Plaint- Immovable property
| Updated at | March 2010 |
IN THE HIGH COURT OF JUDICATURE AT ..........
Civil Suit No............ /200..
Shri (Full name and Address.........) ....Plaintiff
Versus
Shri (Full name and Address.......)....Defendants
A SUIT FOR DECLARATION
The plaintiff abovenamed submits this plaint, praying to state as follows:
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Description of Suit Property: All that piece and parcel of land situate within the Registration Division & District ....., Sub- Division & Taluka ......., within the local limits of the....... Zilla Parishad, Taluka Panchayat ......, revenue village ........, bearing Gat Numbers, admeasuring areas an bounded by as detailed below:
Sr.No. Survey Number
Area
Bounded by -
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The Pedigree: That the one, Shri ...., was the owner of various properties including the suit land, and the plaintiff and the defendant No. 1 are the sons of the said Shri ....., while the plaintiff and the defendant No. 1 are step-brothers of the plaintiff and full sisters of the defendant ..... Likewise, the said Shri..... had a son by name Shri ...., and the said Shri..... was the real brother of this plaintiff. He died in about .....,leaving behind his only daughter, the defendant No.....
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That the parties hereto had been forming a joint family for some time, and while in the joint family, the marriages of the defendants were performed as well as in Survey No. ...., a well was constructed so as to provide irrigated facilities to the other holdings of the plaintiff, and for raising the necessary funds firthe marriages and the construction of the well, there being no other source, the family was required to transfer the lands bearing Survey No. .....
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That it would be clear that the properties those described hereinabove had been sold for legal necessity of the family, and, therefore, on behalf of the family.
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That it would be apparent that since there was a coparcenery consisting of the plaintiffs father, plaintiff, plaintiffs deceased brother by a coparcenery and the plaintiffs father died in coparcenery prior to the commencement of the Hindu Succession Act 1956, and, as such, by survivorship, the total property of the coparcenery devolved upon the plaintiff and the defendant..... only, and in the property of the coparcenery, the defendant Nos..... to.....would be entitled to claim no interest at all.
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That the defendant No..... has been claiming that the lands sold by the family had been sold out of the plaintiffs share, and the lands those remaining with the party have been the...
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