SUIT BY A VENDEE AGAINST VENDOR FOR REFUND OF PURCHASE AMOUNT WITH DAMAGES DUE TO DEFECT IN THE VENDOR’S TITLE
IN THE COURT OF THE....................
Suit No..................... of 19....................
C. D.................................................................... Plaintiff
versus 
C. F................................................................. Defendant
The abovenamed plaintiff most respectfully submits as under: —
That on.................... 19.................... the defendant executed a sale deed of House No..................... situate in.................... in favour of the plaintiff for a consideration of Rs..................... received by him from the plaintiff in advance and at the time of the execution of the sale deed before the Sub-Registrar., and the plaintiff obtained possession of the house on that date.
2. That.................... sister of the defendant filed a suit No..................... of 19.................... claiming her half share in the house aforesaid, inheritance from her deceased father, and partition of her share and that the defendant has wrongfully sold the whole house to the plaintiff. This suit of.................... was decreed on.................... 19.................... and one half share in the house was declared to belong to her, along with the plaintiff transferee from the defendant., and partitioned and possession of the half share given to.....................
3. That accordingly, half share in the house is found defective due to the decree aforesaid, and the defendant is liable to refund half of the amount of the consideration of Rs..................... aforesaid, and damages due to loss of stamp paper respecting the half share and expenses of the execution of the sale deed respecting thereto, expenses incurred in defending the suit filed by.................... which amounted to Rs..................... and loss of business of the plaintiff incurred in the Factory of Brush-making run by the plaintiff in the said house, half portion of which now has been partitioned and possession given to.................... according to the decree of the Court.
4. That cause of action arose within the jurisdiction of this Court on .................... 19.................... when decree in favour of.................... was passed.
5. That the suit is valued at Rs...................... half of the amount of sale consideration aforesaid, and expenses incurred on execution of the said sale deed
respecting the half share lost by the plaintiff, and also expenses incurred by the plaintiff in contesting the suit filed by the..................... and the amount of Rs. .................... as damages caused to the plaintiffs business run in the house aforesaid, and court-fee is paid according to the relief claimed.
RELIEF CLAIMED:
The plaintiff claims payment of Rs..................... as half of the sale consideration plus damages as mentioned above and interest from date of filing the suit till payment thereof.
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