How to draft a plaint using AI: save time and ensure legal accuracy

This article is your roadmap to mastering AI-assisted drafting of plaint without falling into common traps. You will learn how to transform AI from a potential liability into your secret weapon, one that helps you draft faster, think more systematically, and present your client’s case with the precision your senior expects. If you are a lawyer or law student who has ever struggled with the time-consuming process of drafting a plaint from scratch, this guide is for you.

Introduction

It was a Friday evening, and I was planning to end my day early and catch up with some friends.

That is when my senior came up to my desk with a bunch of files, “We need a plaint drafted by Monday morning, and the facts are in the file.”

This is a common phenomenon in law firms, isn’t it? The day you decide to leave early, you are handed over more tasks to complete.

I know many reading this can relate to it.

As my senior walked away, I opened the file to find a maze of documents. I panicked and wondered how do I weave these scattered facts into a legally sound and persuasive plaint that will impress my senior, court and most importantly, the client?

Does this sound familiar to you?

Junior lawyers often find themselves tasked with drafting pleadings, which serve as the foundation of every civil suit. For those who are unaware, let me tell you that pleadings means plaint or written statement.

So today, let me teach you something that will change how you approach drafting a plaint forever.

Drafting a plaint is one of the most fundamental skill required in litigation practice. It is your opportunity to present your client’s case in a structured, persuasive manner that sets the stage for everything that follows.

However, let me be honest, it can be a time-consuming process and often frustrating when you are staring at a blank page for hours, trying to organize complex facts into clear, concise legal language.

Today, I will show you how artificial intelligence can become your most valuable drafting assistant.

You surely might have heard about tools like ChatGPT, Claude, and other AI platforms and some of you here might have even tried using it.

For those who are new to it, let me tell you that these tools can dramatically speed up your drafting process, help you organize your thoughts, and even suggest some points. But the key here is that it is possible only if you know how to use AI correctly.

Here is what I want you to understand from the start: AI is not going to replace your legal judgment. It cannot understand the nuances of your local court or capture the unique aspects of your client’s situation. What it can do is serve as an incredibly efficient starting point and a brainstorming partner.

In this article, I will walk you through the exact process I use to draft a plaint using AI. You will learn how to structure your prompts, what to ask AI to do (and what not to ask), and most importantly, how to edit and refine AI-generated content so it sounds like it has been drafted by some experienced lawyer and not some generic computer-generated template.

Before moving to drafting, let us understand certain core concepts that are important for you to know.

What is a plaint?

A plaint is a written legal document filed by the person initiating a civil suit in a civil court.

A plaint essentially outlines the details of the case, the cause of action, and the relief the plaintiff seeks.

Plaint forms an essential element in any proceeding that is filed in the court, without which the court cannot arrive at any conclusion.

Your senior has probably seen hundreds of poorly drafted plaints where the facts are jumbled or where the relief sought appears disconnected from the cause of action.

So when your senior says “draft a plaint,” they are not just simply asking you to prepare a document. They require a legally compliant document that complies with Order VII of the Code of Civil Procedure, 1908.

Something that law schools don’t teach you is that a well-structured plaint is like a good story. It should flow logically from “what happened” to “what we want the court to do about it.”

But let me tell you that a plaint that is not well drafted does not just look unprofessional, but it can actually weaken your client’s case.

Now, do you understand that it is not just a legal formality, but it is about your client’s first impression before the court.

Was this easy? Keep reading further.

What are the pre-requisites of a plaint?

Have you gone through Order VII Rule 1 of the Code of Civil Procedure, 1908?

So, Order VII Rule 1 of the Code of Civil Procedure, 1908, outlines the essential particulars that must be included in a plaint.

Yes, you got me right, like others, a plaint also shall consist of certain particulars..

It is vital to understand these before drafting a plaint as this forms the base of your plaint drafting.

Let us read what those particulars are that are mentioned in Rule 1.

Rule 1 (a) – Name of the court

You must specify the name of the Court in which the suit is brought.

Rule 1(b) – Name of the Plaintiff

You must mention the name, description and place of residence of the plaintiff;

Rule 1(c) – Name of the Defendant

You must also clearly mention the name, description and place of residence of the defendant, so far as they can be ascertained;

Rule 1 (d) – If Plaintiff or Defendant is a minor or of unsound mind

You must mention if the plaintiff or the defendant is a minor or a person of unsound mind; a statement to that effect shall be given.

Rule 1(e) – Cause of action

Remember, this is crucial. You need to explain the facts constituting the cause of action and when it arose.

Rule 1(f) – Jurisdiction

This also forms a crucial part of the plaint; you need to show the facts that demonstrate the Court has jurisdiction.

Do you know that Jurisdiction is primarily determined based on territorial and pecuniary considerations?

Territorial jurisdiction

Territorial jurisdiction refers to the geographical area within which a court has the authority to adjudicate matters. Territorial Jurisdiction is determined based on:

Place where the cause of action arose – If an event giving rise to the dispute occurred within a particular territory, the courts of that area will have jurisdiction.
Location of the defendant – The suit can be filed where the defendant resides or carries on business.
Contractual jurisdiction clause – If the parties have agreed in a contract that disputes will be resolved in a specific court, that court will have jurisdiction.

Let me give you an example of how the clause will look like:
“The Hon’ble Court has jurisdiction to entertain and try the present suit as the cause of action arose within its territorial jurisdiction. The Agreement dated 10th October 2020 was executed in New Delhi, and the Defendant has its principal place of business in Connaught Place, New Delhi, which falls within the jurisdiction of this Hon’ble Court. Further, as per Clause 12 of the Agreement, the parties agreed to submit to the exclusive jurisdiction of the courts in New Delhi.”

Now, let us see the pecuniary jurisdiction

Pecuniary jurisdiction

Pecuniary jurisdiction refers to the financial limits within which a court can hear cases. Courts are categorised based on their power to hear suits of a particular monetary value. If the claim amount exceeds a lower court’s jurisdictional limit, the case must be filed in a higher court.

This is an example of how the clause will look like:
“The Plaintiff claims a sum of ₹50,00,000 as damages, which falls within the pecuniary jurisdiction of this Hon’ble Court.”

Rule 1(g) – Reliefs sought

This basically relates to what you want from the court. It is basically the relief that the plaintiff claims.

Let me show you how your prayer clause will look like in a suit for recovery of money:

“It is, therefore, most respectfully prayed that this Hon‟ble Court may be pleased to:-

(a) Pass a decree for Rs. 4,19,200/-(Four Lac Nineteen Thousand and Two Hundred only) with interest @ 18% per annum from 18.4.2024 upto the date of filing the suit in favour of the Plaintiff and against the Defendant;

(b) award pendente lite and future interest at the rate of 18% per annum on the above-stated amount of Rs. 4,19,200/-(Four Lac Nineteen Thousand and Two Hundred only) with interest @ 18% per annum from 18.4.2024 up to the date of filing the suit in favour of the Plaintiff and against the Defendant;

(c) award the cost of the suit in favour of the Plaintiff and against the Defendant; and

(d) pass such other and further order(s) as may be deemed fit and proper on the facts and in the circumstances of this case.”

Rule 1 (h) – Set off or relinquished claim

You shall also mention where the plaintiff has allowed a set-off or relinquished a portion of his claim; the amount so allowed or relinquished shall be mentioned.

Rule 1(i) – Court fees

You should also mention a statement of the value of the subject matter of the suit for the purposes of jurisdiction and of court fees, so far as the case admits.

This was quite insightful, right? You can read Order VII Rule 1 of Code of Civil Procedure, 1908 for better understanding.

Did you know that your plaint can be rejected if all the pre-requisites are not met? No matter how strong your claim is, the court will not entertain it, if the plaint is defective and your case is over even before it begins.

Order VII Rule 11 of the Code of Civil Procedure, 1908 speaks of rejection of plaint.

Coming to the drafting bit.

How to use AI to draft a plaint?

Let me tell you a little about the matter. Arjun was our client and his family property got into a legal mess and the matter has been dragging on. I took some brief notes while sorting the papers:

Grandfather had a flat → died in 1995 → family kept paying rent → relative illegally occupied in 2023 → wants it back

A classic property dispute.

Also, I will be using ChatGPT to draft this plaint.

Here, it is essential to give the right prompts. If you do not give specific prompts, then you will not get the desired result and I have seen people make this mistake all the time.

Let me show you exactly how I used AI to draft the plaint, step by step.

Step 1: Don’t jump into drafting – understand your case first

Here’s where most people go wrong: Most people directly ask ChatGPT, “Draft a plaint for me.” I, too, have made this mistake, so don’t worry.

It is like asking a junior to draft something without giving any details or documents of the matter.

What I do instead is make AI my legal research assistant first.

This is the prompt that I gave to ChatGPT:

“There is a property dispute and I need to understand what type of legal case this is, before drafting anything. Let me give you the basic facts:

– My client’s grandfather was the tenant of a flat in Mumbai.

– My client’s grandfather died in 1995

– Client’s family has been paying rent on and off since then

– A relative illegally occupied the flat in 2023 when my clients were temporarily not using it

– My client wants to get the flat back

Before we draft anything:

1. What type of legal case is this?

2. What kind of legal document do I need to file?

3. Who should I sue?

4. What laws govern this situation?

Please ask me any questions you need to understand this better.”

Based on my prompt, this is what ChatGPT wrote back:

“Based on your facts, this appears to be a property dispute involving tenancy rights. Here’s my analysis:

1. Type of case: This is a suit for possession with a declaration of rights

2. Legal document needed: A civil plaint under Order VII Rule 1 of CPC

3. Who to sue:

– The relative currently occupying (primary defendant)

– Possibly the landlord (for tenancy transfer issues)

4. Governing laws:

– Maharashtra Rent Control Act

– Code of Civil Procedure, 1908

– Indian Succession Act (for inheritance rights)

I need more details:

– Is this a municipal/government flat or a private landlord?

– Do you have documents proving your grandfather’s tenancy?

– Are rent receipts still in the grandfather’s name?

– What’s your exact relationship to the illegal occupant?

– Have you sent any legal notice?

– Which court jurisdiction (which area of Mumbai)?”

Step 2: Building the complete picture

Now I give ChatGPT everything it asked for, this is where the magic happens.

This is the prompt that I gave:

Thanks for that analysis. Here are the additional details you asked for:

– It’s a municipal corporation flat (Brihan Mumbai Mahanagar Palika)

– Rent receipts are still in my grandfather Pradeep Mohan Sharma’s name

– The illegal occupant is Rekha Mohan Sharma – she’s my father’s sister-in-law

– I have a death certificate, family documents proving inheritance

– I’ve been paying rent and utilities

– I sent a legal notice in April 2023, and she ignored it

– The property is located in Dadar West, so the Bombay City Civil Court jurisdiction

– She occupied it around 2023 when we temporarily closed it for family medical reasons

Now, can you tell me:

1. What specific reliefs should I ask for?

2. What evidence do I need to attach?

3. What’s the structure of the plaint I need to file?”

Based on the information provided, ChatGPT generated the following:

Perfect! Now I have a complete picture. Here’s what you need:

RELIEFS TO SEEK:

1. Declaration that you have legitimate rights as legal heir

2. Possession of the flat from Rekha

3. Permanent injunction restraining her from interfering

4. Interim relief to prevent her from creating third-party rights

5. Costs of the suit

EVIDENCE TO ATTACH:

– Exhibit A: Original rent receipt in grandfather’s name

– Exhibit B: Death certificate + family documents

– Exhibit C: Recent rent/utility receipts you paid

– Exhibit D: Legal notice + acknowledgment

– Exhibit E: List of documents

PLAINT STRUCTURE:

1. Court heading and suit number

2. Party details (you vs Brihan Mumbai Mahanagar Palika + Rekha)

3. “Plaint under Order VII Rule 1” heading

4. Numbered paragraphs with facts

5. Jurisdictional grounds

6. Limitation analysis

7. Prayer clause

8. Interim relief prayer

9. Verification

Should I now help you draft each section systematically?”

Step 3: Starting the actual drafting – Header and parties

Alright, now we get to the actual drafting.

But here is my golden rule: Never ask AI to draft the entire document at once.

Why? Because AI becomes overwhelmed and starts making mistakes or gets formatting wrong.

Instead, I build it section by section, it is like assembling IKEA furniture with proper instructions

This is what I told ChatGPT:

“Let’s start drafting the plaint systematically. First, I need you to draft just the header section and party details. Use these exact details:

PLAINTIFF: Arjun Pradeep Sharma, age 35, Software Engineer, residing at 22, Sunrise Apartments, 3rd Floor, Gandhi Road, Borivali (West), Mumbai – 400092

DEFENDANTS:

1. The Brihan Mumbai Mahanagar Palika, Estate Department, “E” Ward, Mumbai 400011

2. Rekha Mohan Sharma, age 68, Retired Teacher, residing at B/14, Shanti Niketan Society, S.V. Road, Andheri (West), Mumbai – 400058, currently occupying Flat No. 203, Navrang Chawl, Plot No. 17, Dadar (West), Mumbai 400 028

Draft only the heading, suit number line, party details, and the case title line. Make it look professional and follow proper legal formatting.”

Accordingly, the ChatGPT generated the following result:

“IN THE BOMBAY CITY CIVIL COURT AT BOMBAY

SUIT NO. ______ OF 2025

Arjun Pradeep Sharma,

aged 35 years, of Bombay, Indian Inhabitant,

Occupation: Software Engineer,

residing at 22, Sunrise Apartments,

3rd Floor, Gandhi Road,

Borivali (West), Mumbai – 400092

…Plaintiff

VERSUS

1. The Brihan Mumbai Mahanagar Palika,

Estate Department, “E” Ward,

Mumbai 400011

…Defendant No.1

2. Rekha Mohan Sharma,

aged 68 years, of Bombay, Indian Inhabitant,

Occupation: Retired Teacher,

residing at B/14, Shanti Niketan Society,

S.V. Road, Andheri (West), Mumbai – 400058

at present occupying Flat No. 203,

Navrang Chawl, Plot No. 17, Dadar (West),

Mumbai 400 028

…Defendant No.2

PLAINT UNDER ORDER VII RULE 1 OF THE CODE OF CIVIL PROCEDURE, 1908 FOR DECLARATION, POSSESSION AND PERMANENT INJUNCTION”

Step 4: The opening story

Now I need to establish the foundation of the case.

But first, let me explain something important. In Mumbai, many flats are owned by the Municipal Corporation (Brihan Mumbai Mahanagar Palika), not private landlords. The Brihan Mumbai Mahanagar Palika acts as the landlord and issues rent receipts. That is the reason why we are suing them as Defendant No.1.

Moving on.

When using AI, it is tempting to just say, “use these facts and ask ChatGPT to draft the opening paragraphs”.

But that is incorrect. I will show you the correct way of doing it.

Accordingly, I gave the following prompt:

“Now let’s draft the opening paragraphs (1-4) of the plaint. These should establish:

1. Who the plaintiff is and his relationship to the original tenant

2. Who the defendants are and their roles (remember Brihan Mumbai Mahanagar Palika is the municipal landlord of this property)

3. Description of the suit property

4. The inheritance/succession rights

Use these key facts:

– Original tenant: Late Pradeep Mohan Sharma (died 15th March 1995)

– Property: Flat No. 203, Navrang Chawl, Plot No. 17, Dadar (West), Mumbai 400 028

– Plaintiff’s father: Suresh Pradeep Sharma (son of original tenant)

– This is a municipal flat where Brihan Mumbai Mahanagar Palika is the landlord who issues rent receipts

– Governed by Maharashtra Rent Control Act

– Plaintiff and brother Vikash Suresh Sharma are legal heirs

Start with “MOST RESPECTFULLY SHOWETH:” and number the paragraphs. Make it sound authoritative but clear. Reference Exhibit “A” for rent receipt and Exhibit “B” Colly for family documents.”

This is what ChatGPT generated for me:

“MOST RESPECTFULLY SHOWETH:

1. The Plaintiff is the grandson of late Pradeep Mohan Sharma, who was the original tenant of the suit premises, namely Flat No. 203, Navrang Chawl, Plot No. 17, Dadar (West), Mumbai 400 028. The Plaintiff’s father, Suresh Pradeep Sharma, was the son of the original tenant and one of the legal heirs entitled to the tenancy rights of the said premises.

2. Defendant No. 1 is the Brihan Mumbai Mahanagar Palika, which is the landlord of the suit premises and the authority responsible for the maintenance of rent receipts and tenancy records. Defendant No. 2 is the sister-in-law of the Plaintiff’s father and has been illegally occupying the suit premises without any legal right, title or interest therein.

3. The suit premises consist of Flat No. 203, Navrang Chawl, Plot No. 17, Dadar (West), Mumbai 400 028, which is a tenanted premises governed by the provisions of the Maharashtra Rent Control Act. The rent receipts for the said premises currently stand in the name of late Pradeep Mohan Sharma, who expired on or about 15th March 1995. A copy of the rent receipt is hereto annexed and marked as Exhibit “A”.

4. The Plaintiff submits that after the death of the original tenant Pradeep Mohan Sharma in 1995, his legal heirs including the Plaintiff’s father Suresh Pradeep Sharma had legitimate rights of succession to the tenancy. The Plaintiff and his elder brother Vikash Suresh Sharma derive their rights through their father as legal heirs and successors-in-interest of the original tenant. Copies of the death certificate and family documents are hereto annexed and marked as Exhibit “B” Colly.”

Step 5: Demonstrate the rights of the Plaintiff

Now here is a crucial legal strategy lesson: In property cases, you need to show the court that your client is not just claiming rights on paper but he has been actively exercising those rights.

This is called “demonstrating continuing interest.”

But if you simply ask ChatGPT to “write paragraphs about rent being paid by the Plaintiff,” you will not get the desired result.

Your aim should be to train AI not only to generate narratives but also to interpret and draw inferences from the facts.

Therefore, I gave the following prompt:

“Now let’s draft paragraphs 5-6 that show the plaintiff has been actively maintaining his rights. These paragraphs should cover:

1. How the plaintiff has been paying rent and utilities (proving he’s the real tenant)

2. The family situation that led to temporary closure of the flat

Use these specific facts:

– Arjun has been paying rent to Brihan Mumbai Mahanagar Palika

– He’s been paying electricity, water charges, and municipal outgoings

– This proves he’s exercising his rights as a legitimate successor

– In 1998, his parents bought an additional flat at Borivali for convenience

– The family used both places as needed

– Mother Kavita Sharma developed a serious heart condition

– Due to the mother’s medical issues, the suit premises were temporarily closed

– Reference Exhibit “C” Colly for rent receipts and utility bills paid by plaintiff

Make sure to emphasize that he’s been acting like the rightful tenant, not an outsider making claims.”

You can see the following result that the ChatGPT has generated based on the prompt given.

“5. The Plaintiff has been paying the rent of the said premises to Defendant No. 1 and maintaining the same by discharging all obligations including electricity charges, water charges, and other municipal outgoings. The Plaintiff has been exercising his rights as a legitimate occupant and successor to the original tenant. Copies of rent receipts and utility bills paid by the Plaintiff are hereto annexed and marked as Exhibit “C” Colly.

6. The Plaintiff submits that when his parents Suresh Pradeep Sharma and Kavita Sharma purchased an additional flat at Borivali in 1998, the family used to reside at both places as per their convenience. However, due to the serious heart condition and various ailments of the Plaintiff’s mother Kavita Sharma, the suit premises was temporarily kept closed for medical reasons.”

Step 6: Write about the interference of the Defendant with Plaintiff’s right

Now comes the dramatic part.

This is where we need to show that Rekha took illegal advantage.

In legal drafting, you want to make the defendant’s actions sound clearly wrong and intentional.

Now, people are usually tempted to use AI to create dramatic accusations. And ChatGPT loves adjectives. But this is where you teach restraint.

But do not ask ChatGPT to “make it look illegal.”

Instead:

Teach it how to factually describe trespass.
Then guide AI to use precise legal terms such as “criminal trespass,” “wrongful restraint.”

Therefore, I gave ChatGPT the following prompt:

Now, let’s draft paragraphs 7-9 that illustrate how Defendant No. 2 took advantage of the situation illegally. These should cover:

1. How Rekha illegally occupied the premises

2. The threats she made to the plaintiff

3. The legal notice that was ignored

Use these key facts:

– Rekha took “undue advantage” of the temporary closure

– She “illegally broke open the lock” and “forcibly occupied” the flat

– She has “no legal right or authority”

– When Arjun tried to visit, she threatened him clearly

– She warned him not to come to the premises or even visit the building

– This amounts to “criminal trespass and wrongful restraint”

– Legal notice sent on 8th April 2023

– She “failed, refused and neglected to comply”

– Reference Exhibit “D” for legal notice and postal acknowledgment

Use strong legal language that makes her actions sound clearly illegal, but don’t be emotional or over-the-top.”

See how the ChatGPT has generated the result for me below:

“7. Defendant No. 2, taking undue advantage of the temporary closure of the premises, illegally broke open the lock of the said premises and forcibly occupied the same without any legal right or authority. Defendant No. 2 has been unlawfully staying in the suit premises and preventing the Plaintiff from exercising his legitimate rights of occupation and possession.

8. The Plaintiff submits that when he attempted to visit and inspect the suit premises, Defendant No. 2 threatened him in clear and unambiguous terms not to come to the suit premises and warned him against visiting the building. Such threats and intimidation amount to criminal trespass and wrongful restraint of the Plaintiff’s lawful rights.

9. The Plaintiff issued a legal notice dated 8th April 2023 to Defendant No. 2 calling upon her to immediately vacate the suit premises and hand over peaceful possession thereof to the Plaintiff. Despite service of the said notice, Defendant No. 2 has failed, refused and neglected to comply with the same. A copy of the legal notice dated 8th April 2023, along with postal acknowledgment, is hereto annexed and marked as Exhibit “D”.

Step 7: Creating urgency and establishing the cause of action

You need to demonstrate to the court why this case is urgent and why they should act promptly. We call this “apprehension of further damage”, basically showing the judge that if any action is not taken then, things will get much worse.

Once again, people would usually type “make it urgent,” and ChatGPT responds with words like “irreparable injury” or “third party rights.”

But you need to justify urgency, not just assert it. You need to ask AI to explain:

How will third-party rights emerge?
Why is this risk real and not hypothetical?

See the following prompt I gave to ChatGPT:

Now let’s draft paragraphs 10-11 that create urgency and establish cause of action. These should cover:

1. Plaintiff’s fears about what Rekha might do next (apprehension of further damage)

2. When and where the cause of action arose

Use these strategic points:

– Rekha may create “third-party rights” in the premises

– She may “transfer or assign her illegal occupation to others”

– She may try to get the tenancy transferred in her name from Defendant No. 1

– This would cause “irreparable loss and injury” to the plaintiff’s rights

– The cause of action arose when she illegally occupied in 2023

– She threatened the plaintiff and ignored the legal notice

– The cause of action is “continuing day by day” as long as she stays

– Everything happened in Mumbai within this court’s territorial jurisdiction

Make it sound like urgent action is needed to prevent disaster, but keep it legally sound.

Based on the prompt, the following result was generated by GPT:

10. The Plaintiff apprehends that Defendant No. 2 may create third party rights in the suit premises, may transfer or assign her illegal occupation to others, or may attempt to get the tenancy transferred in her name from Defendant No. 1, which would cause irreparable loss and injury to the Plaintiff’s legitimate rights and interests in the suit premises.

11. The cause of action for the present suit arose when Defendant No. 2 illegally occupied the suit premises in or around the year 2023, threatened the Plaintiff, and continued her unauthorized occupation despite legal notice. The cause of action is continuing day by day as long as Defendant No. 2 remains in illegal occupation. The cause of action arose within the territorial jurisdiction of this Hon’ble Court as the suit premises are situated in Mumbai.

Step 8: The critical stuff – Jurisdiction and limitation

This section can make or break your case.

If you mess up the jurisdiction or limitation, the defendant will get your case thrown out before you even get to argue the real issues.

Instead of asking AI to write the limitation clause, I will give the following prompt.

“Now let’s draft the technical legal requirements in paragraphs 12-14. These must cover:

1. Territorial jurisdiction (why this court can hear the case)

2. Limitation period (why we are not too late to file)

3. Valuation and court fees

Use these specific legal points:

– This court has territorial jurisdiction as the suit premises are within the territorial limits

– The cause of action arose within this jurisdiction

– Suit valued at ₹8,00,000/- for jurisdiction and court fees

– Falls within the pecuniary jurisdiction of this court

– Limitation: Arjun’s right to seek possession arose when Rekha illegally occupied in 2023

– Therefore, not barred by limitation

– Court fees paid according to the Court Fees Act

Make it sound technical and authoritative.”

You can see how ChatGPT wrote those paragraphs for me below.

“12. This Hon’ble Court has territorial jurisdiction to try and entertain the present suit as the suit premises are situated within the territorial limits of this Court and the cause of action wholly arose within the jurisdiction of this Court. The suit is valued at ₹8,00,000/- for the purpose of jurisdiction and court fees, which falls within the pecuniary jurisdiction of this Hon’ble Court.

13. The present suit is filed well within the prescribed period of limitation. The Plaintiff’s right to seek possession arose when Defendant No. 2 illegally occupied the premises in or around the year 2023. Therefore, the suit is not barred by limitation.

14. The Plaintiff values the suit at ₹8,00,000/- for the purpose of jurisdiction and court fees. Court fee of ₹____/- has been paid accordingly as per the Court Fees Act.”

Step 9: The administrative paragraphs

We are almost there. These are the administrative paragraphs that every plaint needs. Consider them essential for maintaining legal compliance.

Keep it simple and standard; these are just procedural requirements.

This is my prompt:

“Now let’s draft the final administrative paragraphs 15-16 before we get to the prayer clause. These should cover:

1. Documents that will be relied upon

2. Confirmation that no other suit has been filed

Use these standard legal points:

– Plaintiff will rely upon documents, list annexed.

– Plaintiff has not filed any other suit in this court or any other court

-Same cause of action or any part thereof”

Accordingly, ChatGPT gave the following result:

15. The Plaintiff will rely upon the documents, a list whereof is hereto annexed as Exhibit “E”.

16. The Plaintiff has not filed any other suit in this Hon’ble Court or any other Court in respect of the same cause of action or any part thereof.

Step 10: Prayer clause

Here is where we finally ask for what we want.

This is like the climax of our legal story, after all that setup, what exactly do we want the court to do for us?

But do not ask ChatGPT to give all the relief possible in the suit because you will get irrelevant results.

It is rather better to give specific reliefs as per your understanding of the law and ask ChatGPT to frame it properly.

Accordingly, I gave the following prompt:

“Write the prayers (paragraph 17) for this suit in the following manner:

“In the circumstances aforesaid, the Plaintiff humbly prays that this Hon’ble Court may be pleased to:”

Then list these specific reliefs:

a) Declare that the plaintiff has legitimate rights as the legal heir of the original tenant

b) Direct Defendant No. 2 to vacate and hand over possession of the flat

c) Permanently restrain Defendant No. 2 from interfering with the plaintiff’s possession

d) Permanently restrain her from creating third-party rights or transferring occupation

e) Pending hearing and final disposal of the suit, temporarily restrain her from creating third-party rights or transferring occupation.

f) Award the costs of the suit

g) Grant other relief as the court deems fit

Use formal legal language – “this Hon’ble Court may be pleased to” for each relief.”

Consequently, ChatGPT generated the following result for me:

“17. In the circumstances aforesaid, the Plaintiff humbly prays that this Hon’ble Court may be pleased to:

a) Declare that the Plaintiff has legitimate rights, title and interest in the suit premises as legal heir and successor-in-interest of the original tenant late Pradeep Mohan Sharma;

b) Direct Defendant No. 2 to immediately vacate the suit premises being Flat No. 203, Navrang Chawl, Plot No. 17, Dadar (West), Mumbai 400 028 and hand over vacant and peaceful possession thereof to the Plaintiff;

c) Permanently restrain Defendant No. 2, her agents, servants, and all persons claiming through or under her from interfering with the Plaintiff’s peaceful possession and enjoyment of the suit premises;

d) Permanently restrain Defendant No. 2 from creating any third party rights or interests in the suit premises or from transferring, assigning or parting with her unauthorized occupation in any manner whatsoever;

e) Pending hearing and final disposal of the suit, temporarily restrain Defendant No.2 from creating any third party rights or interests in the suit premises or from transferring, assigning or parting with her unauthorized occupation in any manner whatsoever;

f) Award costs of the suit in favour of the Plaintiff and against the Defendants; and

g) Grant such other and further relief as this Hon’ble Court may deem fit and proper in the interests of justice and equity.”

At the end, you can ask ChatGPT to collate all the results and share the full draft. This is the final draft that ChatGPT generated for me after following all the steps above.

You can now review the draft and manually edit the same.

I have edited this draft and made changes in red.

IN THE BOMBAY CITY CIVIL COURT AT BOMBAY

SUIT NO. ______ OF 2025

Arjun Pradeep Sharma,

aged 35 years, of Bombay, Indian Inhabitant,

Occupation: Software Engineer,

residing at 22, Sunrise Apartments,

3rd Floor, Gandhi Road,

Borivali (West), Mumbai – 400092

…Plaintiff

VERSUS

1. The Brihan Mumbai Mahanagar Palika,

Estate Department, “E” Ward,

Mumbai 400011

…Defendant No.1

2. Rekha Mohan Sharma,

aged 68 years, of Bombay, Indian Inhabitant,

Occupation: Retired Teacher,

residing at B/14, Shanti Niketan Society,

S.V. Road, Andheri (West), Mumbai – 400058

at present, occupying Flat No. 203,

Navrang Chawl, Plot No. 17, Dadar (West),

Mumbai 400 028

…Defendant No.2

PLAINT UNDER ORDER VII RULE 1 OF THE CODE OF CIVIL PROCEDURE, 1908 FOR DECLARATION, POSSESSION AND PERMANENT INJUNCTION

MOST RESPECTFULLY SHOWETH:

2. The Defendant No.1 is the Brihan Mumbai Mahanagar Palika, who ~~which~~ is the landlord of the suit premises and the authority responsible for the maintenance of rent receipts and tenancy records. The Defendant No.2 is the sister-in-law of the Plaintiff’s father and has been illegally occupying the suit premises without any legal right, title or interest therein.

3. The suit premises consist of Flat No. 203, Navrang Chawl, Plot No. 17, Dadar (West), Mumbai 400 028, which is a tenanted premises governed by the provisions of the Maharashtra Rent Control Act. The rent receipts for the said premises are currently in the name of the late Pradeep Mohan Sharma, who passed away on or about 15th March 1995. A copy of the rent receipt is hereto annexed and marked as Exhibit “A”.

4. The Plaintiff submits that after the death of the original tenant, Pradeep Mohan Sharma, in 1995, his legal heirs, including the Plaintiff’s father, Suresh Pradeep Sharma, had legitimate rights of succession to the tenancy. The Plaintiff and his elder brother, Vikash Suresh Sharma, derive their rights through their father as the legal heirs and successors-in-interest of the original tenant. Copies of the death certificate and family documents are hereto annexed and marked as Exhibit “B” Colly.

5. The Plaintiff has been paying the rent of the said premises to Defendant No.1 and maintaining the same by discharging all obligations, including paying electricity charges, water charges, and other municipal outgoings. The Plaintiff has been exercising his rights as a legitimate occupant and successor to the original tenant. The copies of rent receipts and utility bills paid by the Plaintiff are hereto annexed and marked as Exhibit “C” Colly.

6. The Plaintiff submits that the Plaintiff alongwith his father ~~when his parents~~ Suresh Pradeep Sharma and mother Kavita Sharma, have been residing in the suit premises. The Plaintiff had purchased an additional flat at Borivali in 1998, the family used to reside at both places ~~as per their convenience~~. However, due to the serious heart condition and various ailments of the Plaintiff’s mother Kavita Sharma, the suit premises was temporarily kept closed for medical reasons.

7. The Defendant No. 2, taking undue advantage of the temporary closure of the suit premises, illegally broke open the lock of the said suit premises and forcibly occupied the same without any legal right or authority. The Defendant No. 2 has been unlawfully staying in the suit premises and preventing the Plaintiff from exercising his legitimate rights of occupation and possession.

8. The Plaintiff submits that when he attempted to visit and inspect the suit premises, Defendant No.2 threatened him in clear and unambiguous terms not to come to the suit premises and warned him against visiting the suit premises ~~building~~. Such threats and intimidation amount to criminal trespass and wrongful restraint of the Plaintiff’s lawful rights.

9. The Plaintiff issued a legal notice dated 8th April 2023 to Defendant No.2 calling upon her to immediately vacate the suit premises and hand over peaceful possession thereof to the Plaintiff. Despite service of the said notice, Defendant No. 2 has failed, refused, and neglected to comply with the same. A copy of the legal notice dated 8th April 2023, along with postal acknowledgment, is hereto annexed and marked as Exhibit “D”.

10. The Plaintiff has an apprehension ~~apprehends~~ that Defendant No. 2 may create third party rights in the suit premises, may transfer or assign her illegal occupation to others, or may even attempt to get the tenancy transferred in her name from Defendant No.1, which would cause irreparable harm, loss and injury to the Plaintiff’s legitimate rights and interests in the suit premises.

11. The cause of action for the present suit arose when Defendant No.2 illegally occupied the suit premises in or around the year 2023, threatened the Plaintiff, and continued her unauthorised occupation despite legal notice. The cause of action is continuing ~~day by day~~ as long as Defendant No.2 remains in illegal occupation. The cause of action arose within the territorial jurisdiction of this Hon’ble Court as the suit premises are situated in Mumbai.

12. This Hon’ble Court has territorial jurisdiction to try and entertain the present suit as the suit premises are situated within the territorial limits of this Court and the cause of action wholly arose within the jurisdiction of this Court. The suit is valued at ₹8,00,000/- for the purpose of jurisdiction and court fees, which falls within the pecuniary jurisdiction of this Hon’ble Court.

14. The Plaintiff values the suit at ₹8,00,000/- for the purpose of jurisdiction and court fees. Court fee of ₹____/- has been paid accordingly as per the Court Fees Act.

15. The Plaintiff will rely upon the documents, a list whereof is hereto annexed as Exhibit “E”.

16. The Plaintiff has not filed any other suit in this Hon’ble Court or any other Court in respect of the same cause of action or any part thereof.

17. In the circumstances aforesaid, the Plaintiff humbly prays that this Hon’ble Court may be pleased to:

a) Declare that the Plaintiff has legitimate rights, title and interest in the suit premises as legal heir and successor-in-interest of the original tenant late Pradeep Mohan Sharma;

e) Pending hearing and final disposal of the suit, temporarily restrain Defendant No.2 from creating any third party rights or interests in the suit premises or from transferring, assignin, or parting with her unauthorized occupation in any manner whatsoever;

f) Award costs of the suit in favour of the Plaintiff and against the Defendants; and

g) Grant such other and further relief as this Hon’ble Court may deem fit and proper in the interests of justice and equity.

Alright, so we have walked through the entire process of drafting a plaint using AI, step by step, and I am sure you will be feeling a bit more confident about tackling that daunting pile of case files now!

Conclusion

Using AI can be a game-changer for drafting legal documents, it is all about giving it the right prompts and keeping a sharp eye on the output. As you saw with Arjun’s property dispute, breaking the process into parts like starting with understanding the case, building a clear structure, and crafting each section with precise instructions gives you a perfect draft.

But will not replace your legal brain or your ability to weave a compelling narrative for the court, but it can surely save you hours of staring at a blank page. With practice, you will churn out polished legal documents that will impress your seniors, the court, and, most importantly, your clients.

Frequently asked questions

What happens if my plaint is defective or does not meet legal requirements?

Your plaint can be rejected under Order VII Rule 11 of the Code of Civil Procedure, 1908. No matter how strong your claim is, if the plaint is defective, the court will not entertain it and your case is over before it begins. This is why understanding the prerequisites is essential.

What’s the difference between cause of action and relief sought?

Cause of action refers to the facts and circumstances that give you the legal right to sue (what happened that was wrong). Relief sought is what you want the court to do about it (the remedy you’re asking for). Both must be clearly connected in your plaint.

What is the proper way to write the prayer clause in a plaint?

The prayer clause should be specific and directly related to your cause of action. Use formal language like “this Hon’ble Court may be pleased to” for each relief. Include primary relief (main remedy sought), consequential relief (costs, interest), and a general prayer for “such other relief as the court deems fit.”