Breach of Contract to Serve
In the Court of ......................................
A.B. (add description and residence) ...................... Plaintiff
against
C.D. (add description and residence) .................... Defendant
A. B., the above-named plaintiff, states as follows:-
1. On the ...... day of ...... 200.. , the plaintiff and defendant mutually agreed that the plaintiff should employ the defendant at an [annual] salary of... rupees, and that the defendant should serve the plaintiff as [an artist] for the term of [one year].
2. The plaintiff has always been ready and willing to perform his part of the agreement and on the day of...... 200 , offered so to do.
3. The defendant (entered upon) the service of the plaintiff on the above-mentioned day, but afterwards, on the... .day of... 200... , he refused to serve the plaintiff as aforesaid.
[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 Coimbatore this ______.
Plaintiff