Affidavit - PETITION FILED BY THE PETITIONER UNDER SECTION 20 OF ORDER 40 - AFFIDAVIT BEFORE THE __ TRIBUNAL FOR STAY OF DISPUTED TAX - PETITION FILED BY THE PETITIONER UNDER SECTION 20 OF ORDER 40 - RECOVERY SUIT – APPLICATION AFFIDAVIT

Category: Civil Law Documents

Updated: 2026-05-13T06:52:33.41118+00:00

Collection of legal affidavit templates for various cases

RECOVERY SUIT – APPLICATION AFFIDAVIT IN THE COURT OF HON’BLE _____________ Civil suit No. ____ of _____ Year M/s ____________________________ Address _______________________ … Plaintiff Versus M/s ______________________ Address _______________________, Principal occupier … Defendant SUIT FOR RECOVERY OF RS ________/- ALONGWITH INTEREST Court Fee paid Rs. ______/- RESPECTFULLY SHOWETH: 1. That the plaintiff is a company under the name and style of M/s _________________________ and Mr. ______________ through whom the present suit is being instituted is the ___________________ of the plaintiff company. The plaintiff has authorized him vide Resolution dated __________. He is fully competent to engage the counsel, sign the vakalatnama, plaint, application for stay, affidavit, applications, etc. , to depose before this Hon’ble court and to do such other acts, deeds, and things.

The copy of the Resolution is enclosed as Annexure –A. 2. That the plaintiff is engaged in the business of _______________________________. 3. That during the course of business with the defendant the plaintiff has done _____________________________. An agreement to this effect was executed between the plaintiff and the defendant on _____________. The plaintiff did the job work to the satisfaction of the defendant. During the course of business, the plaintiff issued proper bills to the defendant, which were accepted and acknowledged by the defendant. The copy of the Bill is enclosed as Annexure –B. 4. That as per the statement of account maintained by the plaintiff the balance amount of Rs. ________/- is outstanding against the defendant as on ______________ after receiving the last payment of Rs. ___________/- on ________________.

The photocopies of the Agreement and statement of account are enclosed. 5. That as per the terms and conditions of the Agreement the defendant have to make the payment of ___% on the delivery of the ____________, which was supplied to the defendant in time but the payment was not made by the defendant upto ____________. Thereafter, so many requests were made to the defendant to make the payment so that the work could be done in time, but the defendant failed to make the payment. It is not out of place to mention here that the work was delayed due to a reason known to the defendant. The defendant violated the terms and conditions of the Agreement. 6. That the account of the defendant became irregular and, despite repeated requests and demands, the defendant failed to regularize their account and also failed to make the payment in time. 7.

That the plaintiff requested the defendant several times to make the payment of the outstanding amount, which is lying against them, but the defendant, on one pretext or another, avoided the legitimate requests of the plaintiff without any cause or reason, and has stopped the payment of the plaintiff. 8. That the account of the defendant became irregular, and despite repeated requests and demands, the defendant failed to regularize their account, and also failed to make the payment in time. 9. That the plaintiff was induced by the defendant to believe in making false representations that they would honour the payment on receipt of the invoice, but the plaintiff realized later that the intentions of the defendant were not clear and became decisive. 10. That the defendant fraudulently and dishonestly induced the plaintiff to deliver their property and caused wrongful loss. 11.

That as per the initial terms and conditions settled with the defendant by the plaintiff, the plaintiff is entitled to interest @ ___% per annum. 12. That plaintiff served a legal Notice dated ____________ through registered post upon the defendant calling upon them to make the payment. 13. That the cause of action to file the present suit accrued on each and every date when the plaintiff requested the defendant to make the payment. 14. That the present suit being filed is the first suit, and no such suit has been previously filed. 15. That this Hon’ble court has jurisdiction to entertain and try the present suit. 16. That the value of the suit for the purposes of court fee and jurisdiction is assessed at Rs. ____________/-. PRAYER: (i) Decree for recovery of Rs. ________/- alongwith interest @ __% per annum. (ii) Costs of the suit. (iii) Any other relief deemed fit.

PLAINTIFF Through Counsel: _________, Advocate, ___________ VERIFICATION: Verified that the contents are true and correct. Verified at __________ on __________ PLAINTIFF