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The draft of a plaint to sue for recovery of damages depends upon the type of damages you are claiming. There are many types of claims for damages. Some of the categories are :
1. Damages under torts;
2. Damages under contracts and also for breach of them;
3. Damages under personal laws;
4. Damages for civil & criminal liabilities; and
5. Other types of damages.
In every case of damages you should first make a specific case as to how the liability for damages arise keeping in view the position of law of the land. So first give a description of the facts which make a liability for damages.
After this you should give details of each violation of fact and law with the damages. The amount of damages with account should be explained as to how you reach the figure of claim. This is necessary because the court will have to consideration all the circumstances which give cause of action for the claim.
The rest of the draft will be as usual as per requirement of law.
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