Using AI to draft a money recovery suit in under 20 minutes

In this article, you will learn how to draft a money recovery suit using AI, turning a 3-day deadline into a 20-minute strategic drafting session. You will receive a practical, step-by-step guide on using prompts to draft a perfect money recovery suit that will surely impress your seniors and also transform how lawyers approach urgent litigation drafting.

Introduction

“Back to office”, Priya announced dramatically. She was glowing with her Bali tan. Meanwhile, I was pretty sure I looked like someone who had spent the last two weeks binge watching series after series and eating too much homemade food.

“Look at you, all bronzed and beautiful,” Priya laughed, but I could tell her mind was still somewhere on the beach, sipping on some cocktail, while soaking up the sun on the beaches of Bali.

It is one of those classic post vacation feelings where your body is back at work but your soul is still on holiday?

“Look at this mountain”, I groaned.

My desk was piled up with files that I had left before the court vacation. I was really hoping for a gentle re-entry today. You know, maybe draft a simple notice, have a relaxed client meeting. 

But fate, it seems, had other plans for me.

Now, I don’t like to pick favourites, but if I had to choose a client least likely to bring peace to me, it would be him. He knows how to nitpick. 

I had drafted certain notices for him a month ago, so I had a faint idea of what brought him to the office.

I was hoping not to be called, but a few minutes later, my clerk appeared and said, “Sir is calling you to his chamber.”  

I went in and my senior, without wasting time, said, “We need to file a suit in two days.”

After the client left, my senior smiled. “This is yours now.” He says, “draft the suit, get the client’s approval, and file it. I am counting on you.”

Well, you might think that I was super panicky or frustrated. No, this is not that story, however. Drafting a suit is a hassle, yes, but I knew how to do it in half a day, AI. 

Not just any AI,  but AI that I had spent months training, customizing, and fine tuning specifically for legal work. It knew my writing style, understood the nuances of Indian legal language, and had been fed every template and format had used. It is like having a super efficient junior associate who never gets tired, never complains and most importantly never asks for salary increments.

Within three hours, I had a complete, well structured civil suit that would have taken me at least two full days to draft from scratch. 

But here is the thing, I am not going to just tell you that AI saved my day and leave you hanging. I am going to show you exactly how I did it. 

Ready to learn. So, let us begin. 

But first let us set some context.. 

What are money recovery suits?

In simple words, a suit for recovery is a legal action instituted by a creditor against a debtor to recover money that is lawfully due to them. 

A person can file suit for recovery of money when there is a breach of contract, non-payment for goods and services, outstanding invoices, etc. 

What are the types of money recovery suits?

Let us understand the types of money recovery suits that are filed in court.

• Summary suit 

It is an expedited civil suit filed under Order XXXVII of the Code of Civil Procedure, 1908. It is designed for quick recovery of money in cases involving written contracts, hundis, promissory notes, bills of exchange, etc. 

The defendant does not have an automatic right to file a written statement in this type of suit. They need to file a leave to defend to get that right. Thus, a shortened version of a full trial based on already available documents. 

• Ordinary suit

It is a standard civil suit filed to resolve disputes, including the recovery of money, property, or other civil matters. It is governed by the general provisions of the Code of Civil Procedure, 1908.

In an ordinary suit, the defendant has a broad scope to raise a defence without prior permission of the court. 

It is a lengthy procedure and often takes years due to detailed hearings and evidence. 

An ordinary suit and summary suit are both legal mechanisms used to recover money, but they differ in procedure, purpose, and application.

What are the essential elements of a money recovery suit? 

Now, let us focus on a money recovery suit specifically. But before we learn drafting, let us understand what should be the elements of suit. 

• Name and the court where the suit is being filed
• Name, address, and description of the Plaintiff
• Name, addres,s and description of the Defendant
• Particulars of the cause of action and when it arose
• Whether the suit is filed within the period of limitation
• Facts establishing the jurisdiction of the court
• Total amount of subject matter of the suit
• Court fees paid
• Prayer clause
• Verification and signing by the Plaintiff

This is in accordance with Order VII, Rule 1 of the Code of Civil Procedure, 1908, which outlines the particulars that should be included in a civil suit. You need to remember that a plaint (the document filed to institute a suit) contains only the aforementioned details. 

You will not incorporate any legal arguments in it. A simple narration of the events leading up to the cause of action should be stated, followed by the mandatory particulars as per Code of Civil Procedure, 1908 

You also need to remember that any documentary evidence you want to introduce in court must be attached to the plaint as a list of documents and mentioned in the body of the plaint. 

Let us now see how to use AI to do this for us. 

How to use AI to draft the money recovery suit?

I am going to use ChatGPT and demonstrate the steps to draft a money recovery suit in under 20 minutes. You can also prefer using any other AI tool. Claude.ai does a brilliant job with litigation drafts. 

I will show the reasoning/explanation of why I’m drafting a particular part in green and I will also tell you what you should not do in red. 

STEP 1: Ask AI to build a legal checklist before you draft

I gave the following prompt to GPT:

“I am preparing to draft a money recovery suit in the Bombay City Civil Court. Before I start feeding you facts, help me build a checklist of every essential component that must go into the plaint, including factual details, documents, and legal requirements, based on the Civil Procedure Code,1908. Break it down like a junior lawyer who is about to draft for the first time.”

This is the result generated by AI: Checklist 

Explanation: Instead of rushing into factual storytelling, I asked ChatGPT to do what a seasoned lawyer would do first, which is to break down the elements of a plaint. This is especially helpful if you are working with AI for the first time.

By doing this:

• You are training yourself to think like a drafter before acting like one.
• You also now have a reusable checklist that you can attach to your drafting SOP.
• This method also improves accuracy in later prompts. 

Why? Because you now have a structure to anchor your facts to, which leads to better and complete drafts.

What not to do:

• Do not say “Draft a money recovery suit for me” as your very first prompt. You will get a vague or generic plaint.
• Do not treat ChatGPT like a stenographer. Treat it like your first-year associate, give it instructions and legal frameworks to follow.

STEP 2: Feed your case facts under the right heads 

 Based on the checklist provided to me, I created a detailed set ot facts that I needed to provide to GPT. I gave the following prompt:

“I’ve compiled the complete facts of the case in a structured format as per your earlier checklist. Please confirm if all essential elements needed for drafting the money recovery suit have been covered, and let me know if you need any further clarification before proceeding to the draft.”

Court: Bombay City Civil Court

Plaintiff: Mr. Rajesh Kumar, age 40, sole proprietor of M/s. SteelTech Supplies, Mumbai — engaged in the business of supplying Mild Steel plates.

Defendant: Mr. Vikram Mehta, age 63, sole proprietor of M/s. Mehta Engineering Works, Mumbai — a manufacturer sourcing raw materials like M.S. plates.

Jurisdiction: Cause of action arose in Mumbai; both parties are based in Mumbai; total claim of ₹24,23,665 falls within the pecuniary jurisdiction of the City Civil Court.

Facts/Cause of Action: Between 15 June 2015 and 8 January 2016, Defendant placed written purchase orders with the Plaintiff. Plaintiff supplied goods worth ₹87,76,016 against valid invoices and delivery challans (Exhibit A). Defendant made part-payments totaling ₹69,92,351 between August 2015 and January 2023 (Exhibit B), leaving an unpaid balance of ₹17,83,665. Plaintiff issued a legal notice dated 25 February 2025 demanding payment (Exhibit C), but the Defendant failed to respond.

Defendant’s Objections:The Defendant later raised objections about quality and quantity of goods. However, he had accepted the supplies without protest, availed VAT credit, and continued making payments even after raising those objections.

Limitation: Suit is filed in June 2025, within 3 years of the last part-payment (5 January 2023).

Court Fee: Court fee paid as per the Maharashtra Court Fees Act, 1959.

Relief Claimed Recovery of unpaid principal of ₹17,83,665, Interest of ₹6,40,000 calculated at 18% per annum and Future interest and litigation costs

Exhibits: Exhibit A: Invoices and purchase orders, Exhibit B: Ledger of part-payments, Exhibit C: Legal notice dated 25 February 2025 and Exhibit D: Delivery proofs and VAT credit documents

Verification: To be signed and verified by the Plaintiff.”

This is what AI wrote back after this prompt.

“Thank you for the detailed factual breakdown. All essential components appear to be covered for preparing a well-drafted money recovery plaint. Would you like me to proceed with drafting the plaint based on this structure, or do you want to share a specific format that I should follow?”

Explanation: This step is all about giving the AI the raw material exactly the way a court expects to read it. By providing GPT with structured data, you are improving its accuracy. 

What not to do:

• Do not dump unstructured facts into one text. GPT will either miss something or mess up the flow.
•  Do not assume the AI knows your court’s jurisdiction limits or limitation rules; spell them out.

STEP 3: Generate the first draft

I gave the following prompt 

“Draft a complete plaint for a money recovery suit before the Bombay City Civil Court based on the facts I have provided. Structure it with continuous paragraph numbering and proper legal language. Ensure all necessary elements like parties, jurisdiction, cause of action, limitation, prayer clause, and verification are included. Do not insert section headings.”

This is the first draft that GPT generated for me: First draft 

Explanation:

Let me break down the prompt strategy here:

• You explicitly asked GPT to draft a complete plaint, not just a template or outline. This is important. If you just say “draft a plaint,” it might respond with a semi-filled skeleton.
• You set formatting boundaries: continuous numbered paragraphs, no headings. GPT tends to generate results in headers unless you specifically stop it.
• You recalled all legal ingredients of a plaint: cause of action, jurisdiction, limitation, relief, etc. This ensures GPT ticks every box required under Order VII Rule 1 of the CPC.
• You told the court: Bombay City Civil Court. That lets it phrase jurisdiction and prayer clauses more accurately.

In short, you trained your AI like a good junior.

What not to do:

•  Do not ask “Draft a plaint for money recovery” without more context.
• Do not forget to set the tone and format. GPT needs to be reminded that you are filing in court, not writing a LinkedIn post.

STEP 4: Use AI as a senior advocate to review the draft before finalising

I gave the following prompt:

“I am going to share the full draft of a money recovery plaint meant for the Bombay City Civil Court. Please act as a senior lawyer and review it thoroughly and identify:

1. Any missing legal ingredients required under the CPC?
2. Weaknesses in structure or factual narration.
3. Gaps in persuasive strategy.
4. Stylistic improvements to make it more courtroom-ready.

Do not rewrite the plaint. Just give bullet-pointed feedback like a senior reviewing a junior’s work before filing.”

This is what GPT generated: Suggestions on first draft 

Explanation: By this stage, you already have a fully generated plaint. But good lawyers do not file the first drafts. They review and refine it. Instead of directly asking for edits, you are telling AI:“Step into a mentor’s shoes and critique like a senior.”

What not to do:

• Do not rush to the final draft just because AI gave you something complete.
• Avoid vague prompts like “edit this” or “improve this.” That will often trigger a full rewrite, which defeats the review mindset.

Step 5: Finalising the money recovery suit

I gave the following prompt to GPT:

“Based on your previous review, please now revise the draft plaint for money recovery.
Incorporate all the following:

1. Clearly state territorial and pecuniary jurisdiction.
2. Add an averment on limitation (last payment date and legal basis).
3. Clarify the relief sought, including principal amount, pre-suit interest, pendente lite, and future interest, along with court fees.
4. Maintain a persuasive and legally sound tone.
5. Do not use short sentences or bullet points.
6. Use appropriate references like ‘Exhibit A’, ‘Exhibit B’, where documents are mentioned.
7. Add verification after the draft.”

This is what AI has generated: final draft 

Explanation: Now that the AI has reviewed the draft like a senior lawyer, this step puts those observations into action and gives you a clean draft. This step ensures:

• No missing ingredients (jurisdiction, limitation, interest breakdown).
• No cosmetic leftovers (headings, short sentences, generic language).

What not to do: Now that you have a ready draft, you must not blindly accept it. It is now your turn to check the draft and use your legal acumen

Here’s the final draft with manual edits in red

IN THE BOMBAY CITY CIVIL COURT AT BOMBAY
SUIT NO. ______ OF 2025

Mr. Rajesh Kumar,

aged 40 years,  of Bombay, Indian Inhabitant,

proprietor of M/s. SteelTech Supplies,

having its office at Gala No. 12, Industrial Estate,

VERSUS

Mr. Vikram Mehta,

aged 63 years, of Bombay, Indian Inhabitant,

proprietor of M/s. Mehta Engineering Works,

having its registered office at Plot No. 44,

PLAINT UNDER ORDER VII RULE 1 OF THE CODE OF CIVIL PROCEDURE, 1908 FOR RECOVERY OF MONEY

MOST RESPECTFULLY SHOWETH:

1. The Plaintiff is a sole proprietor carrying on business under the name and style of M/s.SteelTech Supplies. The Plaintiff is engaged in the trade of Mild Steel plates and related materials. 
2. The Defendant is also a sole proprietor, carrying on business under the name and style of operating M/s. Mehta Engineering Works, which manufactures engineering components and regularly sources raw materials from the Plaintiff.
3. From June 2015 to January 2016, the Defendant placed written purchase orders for M.S. plates, which were duly supplied by the Plaintiff along with corresponding tax invoices and delivery challans. Copies of the invoices and delivery challans are annexed hereto and collectively marked as Exhibit “A” Colly.
4. The total value of goods supplied was ₹87,76,016/-. The Defendant made part payments totaling ₹69,92,351/- between 26 August 2015 and 5 January 2023. The payment ledger and receipts are annexed hereto and marked as Exhibit “B”.
5. However, A a sum of ₹17,83,665/- remains outstanding and unpaid by the Defendant on the date of filing the suit. 
6. The Defendant initially accepted all goods without protest, availed of Input VAT credit, and continued payments for several months. Only belatedly did the Defendant raise vague objections regarding the quality and quantity of supplies, which are denied by the Plaintiff. 
7. The Defendant’s conduct clearly amounts to an acknowledgment of liability. The Plaintiff craves leave to refer to and/or rely upon the necessary documents claiming input VAT credit, as and when produced.
8. The Plaintiff issued a legal notice dated 12th February 2025 calling upon the Defendant to pay the outstanding dues. Despite receipt of the notice, the Defendant has failed and neglected to make any payment. A copy of the legal notice dated 12th February 2025 and postal acknowledgment is annexed as Exhibit “C”.
9. The cause of action arose in Mumbai, where the goods were delivered, payments were made and notices were sent. Therefore, this Hon’ble Court has territorial jurisdiction to try and entertain the present suit under Section 20(c) of the Code of Civil Procedure, 1908. The suit claim amount is ₹24,23,665/- (₹17,83,665 principal + ₹6,40,000 towards interest), which falls within the pecuniary jurisdiction of this Hon’ble Court.
10. The last payment made by the Defendant was on 5th January 2023. The present suit is filed on 11th June  2025 and is well within the prescribed limitation of 3 years under law. Article 15 of the Limitation Act, 1963. Therefore, the suit is not barred by the law of limitation.
11. The Plaintiff is entitled to recovery of ₹17,83,665/- towards outstanding principal, along with ₹6,40,000/- towards interest @ 12% per annum for the period between 6 January 2023 to 31 May 2025. The Plaintiff also seeks pendente lite and future interest @ 12% per annum on the principal amount until realization, and costs of the present proceedings. A copy of the statement of claim is hereto annexed as “Exhibit D”.
12. The Plaintiff values the suit at ₹24,23,665/- for the purpose of jurisdiction and payment of court fees Court fee of ₹____/- and has been paid the Court fees accordingly.
13. The Plaintiff will rely upon the documents, a list whereof is hereto annexed.
14. 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.

  PRAYER

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

a) Pass a decree in favour of the Plaintiff and against the Defendant for ₹24,23,665/- with further interest on ₹17,83,665/- at 12% per annum from the date of suit till realization as per the statement of claim annexed at Ex D hereto.

b) Award Order costs of the suit; and

c) Grant such other relief as this Hon’ble Court deems fit in the interests of justice.

VERIFICATION

I, Rajesh Kumar, the Plaintiff herein, do hereby verify that the contents of paragraphs 1 to 9 are true to my personal knowledge and belief. Verified at Mumbai on this 11th day of June 2025.

Sd/-
Rajesh Kumar

(Plaintiff)

Conclusion

If you are just starting out and know nothing about legal language or have a ton of drafting to do, using AI tools to formulate your drafts is a smart idea. Lawyers all over the world are already incorporating AI into their everyday practice. You just need to not use it blindly and exercise caution by proofreading everything that it drafts. However, with the right training, it can do 75% of your drafting work. 

Frequently asked questions

1. What determines the territorial jurisdiction for filing a money recovery suit? 

Territorial jurisdiction refers to the geographical area within which a particular court has the authority to hear and decide a case. Territorial jurisdiction for filing a money recovery suit is established where:-

• Either the defendant resides or carries on business
• Or the cause of action wholly or partly arises
• Or the contract was made or was to be performed, for instance, in our case, Mumbai jurisdiction was established as goods were delivered, payments were made, and notices were sent there.

2. What happens if I file in the wrong jurisdiction?

If you file in a court lacking territorial jurisdiction, the defendant can raise this objection. The court may:

• Return the plaint for presentation to the proper court
• Transfer the case to the court with proper jurisdiction
• Dismiss the suit (in some cases)

3. What is the difference between territorial jurisdiction and pecuniary jurisdiction?

Territorial jurisdiction determines which geographical court can hear the case, while pecuniary jurisdiction determines whether a court has the monetary authority to hear cases above or below certain value limits. Both must be satisfied for a valid suit.