The 4 Golden Rules of Pleadings (Order VI Rule 2 CPC)
1. Plead Facts, Not Law: The plaint or written statement must state the material facts on which the party relies, leaving the legal conclusions to the court.
2. Plead Material Facts Only: Every fact necessary to prove the cause of action must be specifically stated.
3. Do Not Plead Evidence: State the facts (facta probanda), not the evidence by which facts will be proved (facta probantia).
4. Be Concise, Precise, and Chronological: Use short numbered paragraphs.
Standard Anatomy of a Civil Plaint (Order VII CPC)
Every Civil Plaint contains seven standardized components:
1. Court Header: In the Court of Principal Senior Civil Judge at Ahmedabad
2. Suit Number & Cause Title: Special Civil Suit No. ___ of 2026 (Plaintiff vs Defendant)
3. Introductory Description: Full names, occupations, and residential addresses of parties.
4. Facts Constituting Cause of Action: Chronological series of transactions or events.
5. Jurisdiction & Valuation Paragraph: Territorial/pecuniary jurisdiction and court fee calculation under Gujarat Court Fees Act.
6. Prayer Clause (Reliefs Sought): Clear, enumerated claims for decree, injunction, interest, and costs.
7. Verification Clause & Affidavit: Signed declaration on personal knowledge and belief.