Wrongful Dismissal 

In the Court of ………………………………..

kk………………………………………………… resi …………………………………………… Plaintiff 

against

gm………………………………………….. resi……………………………… ……………….. Defendant 

kk……………………………………………………………………..…………., the above-named plaintiff, states as follows:- 

1. On the …………. day of ……….. /………. , the plaintiff and defendant mutually agreed that the plaintiff should serve the defendant as [an ………………………………………………………………….. or as the case may be], and that the defendant should employ the plaintiff as such for the term of [..……………… year] and pay him for his services ………………………………………………………………………………………………. Rupees [monthly]. 

2. On the …………….. day of…………………. /………….. .. , the plaintiff entered upon the service of the defendant and has ever since been, and still is, ready and willing to continue in such service during the remainder of the said year whereof the defendant always has had notice. 

3. On the …………. day of…………… /…………………… , the defendant wrongfully discharged the plaintiff, 

and refused to permit him to serve as aforesaid, or to pay him for his services. 

[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   AGRA   this ______. 

Plaintiff