SUIT FOR REINSTATEMENT BY SPECIFIC PERFORMANCE AND ARREARS OF BACK WAGES (OR SALARY)
IN THE COURT OF THE………………..
Suit No………………… of 20………………..
C. D………………………………………………………….. Plaintiff
versus
C. F……………………………………………………….. Defendant
The abovenamed plaintiff most respectfully submits as under: —
1. On the……………….. day of……………….. 20……………….. the plaintiff and the defendant mutually agreed that the plaintiff should serve the defendant as (an accountant, or in the capacity of foreman, or as the case may be), and that the defendant should employ the plaintiff-as such for term of one year and pay him for his service,……………….. rupees (monthly).
2. On the……………….. day of……………….. 20………………… the plaintiff entered upon the service of the defendant in such services and has ever since been, and still is, ready and willing to continue in such services during the remainder of the said year whereof the defendant always has had notice.
3. On……………….. day of……………….. 20………………… the defendant wrongfully discharged the plaintiff and refused to permit him to serve as aforesaid, or to pay him for his services.
4. The cause of action arose within the jurisdiction of this Court when the defendant discharged the plaintiff on……………….. 20……………….. without payment of his back wages earned and due.
5. The valuation of the suit for the purposes of jurisdiction is……………….. rupees, and for the purposes of court fee on the relief of injunction is……………….. rupees, and Court fees is paid on both reliefs.
6. The balance of convenience is in favour of the plaintiff employee, and it is expedient that the plaintiff be reinstated in service of the defendant and his back wages and wages pendente lite be ordered to be paid to the plaintiff
Plaintiff
Through Advocate
VERIFICATION
I, abovenamed plaintiff, do hereby verify that the contents of paras ……………….. to……………….. of the plaint are true to my personal knowledge and those of paras……………….. and……………….. thereof are based on legal advice which I believe to be true.
Verified on this…………….. day of……………….. 20……………….. at………………..
Plaintiff
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