SUIT FOR CANCELLATION OF DEED OF GIFT OBTAINED BY UNDUE-INFLUENCE OR DUE TO THE INSANITY OF THE DONOR
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 father of the plaintiff is aged.................... years and has been in very sick health due to old age, and asthma and due to irritation having been caused from the side of the younger brothers of the plaintiff who are leading a life out of way in drinking and other bad habits of gambling etc. The father of the plaintiff is in great mental distress, and he has been allured by the defendant .................... wrongfully to make a gift in his favour of the house No..................... situate at..................... in consideration of which.................... has promised him to maintain for the remaining of his life.
Or
That E. F. defendant is the mother of the plaintiff, she is aged about 60 years. She has got the house No..................... situate at.................... in inheritance from the father of the plaintiff by way of a will dated.................... left by the deceased father. Now the mother has been in undue influence of XY, sister of the plaintiff and XQ the brother-in-law of the plaintiff and they have got a gift deed of the house registered under their influence in favour of their minor son, on.................... 19....................
2. That the plaintiff’s father/mother aforesaid had not been insane body and mind and was in great mental distress at the time of executing the said gift, and he/ she had not independent advice, and was induced by the insane mind/the undue influence aforesaid to execute the said gift.
3. That the plaintiff is a minor and is a co-sharer in the properties left by his father, and as such and also due to the reasons aforesaid the gift is void and liable to be cancelled by this Court.
4. That the cause of action arose on.................... 19.................... when the said gift was executed, within the jurisdiction of this Court.
5. That the suit is valued at Rs..................... the price of the house, thirty times of the house tax paid thereon, and court fee is paid accordingly to the reliefs claimed.
RELIEF CLAIMED:
The plaintiff claims to have the said deed of gift adjudged void and cancelled.
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