Suit for Recovery of Money

Complete plaint for recovery of a liquidated sum with cause of action, jurisdiction clause, limitation plea and prayer, drafted under Order VII CPC.

When to use this draft

Use where a defined sum is due under a contract, invoice, cheque or acknowledged account and the defendant has failed to pay after notice.

Essential contents

• Parties with complete addresses and CNIC
• Cause of action with dates and place
• Valuation for court fee and jurisdiction
• Limitation - within 3 years of the cause of action
• Verification and affidavit under Order VI Rule 15 CPC
• List of documents relied upon (Order XIII CPC)

Drafting notes

1. Attach the original agreement, invoices or legal notice as annexures marked A, B, C.
2. State the exact figure claimed with a break-up of principal and mark-up separately.
3. Where a cheque was dishonoured, plead the bank memo date - it re-starts limitation.
4. Verify the plaint before an Oath Commissioner, not merely by signature.