Drafting and Pleading

CIVIL PLEADINGS
EXERCISE-I PLAINT
PLAINT
ORDER-6, RULE-17, SECTION-26
In the court of the Junior Civil Judge at Varanasi
O.S No. ____/2018
Shri Rohit Singh s/o Shri Rajendra Singh, aged 40 years, r/o A-20, Laxmi Nagar,
Sundarpur, Varanasi-221005 …………..Plaintiff
Vs.
Shri Jatin Yadav s/o Jayant Yadav, aged 43 years, r/o A-19, Laxmi Nagar,
Sundarpur, Varanasi-221005 ………..Defendant
Suit for recovery of Rs. 500 as compensation for trespass
The plaintiff begs to submit as under:
1. That the defendant is residing in House No- A-19 which is adjoining the plaintiff’s
House no. A-20 situated in Sundarpur in the city of Varanasi. There is a House no.
A-21 which is adjoining the plaintiff’s house on its northern side.
2. That the defendant, without the permission of the plaintiff, stepped in, and trespassed
on the roof of plaintiff’s house from his house no A-19 on 18TH April ,2018 at about
11 pm and in spite of remonstrance by the plaintiff’s son, crossed the roof of the
plaintiff and went to House no B-21.
3. That the defendant has committed an act of trespass on the immovable property of the
plaintiff and is liable to pay compensation for his such wanton act to thee plaintiff,
which the plaintiff claims at Rs. 500. As the defendant threatens to repeat the act and
as the plaintiff’s family members privacy is disturbed thereby, the at of the defendant
becomes still more reprehensible.
1. DRAFTING, PLEADING AND CONVEYANCING

4. That the cause of action arose on 18th April 2018 at Varanasi. Hence this court has
jurisdiction.
5. The Plaintiff values this suit for the purpose of Court Fee and Jurisdiction at Rs.500/-
and pays Court Fee of Rs.151/-
6. That the plaintiff prays:
 That the honourable court may be pleaded to pass a judgment and decree
against the defendant and in favour of the plaintiff.
 Directing the plaint defendant to pay the plaintiff the sum of Rs. 500.
 Awarding the plaintiff, the cost of the suit.
 Passing such further or other order as the honourable court may deem fit and
proper in the circumstances of the case.
Counsel for Plaintiff Plaintiff
VERIFICATION
I, Rohit Singh, son of Shri Rajendra Singh, the plaintiff above named do hereby declare
that what is stated in the above paragraphs are true to the best of my knowledge and
belief.
Verified at Varanasi on the 23rd day of April 2018.
Plaintiff

IN THE COURT OF THE JUNIOR CIVIL JUDGE AT VARANASI
O.S. No …………………/2018
Vs.
AFFIDAVIT
I. Rohit Singh do hereby solemnly affirm and state as under that: -
That I am the deponent in the captioned suit. I am fully conversant with the facts
of the plaint and competent to swear this affidavit on my behalf.
That the present appeal has been drafted by my counsel under my instructions and
guidance and the contents of the same are true and correct and are not being
repeated herein for the sake of brevity and to avoid repetition and prolixity.
That the contents of the plaint may kindly be read as part and parcel of this
Affidavit also.
DEPONENT
VERIFICATION:
Verified by me at Sundarpur, Varanasi on 23rd April, 2018

EXERCISE-II
WRITTEN STATEMENT
Civil suit no. ____/2018
Vs.
Written Statement on behalf of the defendant
The defendant most respectfully-

Showeth:
1. Para 1 is admitted.
2. Para 2 is admitted. The defendant heard a shout from house No. 21 saying “Fire!,
Fire!” The defendant accordingly rushed to render aid to the occupant of house
No. 21 on account of neighborly feeling.
3. It was a trespass, it was so on account of sheer necessity. The defendant has never
threatened to trespass into or onto the house of the plaintiff. The insinuation
mentioned in the last part of this paragraph is uncalled for. The defendant is not
liable to pay any compensation. In any event a nominal compensation of one paisa
would meet the ends of justice.
4. Para 4 is legal.
5. Para 5 is legal.
6. The suit is dismissed. In the circumstances of the case the defendant forgoes his
costs.

Defendant
VERIFICATION:
I, Jatin Yadav, do hereby verify that the contents from paras 1 to 6 are correct
and true to the best of my knowledge and personal belief and no part of it is false
and nothing material has been concealed therein.
Place: Varanasi Defendant
Date:18-04-2018

EXERCISE III
INTERLOCUTORY APPLICATION
Application under order 39 Rule 1 and 2
Application No: ______ of 2018
Sundarpur, Varanasi …………………………………………………..Applicant
Versus
Sundarpur, Varanasi ............................................................................Respondent
Application under order 39 Rule 1 and 2 of the Civil Procedure Code
Respectfully Sheweth:
1. That the applicant/plaintiff has filed a case before this honorable court hearing
where of will take some time.
2. That it is apparent from perusal of grounds and documents attached therewith

that the applicant has prima facie a very good case in his favour and the case is
likely to succeeds. The balance of convenience is in favour of the applicant. The
grounds of the case may be read as part of this application to save the repetition.
3. That the interest of justice demands that the respondent is restrained from
constructing any kind of construction or building whatsoever interfering and
disturbing the peaceful enjoyment usage and possession of the common pathways
in the area in any manner. In case the respondents are not restraining that the
applicant will suffer irreparable loss and injury which cannot be compensated in
terms of money and filing of this case will become infructuous.
4. It is therefore most respectfully prayed that the respondents be restrained from

constructing any kind of construction or building whatsoever interfering and
disturbing the peaceful enjoyment, usage and possession of the common pathways
in the area in any manner in the interest of justice. Such other orders be also
passed in favour of the applicant as deemed fit in facts and circumstances of the
case.

Varanasi
Applicant
______ Through, Advocate
Application No:______ of 2018
Sundarpur, Varanasi …………………………………………………..Applicant
Versus
Sundarpur, Varanasi ............................................................................Respondent
Affidavit in support of application under order 39 Rule 1 and 2 of the Civil

Procedure Code.
I, Rohit Singh, do hereby solemnly affirm and declare as under:-
1. That the accompanying application has been prepared under my instructions.
2. That the contents of paras 1 to 4 are true and correct to the best of my
knowledge.
3. That I further solemnly affirm and declare that the contents of this affidavit of
mine are correct and true to the best of my knowledge and no part of it is false and
nothing material has been concealed therewith.
Affirmed at Varanasi this ______.
Deponent.

EXERCISE IV
EXECUTION PETITION
IN THE HON’BLE COURT OF DISTRICT JUDGE, FARIDABAD
Execution application No…. /2018
In the matter of Suit, No……/2017
Karnataka Power Transmission Corporation ltd.

Tl & ss division,
KPTCL, Munirabad
Bellary District……………………………………………Decree Holders
Versus
Mr. Hamidulla
s/o Kamal khan
Kumrehera village,
Hatin taluk,
Faridabad district………………………………………...Judgment Debtor
Dated: 5th April,2018

The Decree Holder prays for the Execution of the Decree/order for the particulars
whereof are stated in the column hereunder: -
1. Suit Number : MVC No. 381 of 2011

2. Name of Parties : KPTCL TL & SS Division, Munirabad,
Bellary
Versus
Mr. Hamidulla, S/o Mr. Kamal Khan,
R/o Kumrehera Village, Faridabad
District

3. Date of Decree/Order of which
Execution is sought : 13.02.2017
4. Whether an appeal was filed against
the decree/order under execution : Not known
5. Whether any payment has been
received towards satisfaction of
decree/order : No
6. Whether any application was made
previous to his and if so their dated
and results : No
7. Whether any amount of suit : Decree of Rs.8,55,150/-
along with interest as per decree
or any order relief granted by
the degree with cost and interest @ 6%
p.a. from the date of complaint i.e.
31.03.2011 till the date of filing of this
petition.
8. Amount of costs if allowed by court : 623/-
9. Against whom execution is sought : Against the J.D.
10. Cost of copies : 50/-
11. Present execution cost : 50/-
12. In what manner courts assistance
is sought : (To be filled up)
The Decree Holder Most Humbly Prays:

That on 26.11.2016 at about 2 PM, the judgment debtor, driver of vehicle number
HR-55/F-1877, driving in a rash and negligent manner while proceeding towards
Bangalore, rammed against an electric tower at Line No. 121 in high speed, due to
which the said tower collapsed and fell down on the said vehicle.

That this accident damaged the adjacent towers at Line No. 120 and 122 as well,
interrupting the power supply for 15 days.
That as per the finding of the MACT-II, Bellary, the accident was proved to have
been caused due to rash and negligent driving of the said driver.
That after the said accident, the collapsed tower was separated from the said
vehicle by a crane at the cost of Rs. 40,000/-, paid by the decree holder.
That subsequently, tenders were called by the decree holder for construction of a
new tower replacing the collapsed tower.
That in furtherance of above construction/ replacement, a sum of Rs. 8, 31,150/-

was paid to S & P Structural Pvt. Ltd by the decree holder.
That the total expenditure incurred by the decree holder was calculated at Rs. 8,
71,150/- (Rs. 8,31,150 + Rs. 40,000/-).
That the scrap value of the collapsed tower, which was sold in a public auction,
being Rs. 16,000/- was deducted from the expenditure calculated and the final
amount reached by the Hon’ble MACT was Rs. 8, 55,150/-.
That on 13.2.2017, the Hon’ble MACT-II, Bellary awarded compensation of Rs.

8, 55,150/- with costs and interest at 6% p.a. from the date of petition to the date
of deposit in the Court against the judgment debtor.
That Execution Petition No. 140/2018 was subsequently filed before the Hon’ble
District Judge, Bellary, seeking transfer of decree dated 13.2.2017 passed by the
Hon’ble MACT-II, Bellary, to the Hon’ble District Judge, Faridabad, Haryana.
That on 6.02.2018, the Hon’ble MACT-II and District Judge, Bellary issued a
certificate of execution of decree and certificate of non-satisfaction of decree in
favour of decree holder in the Execution No. 140/2014 and ordered transfer of
decree for execution to Distt. Judge, Faridabad.

In view of the above said facts and circumstances it is, therefore, most
respectfully prayed that this Hon’ble Court may kindly be pleased to:
(To be filled)
pass such other and/or further order as this Hon’ble Court may deem fit and
proper in the facts and circumstances of the case.
Prayed accordingly.
SIGNATURE OF DECREE HOLDER

FARIDABAD:
THROUGH
DATED: COUNSEL
VERIFICATION: -
I, the above-named Decree Holder, do hereby verify that the contents of this
application are true to my knowledge and belief. Verified at Faridabad on this
April 2018
SIGNATURE OF DECREE HOLDER

EXERCISE V
AFFIDAVIT
Affidavit For Resumption Of Indian Citizenship
BEFORE THE DISTRICT MAGISTRATE, VARANASI, U.P
Affidavit of Mr. Rohit Singh aged about 43 years S/o Rajendra Singh, R/o A-21,
Laxmi Nagar, Sundarpur, Varanasi-221005
I, the above name deponent solemnly affirm and state on oath as under:
1. That the deponent has applied before your Honour for the resumption of Indian
Citizenship, and hence is fully conversant of the facts deposed below.
2. That the deponent was born in Sir Sundarlal Hospital on 2nd Day of March,
1974.
3. That the full Name of the father of deponent is Mr. Rajendra Singh.
4. That the deponent has ceased to be any Indian Citizen by virtue of sub section
(1) of Section 8 of the Indian Citizenship Act, 1955, on 1, Jan. 1980 because of
reason that the father of deponent Mr. MY has renounced his Indian Citizenship
on the said date.
5. That deponent declares his intention to resume Indian Citizenship and applied
to the Central Government to register this declaration.
Deponent
VERIFICATION
I, Rohit Singh, the above named deponent do hereby verify that the contents of
this affidavit form paras 1 to 5 are true to the best of my knowledge and belief.
Nothing material has been concealed.
Deponent

EXERCISE- VI
MEMORANDUM OF APPEAL
Memorandum of Appeal
In the Court of District Judge, Jabalpur

Civil Appeal No. ... / 2010
Under Section 96 of CPC, 1908.
Amrit Bhushan. S/o Birendra Bhushan.

12, Main Road, Rewa,
MP ......................................... Plaintiff/Appellant
Vs.
Manju Nath S/o OP Nath.

46, Main Road, Rewa,
MP .................................... Defendant/Respondent
Memorandum of Appeal
Sir,
The aforementioned plaintiff-appellant appeals against the judgement and

decree of the Court of Civil Judge Class II, at Jabalpur, passed in Original Suit
No 9687 of 2010 between Amrit Bhushan S/o Birendra Bhushan vs Manju
Nath S/o OP Nath., dated 01/02/2010, and sets forth the following grounds of
objection to the decree appealed from :-
Value of the suit:

Value of appeal:
Court Fee Paid:
(1) That the orders passed by the Learned Lower Court are contrary to the
provisions of law and the principles of natural justice.
(2) That the findings arrived by the Learned Lower Court are not supported by
the evidence on record.
(3) That the Learned Lower Court committed an error in holding that the
house premises are not required by the plaintiff/appellant for his personal
bonafide occupation.
(4) That the copy of the Judgment and the Decree against which this appeal

has been preferred is attached along with.
(5) That the Learned Lower Court has having answered the first issue in the
negative decided the rest of the issues against the appellant, which itself is
improper and illegal.
(6) That the necessary court fee is paid herewith.
Prayer:
(7) That the appellant, therefore, prays that for the reasons stated above and as
may be argued at the time of hearing, the record and proceedings be called for,
this appeal be allowed, the orders under appeal be set aside and quashed, and
orders deemed just and proper be kindly passed. Further that the cost of this
petition be awarded in favor of plaintiff-appellant.
Place: Jabalpur (Signature of

Date:
01/02/2010 Plaintiff/Appellant)
Advocate for Plaintiff- Appellant
Verification
I, Amrit Bhushan, do hereby verify that the contents from paras 1 to 5 are
correct and true to the best of my knowledge and personal belief and no part of
it is false and nothing material has been concealed therein. Affirmed at
Jabalpur this 1st Day of February 2010.
(Signature)
Plaintiff-Appellant

EXERCISE VII
MEMORANDUM OF REVISION
(MEMORANDUM OF REVISION)
IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD
Civil Revision Application No.......2017
A, S/o Z aged about 62 years

R/o Civil Lines,
Allahabad ...........Applicant/Defendant
Versus
B, S/o Y aged about 40 years
R/o Sangam,
Allahabad ........Opponent/Plaintiff
Civil Revision u/s 115 of C.P.C

To,
The Honourable Chief Justice
And the other Judges of the
Honourable Court.
The applicant named above humbly submits:

1) That the opponent had instituted a suit bearing No 71 of 2010 in the court of
Civil judge, Senior Division, Varanasi for recovery of Rs. 80000. On the ground
of a promissory note said to be due on the applicant after selling opponents shop
at Sigra at Varanasi road.
2) That the applicant submits that he had already paid Rs 700000 to the
opponent as a cost of the shop and no cost was due with regard to the said shop.
3) That the court decreed the said suit in the opponent on 28-04-2015 and
ordered the applicant to pay the amount of the decree to the opponent.
4) That the applicant being aggrieved by the said decree and judgement prefers
this application on the following ground:
a) That the decree and judgement passed by the learned judge is illegal and
unjust.
b) That the judgement of the learned judge is erroneous in law that by passing
the decree on a promissory note which was not stamped.
c) That the learned judge erred in holding that the promissory note was
executed by the applicant.
d) That the handwriting expert was not called inspite of the repeated request for
the applicant.

e) That the learned judge erred in not appreciating the evidence of the applicant
and his witnesses.
f) The in doing so, the learned judge in the exercise of the jurisdiction has
acted with illegality and a material irregularity.
g) That the said judgement is against justice, equity and good conscience and
therefore not substance in the court.
h) That in the aforesaid circumstances the applicant submits that the Hon'ble
court be pleased to call for the records of the trying court and revise its judgement
and decree in the interest of justice.
Date: 5/12/2017 X
Place: Applicant
Allahabad XX
Counsel for Applicant

EXERCISE VIII
WRIT PETITION UNDER ARTICLE 226

In the High Court of Judicature At Allahabad
Civil Original (Extra-ordinary) Jurisdiction
Civil Writ Petition No…………………… of 2018
In the matter of:
Rohit Singh S/o Rajendra Singh R/o A-21, Civil Lines, Allahabad, former
employee (Inspector Grade-I) in the Respondent Company ….Petitioner
1. XYZ Company Ltd., a company wholly owned by the Govt. of India and
having its registered office at Allahabad through its Chairman.
2. Managing Director of the above Company …Respondent
Civil Writ Petition against the order dated 12-02-2018 passed by the
Managing Director, respondent No. 2 herein, by which the services of the
petitioner as an employee of the respondent-company have been terminated.
May it please the Hon'ble Chief Justice of the High Court of Allahabad and His
Lordship's companion Judges.
The Petitioner
MOST RESPECTFULLY SHOWETH:
1. That the petitioner is a citizen of India and is therefore entitled to enjoy all the
rights guaranteed by the Constitution of India.
2. That respondent No. 1 is a company registered under the Companies Act, 1956
having its registered office at Allahabad
The respondent-company is wholly owned by the Government of India and is,

thus, an instrumentality of state is given in Annexure 12 of the Constitution.
3. That the petitioner was an employee of the respondent-company, having been

appointed as a Sub-Inspector Grade-I on 21-08-1991 and he continued to work,
earning one promotion also.
4. That on 11-07-2017 respondent No. 2 herein abruptly issued the impugned

order dated 28-09-2017 terminating the services of the petitioner and the
petitioner came to be relieved of his duties the same day. A copy of the impugned
order is annexed hereto and marked as ANNEXURE-1.
5. That on a bare reading of the impugned order it becomes clear that the order
has been issued on the basis of some alleged misconduct on the part of petitioner,
but no inquiry under the relevant rules has been held before the passing of the
order.
6. That the petitioner has not committed any act that could be termed to be an act
constituting misconduct.
7. The impugned order is being assailed on the following, amongst other,
GROUNDS
7.1 That the petitioner being a permanent employee of the respondent-company

his services could not be terminating without holding an enquiry under the rules
applicable to the employees of the company.
7.2 That the principles of natural justice have been contravened by the
respondents in not giving to the petitioner any opportunity of being heard.
7.3 That the impugned order is otherwise also erroneous and unsustainable, as it
does not contain any reason and is a non-speaking order.
7.4 That the impugned order is arbitrary and contravenes Article 14 of the
Constitution.
8. That the petitioner has not filed any petitioner other proceedings relating to the
matter at this petition in any other court.
PRAYER
In the facts and circumstances stated above the petitioner prays that a direction in
the form of a writ of quo warranto and mandamus or any other appropriate writ be
issued quashing the impugned order and reinstating the petitioner in service with
all consequential benefits including back wages.
It is further prayed that the respondent be burdened with costs.
PETITIONER
THROUGH
DATED: 22-03-2018 COUNSEL MR…………………..

CRIMINAL PLEADING
EXERCISE IX
WRIT PETITION UNDER ARTICLE 32

IN THE HON’BLE SUPREME COURT OF INDIA, NEW DELHI
(Original Criminal Jurisdiction)
Writ Petition No. __________of _________20 _________
A ____ aged about ____ son of _____., resident _____ …Petitioner
Versus
1. Additional Secretary, Ministry of Finance,
Government of____.
2. The Superintendent, ____Jail ____
3. The State of_____ …Respondent
PETITION FOR THE ISSUE OF WRIT OF HABEAS CORPUS UNDER

ARTICLE 32 OF THE CONSTITUTION OF INDIA
To
The Hon’ble the Chief Justice and his companion Judges of the Court
aforesaid.
The humble petition of the above named Petitioner most respectfully sheweth:
1. That the petitioner is a resident of _____. and he was living peacefully at his
residence at the place aforesaid.
2. That on _____. Respondent No. 1 made an order under Section 3 of the

Conservation of Foreign Exchange and Prevention of Smuggling Activities
Act, 1974 by which he directed that the Petitioner shall be arrested and
detained for a period of three months. A copy of the order is annexed herewith
as Annexure ‘‘A’’.
3. That the Petitioner was arrested the same day and was detained in
_____Jail. The grounds of detention were not supplied to the petitioner on that
day. The grounds were actually supplied on_____. A copy of the grounds
supplied is annexed herewith as Annexure ‘‘B’’.
4. That on _____. the Petitioner submitted a representation against his

detention through Respondent No. 2 but the same was considered by the
Advisory Board after one month and was rejected on ____.
5. That the grounds of detention supplied to the Petitioner were in English

which language the Petitioner does not know.
6. That the orders of detention of the Petitioner are illegal, improper and
without jurisdiction on the following:
GROUNDS
1. Because the Conservation of Foreign Exchange and Prevention of

Smuggling Activities Act, 1974, is unconstitutional and void as it is beyond
the legislative competence of Parliament.
2. Because the order has been passed by an officer not duly authorized.
3. Because the grounds were supplied after undue delay.
4. Because the grounds are in English which language the Petitioner does not
know and this has prevented him from making an effective representation.
5. Because the grounds are irrelevant to the object of the Act.
6. Because the grounds are vague.
7. Because there was undue delay in the disposal of the representation

submitted by the petitioner.
Wherefore it is respectfully prayed that this Hon’ble Court may be pleased to

issue a writ in the nature of Habeas Corpus to the opposite parties quashing the
order of detention and directing that the Petitioner be set at liberty forthwith.

Date _________ Advocate for the Petitioner.

EXERCISE X
CRIMINAL COMPLAINT
CRIMINAL COMPLAINT U/S 494 R/W SEC. 34 OF THE INDIAN PENAL
CODE
IN THE COURT OF THE JUDICIAL MAGISTRATE, FIRST CLASS,

(ANTI-CORRUPTION COURT), PUNE AT PUNE
Criminal Complaint No. Smt. .... D .... A .... S...., )
age 25 years, occupation - service, ) Complainant
resident of C/o.Shri DAD, 175 Kothrud, )
PUNE 411 029. )
Versus
1.Shri .... D .... A .... M ...., )
■
age 30 years, occupation - business, )
2. Smt. .... D .... A .... B ...., ) Accused
age 55 years, occupation - household, )
3. Smt. .... D .... A R, )
age 20 years, occupation - education, )
all residents of 320 Erandwana, )

PUNE 411 004. )
A COMPLAINT U/S 494 R/W SEC. 34 OF THE INDIAN PENAL CODE
The complainant above-named submits this complaint, praying to

state as follows:
1. That the complainant is the legally wedded wife of the accused No. 1,
while the accused No. 2 is the mother and the accused No. 3 is the
second wife of the accused No. 1.
2. That the complainant was married to the accused No. 1 at Pune on
according to the Hindu religion, vaidic rites and ceremonies.
3. That before the marriage, the complainant was known by her maiden
name as Kumari Lata, and likewise, the accused No. 3, before this
second marriage, was also' known by her maiden name as Pata.
4. That after the marriage, the complainant and the accused No.
1 cohabited together for about three years. However, during
the existence of their marriage, this complainant could not beget a
child, and hence, on that count, the accused Nos. 1 and 2 were
nervous and unnecessarily offended for no fault on the part of this
complainant.
5. That this complainant submits that last year, in the month of
June, the accused No. 1 told this complainant that she should
better go to her parents', at least, for a few days for a medical
check-up, and under that pretext, she was sent to stay with her
parents.
6. That, thereafter, the complainant No. 1 did not either come to
take back for cohabitation, nor allow her to do so, and thus, the
accused No. 1 has deserted this complainant.
7. That this complainant learnt from very reliable sources that
the accused No. 1 is going to contract marriage on with the
accused No. 3 at the remote place near Katraj, and the ceremony
was fixed to be carried out in a bungalow of one, Shri XYZ.
8. That accordingly, this complainant lodged a report with
the Sahakarnagar Police Station, requesting them to help this
complainant, and the police did try to do so, but they could not
register the offence committed by the accused for the reason
that the venue of the marriage was changed.
9. That, however, this complainant could know the changed
venue, and she collected all the details with a view to registering
the said offence.
10. That this complainant states and submit that the said
second marriage between the accused Nos. 1 and 3 was
celebrated in the Ganesh Mandir, one km away from Katraj, which
took place on ......at 6.00 p.m., and about 100 people were
present for the said marriage.
11. hat while celebrating the said marriage between the accused
Nos.1 and 3, all the religious ceremonies and rites were
performed.
12. That the cause of action for this complaint first arose
on……. and hence, this complaint filed today is well within
limitation.
13. That the offence has been committed within the local limits of the

jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to
try and decide this complaint.
14. That the necessary court -fee is paid herewith.
15. That the complainant, therefore, prays that the accused be kindly
charged with and tried for the offence punishable u/s 494 R/W Sec. 34
of the Indian Penal Code and punished according to law.
Pune, Sd/- DAS

COMPLAINANT
Dated :
Sd/- x X x
ADVOCATE FOR COMPLAINANT
VERIFICATION
I, Smt. DAS, the present complainant, do hereby state on solemn
affirmation that the contents of this complaint in paras 1 to 15 are
true and correct to the best of my knowledge and belief, and so I have
signed hereunder.
Sd/- DAS
COMPLAINANT

EXERCISE XI
CRIMINAL MISCELLENEOUS PETITION
IN THE COURT OF SECOND ADDL. JUDICIAL MAGISTRATE OF SATNA
CR.L.M.P.NO. OF 2012 M.C.No. ____/2011
Dhanarekha …Petitioner
Vs.
Arun Kumar ... Respondent
Petition filed on behalf of the Petitioner U/Sec 128 Cr. P.C
(1) The petitioner submits that he filed the above M.C. for grant of separate
maintenance on 31.12.2011 against the respondent seeking a sum of Rs. 500 per
month to be awarded.
(2) The Honourable Court, after due contest, by order dated 06.01.2012 granted
maintenance to the petitioner directing the respondent to pay a sum of Rs. 400 per
month to the petitioner from 01.01.2012 and keep praying in future.
(3) The petitioner submits that, the respondent has not paid any maintenance so
far, and these disobeyed the order of this honourable court.
(4) The petitioner further submits that the arrears of maintenance from 01.01.2011
to 31.03.2012 to Rs. 6000/-
(5) It is therefore prayed that the honourable court may be pleased to commit the
respondent to prison for such kind has the law required or till he paid the arrears
of maintenance.
Xxxx xxxx

Advocate for the Petitioner Petitioner
VERIFICATION
I, the petitioner, to hereby declared that the facts stated above or true and correct
to the facts stated above or true and correct to the best of my knowledge
information and belief.
Date: xxxxxx
Petitioner

EXERCISE XII
ANTICIPATORY BAIL
IN THE COURT OF DISTRICT AND SESSIONS JUDGE, AT VARANASI
IN THE MATTER OF
STATE
VS
Police Station Lanka
FIR No. Yet to be filed
U/S Section 66A of ITA 2008 and other sections of IPC such as 295A,505,499
APPLICATION U/S 438 CRPC FOR GRANT OF ANTICIPATORY
BAIL ON BEHALF OF THE ACCUSED Ratan Lal.
MOST RESPECTFULLY SUBMITTED AS UNDER :-
1. That I, Shri Ratan Lal s/o Mohan Lal
residing at Ambrosia Apartments, Lanka, Varanasi,
have posted the content as indicated in annexure to this application
2. That based on the precedents of the actions initiated by Police in
different parts of the country in recent days and more particularly in
the cases of Government of Puducherry Vs Ravi Srinivasan on the
complaint made by one Sri Karti Chidambaram and State of
Maharashtra VsMsShaheenDadha on the complaint of one Sri
BhushanSanke, there is a reasonable probability of a false and
bogus case being hoisted on me with malafied intentions,
3. That I have no malicious intentions in making this post which I have

made as a free Citizen of India under the Freedom of Expression
guaranteed to me by the Constitution of India under article 19(1)
4. That the police may falsely implicate the applicant in any case,
the applicant is a respectable citizen of the society and is not involved
any criminal
5. That the postings does not constitute any criminal offence under
any law in India.
6. That the applicant is not required in any kind of investigation
nor any kind of custodial interrogation is required.
7. That the applicant is having very good antecedents, he belongs
to good family and there is no criminal case pending against them.
8. That the applicant is a permanent resident and there are no
chances of their absconding from the course of justice.
9. That the applicant undertakes to present himself before the
court as and when directed.
10. That the applicant undertakes to cooperate with the police
during the course of investigation.
11. That the applicant undertakes not to tamper with the evidence
or the witnesses in any manner.
It is therefore prayed that the court may direct that the applicant shall be
released on bail in the event of their arrest by the police.
Any other order which the court may deem fit and proper in the facts and
circumstances of the case may be also passed in favor of the applicant.

(-----------------------------)
APPLICANT

EXERCISE XIII
BAIL APPLICATION
Bail Application
IN THE COURT OF BASTI

Criminal Miscellaneous Application No...... of 2015
Devi Lal, D/o Sukhdev aged about 56 years, R/o N8/162 Rajendra vihar, Basti
……Applicant
Versus
Shyam Singh, S/o Ajay Singh aged about 60 years, R/o R-13/A, Rajendra vihar,
Basti …Respondent
FIR No. : _____ Dated _____ Police Station:Mankapur
Offence Under Sections: 323 and 325 of IPC
Application under Section 437 of CrPC for the grant of Bail
Respectfully Showeth:
1. That the applicant has been involved in a false and frivolous case by one Will
Smith by lodging a complaint with the SHOPS for offence under sections 323 and
325 of the IPC. The applicant/accused has been arrested by the Police of Police
Station: Mankapur subsequent to the above complaint.
2. That it is submitted that the allegations made against the applicant/accused are
false, frivolous and vexatious and lack in the material substance. The applicant
belongs to a very reputed family in his locality.
3. That the applicant/accused is a permanent resident of Basti and earning

livelihood by business. The applicant has his old parents dependent upon him and
the applicant is the only bread earner for the family.
4. That the applicant/accused is innocent and has been involved falsely due to the
personal grudge to settle the score against the applicant/accused OR due to enmity
and family feud. It is submitted that the complainant is an influential and high-
handed person.

5. That by getting the applicant/accused arrested the applicant has been deprived
of his valuable fundamental right of liberty by abuse of powers and process of law
by the complainant.
6. That the applicant is willing to furnish surety and bail bonds to the satisfaction
of this learned court in case he is ordered to be released on bail. The applicant is
also willing to join the investigations and bind himself by the terms and
conditions laid down by the law or by this Hon'ble court. It is further submitted
that the applicant is not at all required for the investigations. However, if the
applicant is required for investigation, the applicant/accused undertakes to be
present as and when required in accordance with the law.
7. That neither any recovery is to be effected from the applicant nor the applicant
is in a position to temper with the prosecution evidence. The applicant will
associate with the investigation whenever required to do so.
It is, therefore, most respectfully prayed that:-
(a) That the applicant may be ordered to be released on bail and this application
for bail may kindly be allowed;
(b) That till the decision of this application interim bail may be granted to the
applicant;
(c) That the directions may be issued to the police to get the applicant/accused
medically examined at the immediately;
(d) Such other orders be also passed in favour of the applicant as deemed fit and
proper in the facts and circumstances of the case and in the interest of justice.
Applicant
Through, Advocate
Dated: 31.10.2015

Affidavit in Support
IN THE COURT OF BASTI
Devi Lal, D/o Sukhdev aged about 56 years, R/o N8/162 Rajendra vihar, Basti
……Applicant
Versus
Shyam Singh, S/o Ajay Singh aged about 60 years, R/o R-13/A, Rajendra vihar,
Basti ……Respondent
Affidavit in support of the application under Section 437 of CrPC
I, ______, do hereby solemnly affirm and declare as under:-
1. That the accompanying application under section 437 CrPC has been drafted at
my instance and under my instructions.
2. That the contents of paras 1 to 7 are true and correct to the best of my
knowledge.
3. That I further solemnly affirm and declare that this affidavit of mine is correct
and true, no part of it is false and nothing material has been concealed therein.
Affirmed here at Basti on 31.10.2015

EXERCISE XIV
CRIMINAL APPEAL
IN THE COURT OF THE DISTRICT AND SESSIONS JUDGE AT

VARANASI
CRIMINAL APPEAL NO: 101 OF 2010
For the following among grounds the Appellant here in begs to prefer this appeal
against the judgement dated ………………….. of judicial Magistrate, F.C.,
Varanasi in criminal case No: 101 of 2010, convicting the appellant U/Sec 411
I.P.C and sentencing him to U/go, 6 months R.I. and to pay a fine of Rs. 300/-
GROUNDS
1. That the conviction is bad in law.

2. That the Judgement of the lower court offends Sec. 367 of the Cr.P.C.
3. That the learned magistrate should have inferred from the conduct of your
petitioner deposed to by the investigating officer, that he was absolutely straight
forward in his dealings. The conduct of your petitioner as has been deposited to
by P.Ws. No. 52 and 4 would hardly be consistent with his guilty knowledge.
4. That the learned Magistrate should have taken into accent the representation
made to him by the alleged thief.
5. That the learned Magistrate should have bellered that the articles were
purchased bonafide for proper market price and inferred from that the absence of
any guilty knowledge of your petitioner.
6. That the articles sold were common articles of everyday use to be found in
possession of people of even modest means.
7. That the learned Magistrate should have disbelieved the evidence of P.W.s No:
56 and 7 who identified the parker pen and the Wallet alleged to belong to Sri
Anand and should have hold that they were ordinary, common articles incapable
of identification in the absence of any special mark or name.
8. That the learned Magistrate should have believed the defence witnesses who
disposed to having seen the articles sold to the appellant some five months prior
to the incident.
9. That the Lower Court ought to have given the benefit of responsible doubt to
the appellant and acquitted him.
PRAYER
In the circumstances stated above, the petitioner prays that your honour may be
pleased to admit the appeal, call for the record.

Release your petitioner pending disposal of the appeal on bail and after hearing
the case, set aside the order of conviction and sentence or pass such other order as
the ends of Justice may call for and your petitioner, as in duty bound, shall ever
pray.
________________ _______________
Counsel for Applicant Applicant

EXERCISE XV
FIRST INFORMATION REPORT
First Information Report
(Under Section 145 & 157 Cr.P.C.)
1. Chittoor District, Tiruchanoor Police, 2014, FIR No. 102, Date: 15-04-2014
2. (i) Act ………………………….. Sections : ……………………………
(ii) Act ………………………….. Sections : ……………………………
(iii) Other Acts & Sections: ……………………………………………
3. (a) Occurrence of Office: March, 31st, Monday, Night between 10.30 to 11.00
pm
(b) Information received from B. Ajay Kumar and K. NareshBabu at the Police
Station about 11.25 pm, 31st March, 2014.
(c) General Diary Reference Entry No(s): 42, Time: 11.30 pm 31st March, 2014.
4. Type of Information : Written/ Oral
5. (a) Place of Occurrence : Tiruchanoor Road, Near Mango Mandi, Varanasi.
(b) Address: Srinivasapuram, Tiruchanoor Road, Varanasi-517 503
Varanasi Rural, Tiruchanoor Police Station Limits.
6. Complainant/ Informant
(a) Name: B. Ajay Kumar,
(b) Father‟s Name: B.K. Rao
(c) Date/ Year of Birth: 24-10-1994
(d) Nationality: Indian
(e) Passport No ………. Date of issue………… Place of issue ……….
(f) Occupation: Business

(g) Address: Telephone Colony, SrinivasaPuram, Varanasi.
35
7. Details of known/ suspected/ unknown/ accused with full particulars. (Attach

separate sheet if necessary)
…………………………………………………………….
8. Physical features deformities and other details of the suspect:

……………………………………………………………………
9. Contents of the Complaint/ Statement of the complainant or informant (Attach

separate sheets, if required).
10. Action taken. Since the above report reveals commission of offence (s) u/S as
mentioned at Item No. 2 Registered the case and took up the investigation/
directed ……………… Rank ……………… to take up the investigation FIR read
over to the Complainant/ Informant, admitted to be correctly recorded and a copy
given to the Complainant/ Informant free of cost.
Signature of the Officer-in-charge Police Station

__________________
Tiruchanoor Police Station, Varanasi.

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CIVIL PLEADINGS

ORDER-6, RULE-17, SECTION-26

In the court of the Junior Civil Judge at Varanasi

O.S No. ____/2018

Suit for recovery of Rs. 500 as compensation for trespass

The plaintiff begs to submit as under:

1. DRAFTING, PLEADING AND CONVEYANCING

Counsel for Plaintiff Plaintiff

Verified at Varanasi on the 23rd day of April 2018.

2. DRAFTING, PLEADING AND CONVEYANCING

Verified by me at Sundarpur, Varanasi on 23rd April, 2018

3. DRAFTING, PLEADING AND CONVEYANCING

IN THE COURT OF THE JUNIOR CIVIL JUDGE AT VARANASI

Civil suit no. ____/2018

Written Statement on behalf of the defendant

The defendant most respectfully-

4. DRAFTING, PLEADING AND CONVEYANCING

Place: Varanasi Defendant

5. DRAFTING, PLEADING AND CONVEYANCING

IN THE COURT OF THE JUNIOR CIVIL JUDGE AT VARANASI

Application No: ______ of 2018

Application under order 39 Rule 1 and 2 of the Civil Procedure Code

2. That it is apparent from perusal of grounds and documents attached therewith

4. It is therefore most respectfully prayed that the respondents be restrained from

6. DRAFTING, PLEADING AND CONVEYANCING

______ Through, Advocate

IN THE COURT OF THE JUNIOR CIVIL JUDGE AT VARANASI

Application No:______ of 2018

Affidavit in support of application under order 39 Rule 1 and 2 of the Civil

I, Rohit Singh, do hereby solemnly affirm and declare as under:-

1. That the accompanying application has been prepared under my instructions.

Affirmed at Varanasi this ______.

7. DRAFTING, PLEADING AND CONVEYANCING

Karnataka Power Transmission Corporation ltd.

Dated: 5th April,2018

1. Suit Number : MVC No. 381 of 2011

8. DRAFTING, PLEADING AND CONVEYANCING

The Decree Holder Most Humbly Prays:

9. DRAFTING, PLEADING AND CONVEYANCING

That in furtherance of above construction/ replacement, a sum of Rs. 8, 31,150/-

That on 13.2.2017, the Hon’ble MACT-II, Bellary awarded compensation of Rs.

10. DRAFTING, PLEADING AND CONVEYANCING

SIGNATURE OF DECREE HOLDER

SIGNATURE OF DECREE HOLDER

11. DRAFTING, PLEADING AND CONVEYANCING

BEFORE THE DISTRICT MAGISTRATE, VARANASI, U.P

12. DRAFTING, PLEADING AND CONVEYANCING

In the Court of District Judge, Jabalpur

Amrit Bhushan. S/o Birendra Bhushan.

Manju Nath S/o OP Nath.

The aforementioned plaintiff-appellant appeals against the judgement and

Value of the suit:

13. DRAFTING, PLEADING AND CONVEYANCING

(6) That the necessary court fee is paid herewith.

Place: Jabalpur (Signature of

Advocate for Plaintiff- Appellant

14. DRAFTING, PLEADING AND CONVEYANCING

IN THE HIGH COURT OF JUDICATURE AT ALLAHABAD

Civil Revision Application No.......2017

A, S/o Z aged about 62 years

Civil Revision u/s 115 of C.P.C

The applicant named above humbly submits:

15. DRAFTING, PLEADING AND CONVEYANCING

16. DRAFTING, PLEADING AND CONVEYANCING

Writ Petition No. ______of _20 _____

A __ aged about son of _., resident ___ …Petitioner

2. The Superintendent, Jail