A.B., the above named plaintiff, states as follows:--
1. The plaintiff is, and at all the times hereinafter mentioned was, possessed of certain land called ......, situate in ......
2. Ever since the ....... day of ...... 19......., 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 land.
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 livestock 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 there from, and has been prevented from having so beneficial and healthy use and occupation of the lands as he otherwise would have had.

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This is a reference draft reproduced for study and adaptation. Court rules, court fees and the correct forum vary with the facts and the value of the claim, so have the document checked and filed by an advocate. A defective application can be returned or dismissed even when the case itself is good.

Our Civil Litigation team drafts and files these documents before the Calcutta High Court, city civil courts, magistrate, family and consumer courts in Kolkata. Our civil litigation team handles drafting, filing and arguments in Kolkata courts.

Disclaimer: this page is a sample format reproduced for reference and study. It is not legal advice and does not create an advocate–client relationship.

Carrying on a Noxious Manufacture: Format & Sample

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