How to Draft a Plaint under CPC: From Facts to Final Prayer | EduLaw
EduLaw EditorialAdvocate PlaybookA practical, India-specific guide on how to draft a plaint under CPC — Order 7 Rule 1 contents, Order 7 Rule 11 rejection, cause of action, jurisdiction, limitation, court fee, prayer and a full annotated sample plaint format for recovery and specific performance suits.
EL EduLaw Indian Law, Made Practical Basics Anatomy Sample Plaint Checklist FAQ Home › Blog › How to Draft a Plaint under CPC Civil Litigation · Drafting How to Draft a Plaint under CPC: From Facts to Final Prayer A chambers-style walkthrough of how a plaint is actually drafted in Indian civil practice — how to turn a client's messy facts into a legally sound plaint that survives the registry and an Order VII Rule 11 CPC objection. For juniors & litigation interns By EduLaw Editorial · Updated 28 June 2026 · ~28 min read On this page ▾ On this page What a plaint is Facts vs evidence Order VI principles Order VII Rule 1 contents Plaint anatomy (interactive) Cause of action Order VII Rule 11 rejection Jurisdiction Limitation check Valuation & court fee Relief & prayer Documents (O.VII R.14) Verification (O.VI R.15) Flowchart & timeline Annotated sample plaint Registry objections Common mistakes Do / Don't table Senior advocate checklist FAQ Read this first. This article explains general civil practice under the Code of Civil Procedure, 1908 (CPC) as applicable across India up to 28 June 2026. Court fee, valuation, e-filing and local registry rules vary from State to State and from court to court (each High Court has its own Original Side / civil rules and many States have their own Court-Fees and Suits Valuation Acts). Always cross-check the rules of the actual court where you are filing. This is educational material, not legal advice on any specific matter. Part 01 What is a plaint under CPC A plaint is the first pleading filed by a plaintiff; it is the document that institutes a civil suit. The CPC does not contain a definition of "plaint", but Section 26 says every suit shall be instituted by the presentation of a plaint, and its mandatory contents are prescribed by Order VII Rule 1 CPC . A plaint is a "pleading" within the meaning of Order VI Rule 1 CPC , which defines pleading as a plaint or a written statement. Think of the plaint as doing three jobs at once: it tells the court why it has the power to hear the matter (jurisdiction), it tells the court what wrong was done and when (the facts constituting the cause of action), and it tells the court what order the plaintiff wants (the relief/prayer). If any one of these legs is weak, the plaint wobbles — and the defendant will exploit it through an Order VII Rule 11 application. One-line working definition for juniors: A plaint is a verified statement of the material facts that give the plaintiff a present, enforceable right against the defendant, presented to a court that has jurisdiction, within limitation, on proper court fee, asking for specific relief. Part 02 Pleading facts vs arguing evidence — the line every junior must learn The single most common drafting error is mixing up facts with evidence and argument . Order VI Rule 2 CPC is categorical: every pleading shall contain a statement in a concise form of the material facts on which the party relies, but not the evidence by which those facts are to be proved. So in the plaint you state what happened (a fact). You do not reproduce the witness's exact words, attach the lab report's reasoning, or argue the law. The proof comes later — through documents, affidavits of evidence and cross-examination. Evidence / argument (wrong place) "The defendant is clearly a habitual cheat, as PW-1 Mr. Rao will depose that he heard the defendant boast about not paying, and the handwriting expert's report at page 4, paragraph 3, proves the signature is genuine because the loops match…" Material fact (right place) "On 12.03.2024, the defendant executed a written agreement (Document No. 1) agreeing to pay ₹8,00,000 by 12.06.2024. Despite the agreed date having passed and a legal notice dated 20.06.2024 (Document No. 4), the defendant has failed and neglected to pay the said sum." Rule of thumb: if a sentence answers "what happened?" it is a fact and belongs in the plaint. If it answers "how will you prove it?" or "why should the court agree with you?" , it is evidence or argument and does not. Part 03 Order VI CPC — the principles that govern all pleadings Before touching Order VII, internalise Order VI. These principles decide whether your plaint is professionally drafted or amateur: Order VI Rule 2 — plead only material facts, in a concise form, not the evidence. Paragraphs to be numbered consecutively; dates, sums and numbers in figures and words. Order VI Rule 4 — wherever you plead misrepresentation, fraud, breach of trust, wilful default or undue influence, you must give full particulars with dates and items . Vague allegations of fraud are routinely struck down. Order VI Rule 6 — any condition precedent that you have performed need only be averred; non-performance by the other side must be specifically pleaded. Order VI Rule 9 — the effect of a document may be stated; you need not set out the whole document verbatim. Order VI Rule 14 — every pleading must be signed by the party and its pleader. Order VI Rule 15 / 15A — verification (and, in commercial suits, a Statement of Truth). Covered in detail below. Order VI Rule 17 — amendment of pleadings — the safety valve when something is missed, subject to the proviso that post-trial amendments are allowed only if the matter could not have been raised earlier with due diligence. Why "material facts" is the magic phrase — read this A material fact is one which, if not proved, would defeat the right claimed. The classic test: omit the fact and ask whether the cause of action survives. If it does not, the fact was material and must be pleaded. Facta probanda (the facts in issue) go into the plaint; facta probantia (the facts that prove them) are evidence and stay out. Practically, this is why a money-recovery plaint must plead the date of the contract, the amount, the due date and the default — drop any one and the cause of action collapses. The interest rate calculation worksheet, by contrast, is supporting material, not a material fact. Part 04 Order VII Rule 1 CPC — mandatory contents of a plaint This is the checklist the registry will run against your plaint. Under Order VII Rule 1 CPC , a plaint shall contain: Order VII Rule 1 CPC — particulars every plaint must contain Clause What it requires Where it sits in the plaint (a) The name of the court in which the suit is brought Court heading (b) The name, description and place of residence of the plaintiff Cause title / party description (c) The name, description and place of residence of the defendant, so far as can be ascertained Cause title / party description (d) Where the plaintiff or defendant is a minor or of unsound mind, a statement to that effect Party description (e) The facts constituting the cause of action and when it arose Material facts + cause of action paragraph (f) The facts showing that the court has jurisdiction Jurisdiction paragraph (g) The relief which the plaintiff claims Prayer clause (h) Where the plaintiff has allowed a set-off or relinquished a portion of the claim, the amount so allowed/relinquished Body / valuation paragraph (i) A statement of the value of the subject-matter for the purpose of jurisdiction and of court fees, so far as the case admits Valuation & court fee paragraph Two related rules sit beside Rule 1 and are equally mandatory in practice: Order VII Rule 7 (the relief must be stated specifically , simply or in the alternative) and Order VII Rule 11 (rejection — the consequence of getting Rule 1 wrong). Part 05 · Interactive Plaint Anatomy — click each part Tap any component below to see what it does and how to get it right. Court Heading O.VII R.1(a) Cause Title Parties & array Party Description O.VII R.1(b)(c)(d) Jurisdiction ¶ O.VII R.1(f) Material Facts O.VI R.2 Cause of Action O.VII R.1(e) Limitation ¶ Limitation Act 1963 Valuation & Fee O.VII R.1(i) Prayer O.VII R.7 List of Documents O.VII R.14 Verification O.VI R.15 Signature Block O.VI R.14 Click a component above to read what it does, the governing rule, and the typical mistake. Part 06 Cause of action — the heart of the plaint A cause of action is the bundle of material facts which the plaintiff must prove to succeed . It is not the relief, not the evidence, and not the law — it is the set of facts that, taken together, give rise to an enforceable right. If even one essential fact in that bundle is missing, the plaint does not disclose a cause of action and is liable to be rejected under Order VII Rule 11(a). Liverpool & London S.P. & I. Association Ltd. v. M.V. Sea Success I & Anr. , (2004) 9 SCC 512 (Supreme Court of India) — Whether a plaint discloses a cause of action is to be decided by reading the plaint as a whole, assuming the averments to be correct; the question is one of fact to be gathered only from the plaint and the documents accompanying it, not the defence. T. Arivandandam v. T.V. Satyapal & Anr. , (1977) 4 SCC 467 (Supreme Court of India) — If "clever drafting has created the illusion of a cause of action", the court must nip it in the bud at the first hearing. A meaningless, vexatious plaint masquerading as a genuine cause must be thrown out. Dahiben v. Arvindbhai Kalyanji Bhanusali (Gajra) , (2020) 7 SCC 366 (Supreme Court of India) — Reaffirmed Arivandandam: the law does not permit clever drafting to create an illusory cause of action or to get around the bar of limitation. The court must look at the substance of the plaint, not the form. Bad cause of action "The defendant owes the plaintiff money and has not paid despite requests. The plaintiff is therefore entitled to recover the same." No date, no source of the debt, no amount, no due date, no default event. A textbook Order VII Rule 11(a) rejection. Proper cause of action "The cause of action arose on 12.03.2024 when the defendant executed the agreement at Pune; on 12.06.2024 when the agreed due date for payment of ₹8,00,000 expired without payment; and on 20.06.2024 when the defendant, despite the plaintiff's legal notice, refused to pay — and the cause of action is continuing as the amount remains due." ⚙ Cause of Action Builder Fill the facts; the tool drafts a clean "cause of action arose" paragraph in court style. Date the obligation was created (e.g. agreement/loan) What was created on that date Date the right became enforceable (due date / refusal) What happened on that date Date of demand / notice (optional) Defendant's response (optional) Place where the cause of action arose Generate paragraph Clear Your cause of action paragraph will appear here. Part 07 Order VII Rule 11 CPC — when a plaint is rejected This is the rule your opponent will reach for first. Under Order VII Rule 11 CPC , the plaint shall be rejected in the following cases: The six grounds of rejection (a) where it does not disclose a cause of action; (b) where the relief claimed is undervalued, and the plaintiff, on being required by the court to correct the valuation within a time fixed, fails to do so; (c) where the relief claimed is properly valued but the plaint is written upon insufficiently stamped paper, and the plaintiff fails to supply the requisite stamp-paper within the time fixed; (d) where the suit appears from the statement in the plaint to be barred by any law (including limitation); (e) where it is not filed in duplicate; (f) where the plaintiff fails to comply with Order VII Rule 9 (filing of copies/process requirements). Key principles a junior must know cold: Only the plaint is read. The court looks at the plaint and the documents filed with it, taking the averments to be true; the written statement and defence are irrelevant at this stage — Sopan Sukhdeo Sable v. Asstt. Charity Commr. , (2004) 3 SCC 137. All or nothing. A plaint must be rejected as a whole or not at all; it cannot be rejected in part (settled position reaffirmed by the Supreme Court — the plaint is either accepted or rejected in its entirety under Rule 11). Any stage. An application under Rule 11 can be filed at any stage of the suit — Sopan Sukhdeo Sable (supra). Limitation on the face of the plaint. If the plaint itself shows the suit is time-barred, it is rejected under clause (d) — Dahiben (supra). Rejection ≠ dismissal. Under Order VII Rule 13, rejection does not bar a fresh plaint on the same cause of action (subject to limitation). Sopan Sukhdeo Sable v. Asstt. Charity Commr. , (2004) 3 SCC 137 (Supreme Court of India) — For Order VII Rule 11, the averments in the plaint alone are germane; the pleas taken by the defendant in the written statement are wholly irrelevant. The court must read the plaint as a whole and meaningfully. Part 08 Territorial, pecuniary and subject-matter jurisdiction Jurisdiction has three independent legs. Your plaint must satisfy all three; failing any one invites a return of the plaint (Order VII Rule 10) or a challenge. The three jurisdictional questions for every plaint Type Question Governing provisions Territorial Is this the right place to sue? Sections 16–20 CPC. Suits for immovable property — where the property is situate (s.16–18). Other suits — where the defendant resides/carries on business, or where the cause of action wholly or in part arises (s.20). Pecuniary Can this court hear a suit of this value? Section 15 CPC (suit to be filed in the court of the lowest grade competent to try it) + the State's Suits Valuation Act and the pecuniary limits notified for that State/court. Subject-matter Does this court have authority over this kind of dispute? Special statutes may oust the civil court (e.g. rent, family, consumer, debt-recovery, commercial-court thresholds). Check for any ouster before filing. Wrong jurisdiction paragraph "This Hon'ble Court has jurisdiction to try and entertain the present suit." A bare assertion. It states no facts. Order VII Rule 1(f) requires the facts showing jurisdiction. Corrected jurisdiction paragraph "The defendant resides and carries on business at Pune, and the agreement dated 12.03.2024 was executed and was to be performed at Pune, where the entire cause of action arose. The value of the suit being ₹8,00,000, this Hon'ble Court has both territorial jurisdiction under Section 20 CPC and pecuniary jurisdiction to try and entertain the suit." ✅ Jurisdiction Checklist Tick what your facts support. Anything unticked is a hole to plug before filing. Territorial: defendant resides / works for gain within this court's limits (s.20) Territorial: cause of action wholly or in part arose within these limits (s.20) Immovable property suits: the property is situate within these limits (s.16) Pecuniary: suit value is within this court's pecuniary limit (s.15 + State Act) Subject-matter: no special statute ousts the civil court's jurisdiction Commercial dispute? Checked the Rs. 3 lakh threshold under the Commercial Courts Act, 2015 Leave under s.20 / contractual exclusive-jurisdiction clause considered Part 09 Limitation check — before you draft, not after Limitation is jurisdictional in effect: under Section 3 of the Limitation Act, 1963 , the court must dismiss a time-barred suit even if limitation is not pleaded as a defence. Worse, if the plaint shows on its face that the suit is barred, it is rejected under Order VII Rule 11(d) — as in Dahiben . So compute limitation first . Common limitation periods (Schedule to the Limitation Act, 1963) Nature of suit Article Period Starting point Price of goods sold and delivered (no fixed credit period) Art. 18 3 years Date of delivery Money payable for work done / services Art. 18 / 19 3 years When the work/service is done Money lent (loan) Art. 19 3 years When the loan is made Specific performance of a contract Art. 54 3 years Date fixed for performance; or, if none fixed, when plaintiff has notice that performance is refused Compensation for breach of contract Art. 55 3 years When the contract is broken To set aside / cancel a registered instrument Art. 59 3 years When the facts entitling the plaintiff to cancel first become known Possession of immovable property (based on title) Art. 65 12 years When defendant's possession becomes adverse Always also check acknowledgements (s.18), part-payments (s.19), and exclusions/extensions (ss.12–14, 5) — a written acknowledgement before expiry restarts the clock. The legal-notice period is not automatically excluded unless a statute so provides. 🚩 Limitation Red-Flag Checklist If any box stays unticked, stop and re-examine before filing. Identified the correct Article of the Schedule for this exact relief Fixed the precise starting point (date of accrual), in writing Computed the last date of limitation and confirmed today is within it Checked for any acknowledgement (s.18) or part-payment (s.19) that extends time If filing late, noted that s.5 condonation does not apply to suits (only appeals/applications) Drafted a limitation paragraph stating the suit is within time Part 10 Valuation of the suit and court fee Valuation does two distinct things: it fixes pecuniary jurisdiction (under the Suits Valuation Act, 1887 framework) and it fixes the court fee (under the Court-Fees Act, 1870 or the relevant State Court-Fees Act). The two values can differ for some reliefs, so state both clearly under Order VII Rule 1(i). Money recovery: ad valorem court fee is paid on the amount claimed. Specific performance: court fee is generally computed on the consideration / value of the contract as fixed by the applicable Court-Fees Act (the basis varies between the Central Act and State Acts; in several States it is the amount of consideration for the agreement). Declaration with consequential relief / possession: valuation rules differ by State — check the local Court-Fees and Suits Valuation Act. State variation warning. Court fee is a State subject in practice. Maharashtra, Tamil Nadu, Karnataka, Delhi, Uttar Pradesh, West Bengal and others have their own Court-Fees / Suits Valuation Acts with different slabs, ceilings and modes of computation. Always compute the fee under the Act of the State where you file, and confirm the current slab — these are revised from time to time. Do not lift a fee figure from a precedent of another State. Insufficient court fee is not fatal at the threshold: under Order VII Rule 11(b) and (c), the court must first give time to make up the deficiency; rejection follows only on failure to comply within the time fixed. But getting it right the first time avoids a registry objection and a wasted hearing. Part 11 Relief clause and prayer drafting Under Order VII Rule 7 CPC , every plaint must state specifically the relief claimed, either simply or in the alternative. The court generally cannot grant a relief not prayed for (subject to the general/residuary prayer). A vague prayer is a self-inflicted wound: you may prove your case and still walk away with nothing because you asked for the wrong order. Vague prayer "It is prayed that justice be done and the defendant be directed to pay whatever is due, along with such other reliefs as the Hon'ble Court deems fit." Specific prayer "(a) Pass a decree directing the defendant to pay ₹8,00,000 with interest at 9% p.a. from 12.06.2024 till realisation; (b) award costs of the suit; (c) and/or grant such further and other relief as this Hon'ble Court deems fit and proper in the circumstances." For specific performance , the prayer needs special care after the law settled the following: I.S. Sikandar (Dead) by LRs v. K. Subramani & Ors. , (2013) 15 SCC 27 (Supreme Court of India) — Where the contract has been terminated/cancelled by the other side, a suit merely for specific performance is not maintainable unless the plaintiff also seeks a declaration that the termination/cancellation is bad and prays for consequential relief. Frame the prayer to include the declaration, specific performance (execution of the sale deed), and, where the plaintiff is out of possession, recovery/delivery of possession. Specific Relief (Amendment) Act, 2018 — In force w.e.f. 01.10.2018 — Substituted Section 10, making specific performance an enforceable statutory entitlement (subject to the limited bars in Sections 11(2), 14 and 16) rather than a purely discretionary remedy. Section 16(c) still mandatorily requires the plaintiff to plead and prove readiness and willingness to perform. Always include the readiness-and-willingness averment. ⚙ Prayer Clause Builder Type of suit Recovery of money Specific performance of contract Principal amount (Rs.) Interest rate (% p.a.) Interest running from (date) Date of agreement Property / subject of contract Other side has terminated/cancelled the contract (add declaration prayer) Plaintiff is out of possession (add possession prayer) Generate prayer Clear Your prayer clause will appear here. Part 12 Documents and annexures — Order VII Rule 14 CPC Under Order VII Rule 14 CPC , where a plaintiff sues upon a document (or relies on a document in his possession or power), he must produce it in court when the plaint is presented, and must file a list of such documents. Documents not in the plaintiff's possession must be listed with a statement of who holds them. Crucially, under Order VII Rule 14(3) , a document relied on but not produced with the plaint shall not, save with the leave of the court, be received in evidence later. For commercial suits under the Commercial Courts Act, 2015, the disclosure regime is stricter: Order XI (as substituted for commercial disputes) requires a complete list and copies of all documents in the plaintiff's power, possession, control or custody, with a declaration on oath that no relevant document has been omitted. How to reference a document inside the facts Loose reference "There was an agreement between the parties, a copy of which is attached." Disciplined reference "On 12.03.2024 the parties executed a written agreement at Pune (true copy filed and marked as Document No. 1 in the accompanying list of documents), whereby the defendant agreed to pay the plaintiff ₹8,00,000 on or before 12.06.2024." Best practice: give every document a serial number in the list, refer to it by that number in the facts, and keep the list, the facts and the prayer internally consistent. The registry cross-checks them. Part 13 Verification — Order VI Rule 15 (and Rule 15A) CPC A plaint must be verified at the foot by the party (or a competent person acquainted with the facts). Under Order VI Rule 15 CPC , the verification must specify, by reference to the numbered paragraphs, what the deponent verifies of his own knowledge and what he verifies on information believed to be true, and it must state the date and place of signing. Two layers to remember: Affidavit under Section 26(2) read with Order VI Rule 15(4): the facts pleaded must be supported by an affidavit. The Supreme Court in Salem Advocate Bar Association (II) v. Union of India , (2005) 6 SCC 344, upheld this requirement and clarified its purpose — to fix responsibility on the deponent and curb reckless pleadings (though such an affidavit does not by itself constitute evidence in the suit). Statement of Truth under Order VI Rule 15A (Commercial Courts): for suits over the specified value treated as commercial disputes, the pleading must be verified by a Statement of Truth in the prescribed form set out in the Appendix to the CPC, signed in the manner provided. A pleading not so verified cannot be relied upon. Salem Advocate Bar Association, Tamil Nadu (II) v. Union of India , (2005) 6 SCC 344 (Supreme Court of India) — Upheld the amended verification/affidavit requirements and laid down practice directions on the working of the amended CPC, confirming that the affidavit under Section 26(2)/Order VI Rule 15(4) is mandatory. Model verification: I, AB, the plaintiff above-named, do hereby verify that the contents of paragraphs 1 to 6 of the plaint are true to my personal knowledge, and the contents of paragraphs 7 and 8 are based on legal advice received and believed to be true. Verified at Pune on this 28th day of June, 2026. (Signature of Plaintiff) Part 14 · Visual From client facts to filing — the flow Client facts Raw, unordered narration → Material facts Strip evidence; keep what proves the right → Cause of action Bundle of facts giving an enforceable right → Jurisdiction Territorial + pecuniary + subject-matter → Relief Specific prayer + valuation + court fee → Filing Documents, verification, affidavit, registry Arrange the facts chronologically Pleadings read best when the story moves in time. A registry clerk, a judge and your opponent should be able to follow the events in order. Para 1–2 — Parties Who the plaintiff and defendant are; capacity, residence, business. Para 3 — The transaction begins The agreement/loan/sale and its date — the origin of the right. Para 4 — Performance by plaintiff What the plaintiff did / was ready and willing to do. Para 5 — Breach / default by defendant The event that gives rise to the grievance, with date. Para 6 — Notice / demand Legal notice and the defendant's response or silence. Para 7 — Cause of action Tie the dates together; state when and where it arose. Para 8–10 — Jurisdiction, limitation, valuation The formal/legal paragraphs. Prayer — Relief The specific orders sought. Part 15 · The main event Annotated sample plaint (recovery / specific-performance style) Below is a complete, annotated specimen plaint for a money-recovery suit arising out of a written agreement. The right-hand notes explain why each block is drafted that way. Treat the figures and names as illustrative and adapt to your matter and your State's rules. IN THE COURT OF THE CIVIL JUDGE (SENIOR DIVISION) AT PUNE CIVIL SUIT NO. ________ OF 2026 Court heading. Names the court — Order VII Rule 1(a). The suit number is left blank for the registry to allot on filing. Shri Arun Bhalchandra Kulkarni, aged about 46 years, occupation: business, R/o 12, Shaniwar Peth, Pune – 411030 … PLAINTIFF VERSUS Shri Mahesh Dattatray Patil, aged about 50 years, occupation: business, R/o 88, Budhwar Peth, Pune – 411002 … DEFENDANT Cause title & party description. Name, age, occupation, residence of each party — Order VII Rule 1(b)(c). Add a Rule 1(d) statement if any party is a minor or of unsound mind (with the next friend / guardian). SUIT FOR RECOVERY OF ₹8,72,000 The plaintiff above-named respectfully submits as under: Title of the suit. A one-line description of the nature and amount of the claim helps the registry classify and value the suit. 1. The plaintiff is a businessman carrying on business at Pune. The defendant is known to the plaintiff and carries on business at Pune. Para 1 — Parties. Establishes capacity and connection. Concise; no evidence. 2. On 12.03.2024 the defendant approached the plaintiff for a hand-loan and, on the same day, the parties executed a written agreement at Pune (true copy filed and marked as Document No. 1 ), whereby the plaintiff advanced ₹8,00,000 (Rupees Eight Lakh only) to the defendant, repayable on or before 12.06.2024 with interest at 9% per annum. Para 2 — Origin of the right. Date, place, amount (figures + words), the document referenced by serial number — Order VI Rule 2 + Order VII Rule 14. This is a material fact. 3. The plaintiff duly advanced the said sum of ₹8,00,000 to the defendant by account-payee cheque dated 12.03.2024 (bank statement filed as Document No. 2 ), which the defendant encashed. Para 3 — Plaintiff's performance. Shows the plaintiff did his part; documents the disbursal. 4. Despite the agreed due date of 12.06.2024 having expired, the defendant failed and neglected to repay the said amount or any part thereof. Para 4 — Default. The breach event with its date — the trigger of the grievance. 5. The plaintiff, through his advocate, issued a legal notice dated 20.06.2024 (copy and postal proof filed as Documents No. 3 and 4 ) calling upon the defendant to repay the amount with interest. The defendant received the notice on 23.06.2024 but neither replied nor paid. Para 5 — Notice and refusal. Demonstrates demand and the defendant's failure to comply; completes the cause of action narrative. 6. The cause of action for the present suit arose on 12.03.2024 at Pune when the agreement was executed and the loan advanced; on 12.06.2024 when the defendant defaulted in repayment; and on 23.06.2024 when the defendant, despite the plaintiff's legal notice, failed and refused to pay. The cause of action is continuing as the amount remains due and unpaid. Para 6 — Cause of action. Order VII Rule 1(e). Ties the dates and the place together so the court can see the suit is genuine and where it arose. This is the paragraph an Order VII Rule 11 application attacks first. 7. Jurisdiction: The defendant resides and carries on business at Pune, and the agreement was executed and was to be performed at Pune, where the whole of the cause of action arose. The value of the suit being ₹8,72,000, this Hon'ble Court has both territorial jurisdiction under Section 20 CPC and pecuniary jurisdiction to try and entertain the present suit. Para 7 — Jurisdiction. States the facts showing jurisdiction — Order VII Rule 1(f) — not a bare assertion. Covers both territorial and pecuniary legs. 8. Limitation: The cause of action having arisen in June 2024 and the present suit being for recovery of money, the suit is filed well within the period of three years prescribed under the Limitation Act, 1963, and is within limitation. Para 8 — Limitation. Affirmatively shows the suit is in time, pre-empting an Order VII Rule 11(d) attack. 9. Valuation and court fee: For the purposes of court fee and jurisdiction, the suit is valued at ₹8,72,000, being the principal of ₹8,00,000 together with interest of ₹72,000 accrued up to the date of filing, on which ad valorem court fee of ₹________ is paid as per the Maharashtra Court-Fees Act / applicable State law. Para 9 — Valuation & court fee. Order VII Rule 1(i). The fee figure depends on the State slab in force on the date of filing — compute it under the correct State Act. 10. Grounds: (a) The defendant is bound by the written agreement dated 12.03.2024; (b) the defendant has wrongfully withheld the plaintiff's money since 12.06.2024; (c) the plaintiff is entitled to recover the principal with contractual interest and costs. Para 10 — Grounds. A concise statement of the legal basis of the claim. Keep it factual; do not argue evidence here. PRAYER It is therefore most respectfully prayed that this Hon'ble Court be pleased to: (a) pass a decree directing the defendant to pay to the plaintiff ₹8,72,000 together with interest at 9% per annum on the principal sum of ₹8,00,000 from the date of suit till realisation; (b) award the costs of the suit to the plaintiff; and (c) grant such further and other relief as this Hon'ble Court may deem fit and proper in the facts and circumstances of the case. Prayer. Order VII Rule 7 — relief stated specifically , with a general/residuary prayer. Note interest split into pre-suit (in valuation) and pendente lite / future (claimed in prayer). INTERIM RELIEF (if applicable): The plaintiff has filed a separate application under Order XXXVIII Rule 5 CPC for attachment before judgment, the defendant being likely to dispose of his assets to defeat any decree. Interim relief. Substantive interim relief (attachment before judgment, temporary injunction under Order XXXIX) is sought by a separate interlocutory application , not buried in the plaint's main prayer. LIST OF DOCUMENTS (Order VII Rule 14) 1. Agreement dated 12.03.2024 2. Plaintiff's bank statement evidencing the cheque dated 12.03.2024 3. Legal notice dated 20.06.2024 4. Postal receipt and acknowledgement of the legal notice List of documents. Each document numbered to match the references in the facts. Originals/true copies produced with the plaint — Order VII Rule 14(1), failing which Rule 14(3) bars later use without leave. VERIFICATION I, Arun Bhalchandra Kulkarni, the plaintiff above-named, do hereby verify that the contents of paragraphs 1 to 6 are true to my personal knowledge and the contents of paragraphs 7 to 10 are based on legal advice believed to be true. Verified at Pune on this 28th day of June, 2026. (Sd/-) Plaintiff Verification. Order VI Rule 15 — paragraph-wise, distinguishing knowledge from belief, with date and place. Accompany with the affidavit under s.26(2)/Order VI Rule 15(4); add a Statement of Truth (Order VI Rule 15A) if it is a commercial suit. SIGNATURE BLOCK Place: Pune Date: 28.06.2026 (Sd/-) Plaintiff (Sd/-) Advocate for the Plaintiff Enrolment No.: ________ Signature block. Order VI Rule 14 — signed by the party and the pleader. The advocate's enrolment number and a vakalatnama accompany the filing. For a specific-performance suit, adapt as follows: in the facts, plead the agreement to sell, the consideration, the part-payment made, and your readiness and willingness to perform (Section 16(c), Specific Relief Act, 1963 — mandatory). If the seller has terminated the agreement, add a prayer for a declaration that the termination is illegal and void, followed by specific performance (execution and registration of the sale deed), and, if you are out of possession, delivery of possession — per I.S. Sikandar v. K. Subramani , (2013) 15 SCC 27. Value the suit and pay court fee on the consideration as per the applicable State Court-Fees Act. Part 16 Registry objections and filing defects Most plaints first die not at the hands of a judge but at the filing counter / scrutiny branch . The registry checks form before substance. Clear these and you save weeks. Court fee deficient Fee not computed on the correct value or under the wrong State slab. Fix: recompute under the State Court-Fees Act in force; affix/pay the balance; cite the provision in the valuation paragraph. Cause title defective Age, occupation or full address of a party missing. Fix: complete Order VII Rule 1(b)(c) particulars; add Rule 1(d) statement if a party is a minor. Verification/affidavit not in form No paragraph-wise verification; affidavit unsworn or undated. Fix: redo verification per Order VI Rule 15; get the s.26(2) affidavit properly sworn; add Statement of Truth for commercial suits. Documents not listed/produced Documents referred to in facts but not in the list or not filed. Fix: file true copies, number them, match the list to the facts — Order VII Rule 14. No vakalatnama / wrong format Vakalatnama missing, unstamped, or not signed/accepted. Fix: file a properly executed, stamped and accepted vakalatnama with the advocate's enrolment number. Not in duplicate / copies short Plaint not filed in duplicate or process copies short — Order VII Rule 9 / 11(e). Fix: file the requisite number of copies and process fee as per local rules. Limitation not addressed Plaint silent on limitation though dates look old. Fix: add a limitation paragraph; if applicable, file a properly grounded application for any available exclusion/extension. Pecuniary/territorial mismatch Suit value outside the court's limits or wrong forum. Fix: file in the correct court (s.15/s.20) or seek return under Order VII Rule 10. 🧪 Registry Objection Simulator A clerk raises an objection. Pick the correct fix. Next objection → Worked example — one objection, fixed properly Objection raised Scrutiny note: "Cause of action paragraph does not show when and where the cause of action arose. Plaint liable to be returned." How it was fixed The cause-of-action paragraph was redrafted from "the defendant has not paid" to the dated, place-specific version: "The cause of action arose on 12.03.2024 at Pune…; on 12.06.2024 when the defendant defaulted…; and on 23.06.2024 when the defendant refused to pay despite notice." Objection cleared at re-filing. Part 17 Drafting mistakes junior advocates actually make 1. Pleading evidence and argument inside the facts Reciting what a witness will say, quoting documents in full, and arguing the law. Order VI Rule 2 forbids it. Keep the plaint to material facts; save proof for the affidavit of evidence and submissions. 2. A bald jurisdiction line instead of jurisdictional facts "This Hon'ble Court has jurisdiction" states nothing. Order VII Rule 1(f) wants facts — where the defendant lives/works and where the cause of action arose — plus the value for pecuniary jurisdiction. 3. Skipping the limitation paragraph Even when comfortably in time, say so. If the dates look old and the plaint is silent, you invite an Order VII Rule 11(d) attack and a registry objection. Compute limitation before drafting, not after. 4. A vague, omnibus prayer "Such relief as the court deems fit" cannot stand alone. Order VII Rule 7 demands a specific relief. Ask for the exact decree — amount, interest from a stated date, costs — and keep the residuary prayer only as a safety net. 5. Specific-performance prayer without declaration / readiness Forgetting to plead readiness and willingness (Section 16(c) SRA) or, where the contract was terminated, omitting the declaration that the termination is bad — both are fatal per I.S. Sikandar . Also omit possession at your peril if you are out of possession. 6. Documents referenced but not produced/listed Order VII Rule 14(3) bars a relied-on document not produced with the plaint from being received in evidence without leave. Number every document and reconcile the list with the facts. 7. Defective verification and missing affidavit Verification that does not distinguish knowledge from belief, or a missing s.26(2)/Order VI Rule 15(4) affidavit (or, in commercial suits, the Statement of Truth under Order VI Rule 15A). The registry will bounce it. 8. Wrong court fee lifted from another State's precedent Court fee is governed by the State Act in force where you file. Slabs, ceilings and modes differ. Never copy a fee figure across States; compute it fresh for your forum. 9. Misjoinder and a sprawling, unfocused plaint Cramming multiple unrelated causes or parties to "cover everything". This invites confusion and objections. Keep the plaint to one coherent cause of action unless joinder is properly permissible. Part 18 · Interactive Weak vs strong drafting — and a Do / Don't table Show STRONG version Weak pleading "3. The defendant took some money from the plaintiff and did not return it though asked many times. The plaintiff has suffered a lot. The defendant is in the habit of cheating people, as everyone in the locality knows. Hence this suit for whatever is due." Strong pleading "3. On 12.03.2024, at Pune, the defendant borrowed ₹8,00,000 from the plaintiff under a written agreement (Document No. 1), repayable by 12.06.2024 with interest at 9% p.a. Despite the due date having passed and the plaintiff's legal notice dated 20.06.2024 (Document No. 3), the defendant has failed and neglected to repay the said sum or any part thereof. The amount of ₹8,00,000 with interest remains due and payable to the plaintiff." Do / Don't — quick dra