POLLUTING THE WATER UNDER THE PLAINTIFF's LAND

 

IN THE COURT OF_____________ (add detail court)

Suit no.____/20____

_________________ (suppose A.B.)(add description and residence).

Plaintiff

against

__________________ (suppose C.D.)(add description and residence) . . .

Defendant

A. B., the above-named plaintiff, states as follows :-

1. The plaintiff is, and at all the times hereinafter mentioned was, possessed of certain lands 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 19__________, the defendant wrongfully fouled and polluted the 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.
4. [Facts showing when the cause of action arose and that the Court has jurisdiction.]
5. 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.
6. [Relief claimed.]