IN THE COURT OF THE LEARNED DISTRICT JUDGE, LAHORE

Suit No. ____/20

[Plaintiff]
… Plaintiff

Versus

[Defendant]
… Defendant

SUIT UNDER ORDER XXXVII CPC FOR RECOVERY OF AMOUNT

RESPECTFULLY SHEWETH:

1. That the Plaintiff entered into a transaction with the Defendant involving the sale and purchase of property files through a real estate intermediary. Subsequently, both parties mutually agreed to revised terms, whereby the Defendant undertook to refund a partial amount of the transaction and to transfer a limited number of files in favor of the Plaintiff.

2. That in pursuance of the said understanding, the Defendant issued a cheque in favor of the Plaintiff, which was drawn on a commercial bank. The issuance of the cheque was duly acknowledged by both parties in writing and witnessed by third parties.

3. That the Plaintiff presented the said cheque for encashment on multiple occasions, but the cheque was dishonoured due to insufficient funds in the Defendant’s account. The Plaintiff was verbally informed by the bank officials that the cheque could not be honoured.

4. That the Plaintiff lodged a formal complaint with the relevant law enforcement authorities, and criminal proceedings were initiated against the Defendant.

5. That despite repeated verbal and written requests by the Plaintiff, the Defendant failed to make payment of the outstanding amount and continued to make false assurances, thereby willfully avoiding repayment.

6. That a legal notice was issued by the Plaintiff through counsel, demanding payment of the outstanding sum, but the Defendant did not respond or comply with the same.

7. That the cause of action arose when the cheque was dishonoured and continues to accrue with each failure or refusal by the Defendant to fulfill his legal obligation.

8. That this Honourable Court has jurisdiction to adjudicate upon the matter as the relevant transaction, issuance of cheque, and residence of the parties all fall within its territorial limits.

9. That the value of the suit for purposes of jurisdiction and court fee is the amount sought to be recovered. The requisite court fee is affixed with the plaint.

PRAYER

In view of the above, it is respectfully prayed that this Honourable Court may graciously be pleased to:

a) Decree the suit in favor of the Plaintiff for the recovery of the amount along with interest at the prevailing bank rate till realization;
b) Award costs of the suit;
c) Grant any other relief deemed just and appropriate under the circumstances.

Plaintiff
Through Counsel

[Name of Advocate]
[Designation]
[Law Firm, if any]

VERIFICATION

Verified on oath at Lahore this ___ day of ____, 20 that the contents of paragraphs 1 to 5 are true and correct to the best of my knowledge, and those of paragraphs 6 to 9 are true and correct to the best of my information and belief.

Plaintiff