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| Format of Suit for defamation |
IN THE COURT OF DISTRICT JUDGE
____________________________________________
Plaintiff
Versus
____________________________________________
Defendant
SUIT FOR RECOVERY OF AN AMOUNT OF RS. 5,000,000/-
ON ACCOUNT OF DEFAMATION
Respectfully Sheweth:
1.
That the plaintiff is respectable
esteemed and belongs to a noble family, therefore, enjoys spectacular reputation
in the society.
2.
That the plaintiff is a
retired government servant and during his whole job with the Government
Department, he worked diligently and honestly and no complainant has ever been registered
against the plaintiff from any corner.
3.
That on ____________________,
the defendant ________________________________. Furthermore, the defendant
always speaks immoral and dissipated about the plaintiff publicly and also
defaming the plaintiff by giving derogatory and defamatory remarks against the
plaintiff.
4.
That the defendant has been sloppily
defaming the plaintiff by saying the publicly
“that the plaintiff is a corrupt
person” which resulted in an awful name, horrendous influence, tedious impressions
of the plaintiff to the public at large.
5.
That the defendant while defaming
the plaintiff tell pretended story, additionally he speaks false and frolicsome
words against the plaintiff, defendant discussed the Personal life, which is
not allowable by any law to the defendant.
6.
That the defendant has no legal
or primary right to make searches regarding property/ estate belongs to plaintiff
and he also don’t have right to sue such defamatory words against the plaintiff
as mentioned above.
7.
That the plaintiff observed that
defendant also put acute accusations on the other officials of the government, the
plaintiffs as the loyalist citizens of Islamic Republic of Pakistan needs to take
up the said serious matter before the honourable court for the appropriate legal
action.
8.
That the plaintiff has concrete
evidence against the defendant regarding his libel and slander defamation for
the perusal of this honourable court.
9.
That the losses sustained by
the plaintiff at the hands of the defendant due to his above said act, cannot
be measured in terms of money, however, the plaintiff as token, claims only the
following damages from the defendant:-
i. Loss of reputation; Rs. 40,00,000/-
ii. Mental torture: Rs. 10,00,000/-
Total Rs. 50,00,000/-
10.
That the plaintiff is
entitled to recover the above said amount of damages on account of defamation
from the defendant and the defendant is liable to pay the above said amount to
the plaintiff.
11.
That the notice U/S 8 of
defamation ordinance 2002 was sent by plaintiff to the defendant through
registered courier on __________________
12.
That the time of _______days
was given to the defendant for the rejoinder of the above mentioned notice and
for tendering the unconditional apology or for payment of Rupees Five Million on
account of defamation but no reply is given by the defendant, hence this suit.
13.
The cause of action finally accrued
to the plaintiff against the defendant last week which is continuing.
14.
That the cause of action
accrued within the territorial jurisdiction of this
15.
That the value of the suit
for the purpose of court fee and jurisdiction is fixed Rs. 50,00,000/-(Rupees
Five Million only) and prescribed court
fee has been affixed.
PRAYER:
It is therefore respectfully
prayed that for obliterating the respect of the plaintiff in the society, giving
him unpleasant name in the society, mental agony, torture and heightened anxiety
and on derogatory and defamatory remarks of defendant about the plaintiff, a decree
for recovery of the sum of Rs.50,00,000/-(Rupees Five Million only) on account
of defamation may be passed in favour of the plaintiff and against the
defendants with costs.
Any other relief which this
honourable court deems fit and proper may also be awarded to the plaintiff.
Plaintiff
Through
ADVOCATE High Court
VERIFICATION
Verified on oath at
Plaintiff