SUIT FOR CANCELLATION OF A GIFT DEED OBTAINED BY UNDUE INFLUENCE
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 plaintiff had been prosecuted in Cr. Cases S. T. No..................... of.................... 19.................................. versus................. under Section 395 of the Indian Penal Code and had been bailed out by the Defendant.................... his counsel in that case.
2. That the defendant had won the complete faith of the plaintiff as to his honesty and sincerity, and accordingly the defendant induced the plaintiff to make a gift deed in his favour of his house No............... situated in Mohalla.................... in.................... city under the make belief that the defendant would himself get the gift deed cancelled when the defendant fulfils his obligation of furnishing a security for the construction loan for his new house at.................... The defendant has now completed all his constructions of the said house, but despite requests he is not prepared to get the gift deed cancelled.
3. That the assent to gift away his house was obtained by the defendant from the plaintiff under the undue influence being the counsel of the plaintiff. The gift deed executed by the plaintiff in favour of the defendant is void and liable to be cancelled as such.
4. That the plaintiff apprehends that the defendant might sell the house to somebody else and make easy money of that and create further troubles to the plaintiff.
5. That the plaintiff had given a registered notice to the defendant to surrender the gift deed and get it cancelled himself, but he has refused to do so vide his reply received by the plaintiff on.................... 19....................
6. That the cause of action arose on.................... 19.................... when the plaintiff received reply of refusal of the defendant, within the jurisdiction of this Court.
7. That the market price of the house is Rs..................... and as such the suit is valued at Rs..................... and court-fee is paid thereon.
RELIEF CLAIMED:
The relief claimed by this suit is to cancel the gift deed executed by the plaintiff on.................... 19.................... in favour of the defendant its registration Number being No..................... and costs of the suit be awarded to the plaintiff.
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