Polluting the Water under the Plaintiff's Land 

In the Court of ......................................

____ (add description and residence) ...................... Plaintiff 

against

_____(add description and residence) .................... Defendant 

_________, the above-named plaintiff, states as follows:- 

1. The plaintiff is, and at all the time hereinafter mentioned was, possessed of certain land called .......... and situate in ...... and of a well therein, and of water in the well, and was entitled to the use and benefit of the well and of the water therein, and to have certain springs and streams of water which flowed and ran into the well to supply the same to flow or run without being fouled or polluted. 

2. On the...... day of...... 200..., the defendant wrongfully fouled and polluted and well and the water therein and the springs and streams of water which flowed into the well. 

3. In consequence the water in the well became impure and unfit for domestic and other necessary purposes, and the plaintiff and his family are deprived of the use and benefit of the well and water. 

[i. Facts showing when the cause of action arose and that the Court has jurisdiction. ] 

ii. The value of the subject-matter of the suit for the purpose of jurisdiction is ................rupees and for the purpose of court-fees is ................rupees., and Relief claimed.] 

Dated : 

Plaintiff 

Through, Advocate 

Verification:

I, ______, do hereby verify that the contents from paras 1 to ______ 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 ______ this ______. 

Plaintiff 

AFFIDAVIT

 IN THE COURT OF THE CIVIL JUDGE, _____________

 

Petitioner:____________________________ (Name)

                                   Versus

Respondent:____________________________(Name)

That I am the petitioner in the present case and I am well conversant with the facts and circumstances of the case, hence competent to file this affidavit.

That, I am filing an application under Order IX Rule 9 of the Code of Civil Procedure, 1908 before this Hon’ble Court. The contents of the application have been read over, translated and explained to me in Hindi and in English also. The content of the application related to the facts are true from my personal knowledge and that related to law are true to the information received by me from my advocate, which I believe to be true and this affidavit is sworn in support thereof. Nothing contained therein is false and nothing has been concealed.

Place:                                                                                 (Signature)

__________________                                                                         

Date:                                                                                   Deponent

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