Injuries Caused by Negligence on a Railroad





In the Court of ......................................



A.B. (add description and residence) ...................... Plaintiff

against



C.D. (add description and residence) .................... Defendant

A. B., the above-named plaintiff, states as follows :-

1. On the ...... day of...... 200 ... , 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 leg broken, his head cut, etc., and state the special damage, if any, as], and incurred ex pense for medical attendance and is permanently disabled from carrying on his former business as [a salesman].

[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.]

[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 Coimbatore this ______.

Plaintiff