GROUP 7

12. SUIT AGAINST GOVERNMENT

Government of Tamil Nadu, in fulfillment of Chennai Metro Worker's Welfare Scheme

undertook a underground Metro building project. They acquired the land of Mrs. Vidya Balan,
who is residing on 200 feet road of Thirumangalam, chennai with a promise to relocate another
land of same to Mrs. Vidhya balan, to another property of 4000 Square feet by 26th May 2017.
As the government did not take any steps to provide alternate accommodation to Mrs. Vidhya
Balan as promised, even after receipt of notice under section 80 CPC, Mrs. Vidhya Balan desires
to file suit against Government. Draft a suitable plaint.

IN THE DISTRICT COURT OF MUNSIF AT CHENNAI

O.S.No. 223/2017

Mrs. Vidya Balan

D/O. Mr. Kaniya
Door No.007, Thirumangalam, Chennai, 600151 Plaintiff

Vs.
Secy of Chennai Metro Rail Limited
Chennai, Tamil Nadu . Defendants

PLAINT FILED UNDER ORDER VII RULE 1 OF CPC FOR SUIT AGAINST
GOVERNMENT

The Plaintiff above named submits as follows:

1. The Plaintiff Mrs. Vidya Balan is the daughter of Mr. Kaniya, Hindu, aged about 37
years and residing at Door No.007, Thirumangalam, Chennai, 600151.
2. The Address of the Plaintiff for service of all Notices and other processes from this Court
of Law is that of her Advocate Mrs. Mishra, B.A.,LL.B (Hons), having her office
residing at 15/97, Sterlling Road, Chennai, 600004.
3. The Plaintiffs land was acquired by the Chennai Metro Rail Limited, Tamil Nadu in
Chennai in fulfillment of Chennai Metro Workers Welfare Scheme with a promise to
relocate and assign another land of 4000 square feet by 26th May 2017.
 4. Two-month prior notice has been duly given as per Section 80 of Code of Civil
Procedure, 1908
5. The Plaintiff states that the cause of action for this suit arose at Chennai on 26.05.2017
when the plaintiff made a representation and subsequently sends the notice to the
concerned agriculture department as per Section 80 of Code of Civil Procedure.
6. The Plaintiff states that this Honble Court has jurisdiction to try the suit as the whole
cause of action arose at Chennai and values the suit at Rs.4 Crore and pays thereon a
Court Fee of Rs. as per Section 24 of The Tamil Nadu Court Fees and Suits
Valuation Act.

PRAYER
The Plaintiff therefore prays for a Judgment and Decree against both the Defendant
i. for the relocation and assignment of another land measuring the same with similar
value.
ii. for Costs of the suit and
iii. for such other reliefs which the Plaintiff is entitled.

VERIFICATION
I, Vidya Balan, the Plaintiff above named, do hereby verify and state that the
allegations/averments set out in Paras 1 to 5 are based on knowledge, what has been
stated in Para 6 is based on information and what has been stated in Para 7 is based on
belief and that the same is true
.
Dated at.this.day of ..2017

(Sd.) xxxxxxxxxxx

Plaintiff VALUATION
1. Valuation for the purpose of jurisdiction and Court Fees
for relief (a)
Principal amount ________________________
Interest from _____ to ____ ________________________
Total ________________________

2. Court Fees thereon under Section 22, read with Schedule I,

Article 1 of the Kerala Court Fees and Suits Valuation Act, __________________
Court Fees paid under Section 4A of the Kerala Court
Fees and Suits Valuation Act __________________
Dated at. this, _______ day of _______ 2017

(Signature of the plaintiff)