Civil Pleadings Carrying On A Noxious Manufactur1

Carrying on a Noxious Manufacture 



In the Court of ______________________________________



KK_____________ resi____________ ____________________.. Plaintiff 

against

GM________ ______ resi____________ ____________________ Defendant 

KK., the above-named plaintiff, states as follows:- 

1. The plaintiff is, and at all the times hereinafter mentioned was, possessed of certain lands called____ ., situate in ___________ ___________

2. Ever since the _____________ day of________ /______ , the defendant has wrongfully caused to issue from certain smelting works carried on by the defendant large quantities of offensive and unwholesome smoke and other vapours and noxious matter, which spread themselves over and upon the said lands, and corrupted the air, and settled on the surface of the lands. 

3. Thereby the trees, hedges, herbage and crops of the plaintiff growing on the lands were damaged and deteriorated in value, and the cattle and live-stock of the plaintiff on the lands became unhealthy, and many of them were poisoned and died. 

4. The plaintiff was unable to graze the lands with cattle and sheep as he otherwise might have done, and was obliged to remove his cattle, sheep and farming-stock therefore, and has been prevented from having so beneficial and healthy a use and occupation of the lands as he otherwise would have had. 

[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 KALYAN     this ______. 

Plaintiff