Civil Pleadings Injuries Caused By Negligence On A Railroad

Injuries Caused by Negligence on a Railroad 





In the Court of ______________________________________



KK____________________resi. ____________________.. Plaintiff 

against 



GM___________________ resi ____________________ Defendant 

KK_______, the above-named plaintiff, states as follows :- 

1. On the _______ day of_______ /____ ____ , the defendants were common carriers of passengers by railway between _______ and_______ 

2. On that day the plaintiff was a passenger in one of the carriages of the defendants on the said railway. 

3. While he was such passenger, at_______ [or near the station of_______ or____ .. between the stations of____ _______and____ .], a collision occurred on the said railway caused by the negligence and unskilfulness of the defendants' servants, whereby the plaintiff was much injured [having his _______________. etc., and state the special damage, if any, as], and incurred ex pense for medical attendance and is ________ disabled from carrying on his former business as _________ 

[A. Facts showing when the cause of action arose and that the Court has jurisdiction. ] 

 B.. The value of the subject-matter of the suit for the purpose of jurisdiction is _______________Rrupees and for the purpose of Court-fees is _______________.Rupees., and Relief claimed.] 

[Or thus:- 2. On that day the defendants by their servants so negligently and unskillfully drove and managed an engine and a train of carriages attached thereto upon and along the defendant's railway which the plaintiff was then lawfully crossing, that the said engine and train were driven and struck against the plaintiff, whereby, etc., as in para 3.] 

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 KASARA this ______. 

Plaintiff