IN THE COURT OF _____ JUDGE, SENIOR DIVISON, ___________.
______________ Versus. _______________
Suit for Declaration with the consequential relief of Permanent Injunction
________ of Shri _________ R/o _________________
District ___________, do hereby solemnly affirm and declare as under:
1- That the deponent was appointed by the defendants in the Defendant No.1 School on the vacant post of __________ on _________ through the _____________, _________ on a monthly salary of Rs. ________ per month. The copy of appointment letter is enclosed herewith the plaint.
2- That ever since the date of her employment as ___________ with the defendants the deponent regularly and continuously discharged her duties upto the year ________. Thereafter, the defendants after passing a proposal kept the deponent continued her services. The salary of the deponent was released by the defendants from the ____________ in the year ________. The defendant No.1 wrote the letter dated ____________ to the defendant No. 3 in this regard. The copy of the letter is enclosed.
3- That the defendants further extended the period of service of the deponent from time to time. The defendant No.1 wrote various letters to the defendant No. 3 in respect of the service of the plaintiff, extension of the period of service of the deponent vide letters dated _________________, upto __________. The photocopies of the letters are enclosed herewith for the kind perusal of this hon’ble court.
4- That the respondent No.1 wrote the letter bearing its Memo No. ____ dated __________ to the defendant No. 3 for the extension of the period of the deponent upto the year ________. Thereafter the services of the deponent were continued by the defendants on the said terms and conditions and she was kept as Part time ________ upto the year _________. The defendants paid the salary amount of the deponent for the year ______ vide their Account payee Cheque No. _________ dated _______ for Rs. ______/-. The defendants again continued the part time services of the deponent for the year 2005-2006_________ and they also made the payment of the salary through the Account Payee Cheque No..__________ for Rs. ___________. After a span of about _ years continuous and regular services of the plaintiff, the defendants being satisfied with the works of the plaintiff, and the deponent never gave any chance for any complaint to the defendants. Due to the long span of time she has become regular employee and she has become entitled for all the benefits of a permanent and regular employee.
5- That now the defendants with a malafide intention for the purpose of recruiting some other employee at the post of the deponent are bent upon to terminate the services of the deponent forcibly and illegally. The defendants are also threatening the deponent to submit her resignation voluntarily to them, sign the resignation, full and final vouchers of the payment otherwise they would forcibly took the signatures of the deponent and would terminate her immediately.
6- That the deponent requested the defendants several times to see reason and to terminate her from her services as she has no other source of income for her livelihood. The deponent also requested the defendants to regularly her services as part time _______ but the defendants refused to regularize the services of the deponent and they threatened that they would recruit some other person in place of services of the plaintiff.
7- That the cause of action to file the present suit accrued on each and every date when the defendants extended the period of services of the deponent and it further arose on ___________ when the Cheque for the salary of the deponent was handed over by the defendants to the plaintiff. The cause of action further arose on _________ when the defendants threatened the deponent to terminate her services forcibly and illegally. Hence _____ is the final date of cause of action arose in favour of the deponent and against the defendants. Hence this suit.
Verified that the contents of my above affidavit are true and correct to best of our knowledge and belief and nothing material has been concealed therein.
Verified at ___________ on
Sunday, March 21, 2010
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