Wrongful Dismissal

(Title)

A.B., the above-named plaintiff states as follows:-

1.      On the ..........day of......... 19........., the plaintiff and defendant mutually agreed that the plaintiff should serve the deferant as [as accountant, or in the capacity of foreman, or as the case may be], and that the defendant should employ the plaintiff as such for the term of [one year] and pay him for his services rupees [monthly].

2.      On the ........day of ........19.........., the plaintiff entered upon the service of the defendant and has ever since been, and still is, ready and willing to continue in such service during the remainder of the said year whereof the defendant always has had notice.

3.      On the .........day of ........19........., the defendant wrongfully discharged the plaintiff, and refused to permit him to serve as aforesaid, or to pay him for his services.

[As in paras.4 and 5 of Form No.1, and Relief claimed.]