Wrongful Dismissal - Legal Draft

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.]