Recovery Suit Application Affidavit

This document is related to Recovery Suit Application.

In the present document plaintiff and defendant came to into an agreement where defendant has to pay certain amount on completion of certain work for which bill was issued by the plaintiff and the same was accepted and acknowledged by the defendant.

So many requests were made to the defendant to make the payment so as the work could be done in time but the defendant failed to make the payment. It is no out of place to mention here that the work was delayed due to the reason known to the defendant. The defendant violated the terms and conditions of the Agreement.

 The account of the defendant became irregular and inspite of repeated requests and demands the defendant failed to regularise their account and also failed to make the payment in time. The plaintiff requested the defendant several times to make the payment of the outstanding amount which is lying against them but the defendant on one pretext or the other avoided to the legitimate requests of the plaintiff without any cause or reason and has stopped the payment of the plaintiff. In this contest the plaintiff has so many times orally and in writing approached the defendant to make the payment of the outstanding amount lying with the defendant. The notice was sent to the defendant by the plaintiff but the defendant failed to make the payment thereafter the and wrote a letter stating that the account of the plaintiff is debited with some amount without any reason. The defendant is trying to make liable the plaintiff for their wrongs. The defendant issued the same to cheat the plaintiff. The defendant are evading and neglecting the payment of the plaintiff with one false pretext or the other and with some ulterior purpose and motives therefore, the plaintiff can not trust on the defendant any more and cannot and cannot wait for an indefinite period hence they have been compelled to take efficacious legal action against the defendant. 

Therefore it is humbly prayed by the plaintiff to pass appropriate order for debt recovery and other reliefs.

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