SUIT FOR ACCOUNT AGAINST AN EX-GUARDIAN

SUIT FOR ACCOUNT AGAINST AN EX-GUARDIAN

IN THE COURT OF THE....................

Suit No..................... of 19....................

C. D.................................................................... Plaintiff

versus?

C. F................................................................. Defendant

The abovenamed plaintiff most respectfully submits as under: —

1. That the plaintiff had been a minor upto..................... and the defendant had been a guardian of the property of the plaintiff, per order of appointment as guardian, of the District Judge, Dated....................

2. That during the period of his guardianship, the defendant had been in exclusive possession of the plaintiffs property, and had been realising the income thereof. The plaintiff requested the defendant on.................... through a registered letter to give account of the income aforesaid. But the defendant did not heed to the demand. He did not reply even to the letter of demand sent by the defendant as aforesaid.

3. That the plaintiff is not aware of the income actually realised by the defendant or of the expenditure rendered by him on behalf of the plaintiff.

4. That the cause of action arose on..................... the date of service of letter of demand on the defendant, within the jurisdiction of this Court.

5. That the suit is valued at Rs..................... (........................................), the approximate amount of net income of the property of the plaintiff in the hands of the defendant.

RELIEFS CLAIMED:

The plaintiff claims the following reliefs:

(1) The defendant be ordered to give full and correct account of the income realised and expenditure incurred by the defendant in Court, in respect of the plaintiffs property during the period of guardianship of the defendant.

(2) The defendant be ordered to pay the net income of the plaintiff’s property during his guardianship, to the plaintiff.

(3) Interest on the net income at the rate of ................. % per annum, or as may be deemed fit may be awarded to the plaintiff.

Plaintiff

Through Advocate

VERIFICATION

I, abovenamed plaintiff, do hereby verify that the contents of paras .................... to.................... of the plaint are true to my personal knowledge and those of paras.................... and.................... thereof are based on legal advice which I believe to be true.

Verified on this................. day of.................... 19.................... at....................

Plaintiff