KK……………, the above-named plaintiff, states as follows:- 

1. On the …… day of…… /…, plaintiff owned [or state facts showing a right to the possession] the goods mentioned in the schedule hereto annexed [or describe the goods. ] the estimated value of which is …… rupees. 

2. From that day until the commencement of this suit the defendant has detained the same from the plaintiff. 

3. Before the commencement of the suit, to wit, on the …… day of…… /… , the plaintiff demanded the same from the defendant, but he refused to deliver them. 

[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.,] 

4. The plaintiff claims- 

(1) delivery of the said goods, or…………………….Rupees, in case delivery cannot be had; 

(2) ………………………………. rupees compensation for the detention thereof. 

Dated : 

Plaintiff 

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 KAYAN. this ______.