records of the Plaintiff maintained in the ordinary course of its business, those of paras …. to …. are true on information received and believed to be true and last para is the humble prayer to this Hon’ble Court.

[[Signature of the Plaintiff]]

[[Name of the Plaintiff]]

 

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