BEFORE THE SENIOR CIVIL JUDGE (DISTRICT ___________), DELHI
SUIT NO.______________OF 20

IN THE MATTER OF:
Mrs. [Name of Plaintiff 1]
Mr. [Name of Plaintiff 2]
Both residents of [Address], Chandigarh

…PLAINTIFFS

VERSUS
Power Grid Corporation of India Ltd.
[Address], New Delhi – 110029
Through its Chairman/Managing Director

…DEFENDANT

SUIT FOR EJECTMENT AND DAMAGES FOR WRONGFUL USE AND OCCUPATION

MOST RESPECTFULLY SHOWETH:

1. The Lease Agreement and Possession
   The plaintiffs, being the owners of Flat No. [Flat Number], located at [Address], New Delhi, let out the said flat to M/s National Power Transmission Corporation Limited, now known as Power Grid Corporation of India Limited, having their registered office at [Address], New Delhi, for a period of three years commencing from [Start Date] vide an unregistered Lease Deed (copy annexed as Annexure ‘A’). The possession of the premises was handed over to the defendant on the same date.

2. Expiry of Lease and Continuation of Tenancy
   The lease period of three years expired on [Expiry Date], after which the defendant continued to occupy the premises as a month-to-month tenant under the provisions of the Transfer of Property Act, 1882.

3. Need for Premises and Communication with Defendant
   The plaintiffs, being in urgent need of the premises for personal use, approached the defendant on multiple occasions (dates: [Specify Dates]) requesting vacation of the premises. However, the defendant failed to accede to the requests. Consequently, the plaintiffs served a legal notice dated [Date] through their Counsel, Shri [Name of Counsel], under Section 106 of the Transfer of Property Act, terminating the tenancy (copy annexed as Annexure ‘B’).

4. Service of Legal Notice
   The defendant received the plaintiffs’ legal notice on [Date of Receipt], ensuring the statutory period of 15 days’ notice under Section 106 of the Transfer of Property Act was complied with. Proof of service is annexed hereto as Annexure ‘B’.

5. Wrongful Use and Occupation
   Despite receipt of the legal notice, the defendant has neither vacated the premises nor demonstrated any intention to do so. As a result, from [Date], the defendant has been in wrongful occupation of the property, causing losses to the plaintiffs. Based on prevailing rental rates in the area for comparable properties, the damages for wrongful use and occupation are assessed at Rs. 1,000/- per day, as stated in the legal notice dated [Date].

6. Current Rent and Jurisdiction
   The defendant is currently paying a rent of Rs. 6,808/- per month for the flat measuring 370 sq. ft. Since the rent exceeds Rs. 3,500/-, the provisions of the Delhi Rent Control Act do not apply. Therefore, this Hon’ble Court has jurisdiction to adjudicate the matter.

7. Cause of Action
   The cause of action arose on [Date], when the plaintiffs first approached the defendant for vacation of the premises. The cause of action further arose on subsequent occasions ([Specify Dates]) when the plaintiffs reiterated their request, culminating in the issuance and service of the legal notice dated [Date]. The cause of action continues as the defendant remains in wrongful occupation.

8. Jurisdiction of the Court
   Since the property is situated in Delhi, the lease agreement was executed in Delhi, and the provisions of the Delhi Rent Control Act do not apply, this Hon’ble Court has jurisdiction to entertain and adjudicate the present suit.

9. Court Fees
   The annual rent of the property, calculated at Rs. 81,696/- (monthly rent of Rs. 6,808/- × 12 months), has been used to compute the ad valorem court fee of Rs. [Court Fee Amount]. The plaintiffs undertake to pay any additional court fees as directed by the Hon’ble Court.

PRAYER

In light of the foregoing, the plaintiffs most respectfully pray that this Hon’ble Court may be pleased to:

(i) Pass a decree for ejectment against the defendant, directing them to vacate the premises in question;
(ii) Pass a decree for damages @ Rs. 1,000/- per day from [Date] for wrongful use and occupation of the premises by the defendant;
(iii) Award the costs of the suit to the plaintiffs; and
(iv) Grant such other relief(s) as this Hon’ble Court may deem fit and proper under the circumstances.

PLAINTIFFS
[Place: Delhi]
[Date:]

THROUGH COUNSEL
[Name and Address of Advocate]

VERIFICATION

I, [Name of Plaintiff 1], son/daughter of [Parent’s Name], aged [Age], and I, [Name of Plaintiff 2], son/daughter of [Parent’s Name], aged [Age], both residents of [Address], do hereby solemnly verify and declare that the contents of Paragraphs 1 to [End Para] are true to our personal knowledge and those of Paragraphs [Specify Para Numbers] are based on legal advice, which we believe to be true. Last paragraph is a humble prayer to this Hon’ble Court.

Verified at Delhi on this ___ day of ______, 20.

PLAINTIFFS

(Note: This plaint must be supported by an affidavit as per law.)