Model Issue : ISSUES RELATING TO RENT SUITS

ISSUES RELATING TO RENT SUITS

1. Whether the plaintiff proves that the defendant is a tenant of the Suit property at a monthly rent of Rs…….. ?
2. Whether the plaintiff proves that the monthly rent of the Suit premises is Rs……… ?
3. Whether the plaintiff proves that the defendant is in arrears of rent for more than six months ?
4. Whether the plaintiff proves that the defendant has neglected to pay the due amount of rent within one month from the date of service of Notice ?
5. Whether the plaintiff proves that the defendant has changed the use of the rented premises ?
6. Whether the plaintiff proves that the defendant has without his consent or knowledge, made construction of permanent nature in the Suit premises which cannot be removed without causing serious damages to the property ?
7. Whether the plaintiff proves that the defendant is using the premises in such a way which creates nuisance and annoyance to the adjoining/neighbouring occupiers, as alleged ?
8. Whether the plaintiff proves that the defendant No. without his consent or knowledge, has subletted the Suit premises to the defendant No…. against the terms and conditions of the agreement ?
9. Whether the plaintiff proves that the defendant was permitted to reside in the Suit premises as an employee of the plaintiff but now he ceased to be an employee ?
10. Whether the plaintiff proves that the Suit property is required for reasonable and bonafide requirements of the plaintiff himself & his family members ?
11. Whether the plaintiff proves that the suit property is reasonably and bonafide required for carrying out repairs ?
12. Whether the plaintiff proves that premises are required for the immediate purpose of demolition and that such demolition has been ordered by the Competent authority ?
13. Whether the plaintiff proves that the Suit premises are required for erecting new building ?
14. Whether the plaintiff proves that the Suit premises have not been used without reasonable cause for the purpose for which the premises let, for a continuous period of six months immediately preceding the date of the Suit ?
15. Whether the plaintiff proves that the defendant has acquired suitable residence, as alleged ?
16. Whether the plaintiff proves that the defendant is using the Suit premises for immoral and illegal purposes, as alleged ?
17. Whether the plaintiff proves that the defendant has committed breach of terms of tenancy, as alleged ?

18. Whether the defendant proves that the rent claimed by the plaintiff is not a standard rent ?
19. Whether the defendant proves that he has already paid the rent to the plaintiff but he never issued receipt thereof to the defendant ?
20. What should be the standard rent & permitted increases on the Suit premises ?
21. Whether the defendant proves that he had also sent the amount of rent by Money Order but the plaintiff refused to accept the amount ?
22. Whether the defendant proves that he was and is ready and willing to pay the due amount of rent ?
23. Whether the defendant proves that the Notice of demand issued by the plaintiff is illegal and invalid ?
24. Whether the defendant proves that the Suit is bad for non joinder of necessary of parties ?
25. Whether the defendant proves that this Court has no jurisdiction to entertain the Suit ?
26. Whether the defendant proves that the Suit is bad for non joinder of necessary parties ?
27. Whether the defendant proves that the Suit is barred by principles of resjudicate ?
28. Whether the defendant is entitled to get compensatory costs as prayed for ?
29. Whether the plaintiff is entitled to get the vacant possession of Suit premises ?
30. Whether the plaintiff is entitled to get mesne profits ?
31. What s due to the plaintiff ?
32. What order and decree ?