Plaints for a Suit for Possession

Updated at:March 2010
 
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In the Court of...................

Suit No.......20...

............................. Plaintiff

Versus

...........................Defendant

The above named plaintiff begs to submit as under:

  1. That previously........... of which total area as............. and....... was in...... of two persons...................... and...................... out of which Shri..................was the......... land and remaining......... and........ was under the....... of............. and the entire............... was under the............... of......................

  2. That after the death of............ land was inherited by his three sons Shri..............., and Shri..................who are the predecessor-in-interest of the plaintiff.

  3. That this................ land which is disputed in the plaint and shall be called the property in suit in further paras of the plaint.

  4. That this........ land which later on came in.......... was also entered in..........and because the entire area was abadi area therefore it was entered with the name of....................... but in......... the name of the predecessor-in-interest over the property in suit was entered with the name of.......................... and others.

  5. That after some time the all three sons of Shri........................ viz. Sri................, Sri...................and Sri....................had executed power of attorney is favour of one person Shri................................... son of Shri............................... Resident of.............................who on..........exacted three separate registered sale-deeds in favour of the plaintiff and since then till the date of cause of action the plaintiff remained in possession of the property in suit.

  6. That after getting executed the sale deed regarding the property in suit the plaintiff has started to raise boundary wall and some.

  7. That the defendants who have no right, title or interest of any kind over the property in suit but who are very risk persons having a Giroh of unsocial elements persons of the locality have compelled the plaintiff to sell the entire property in suit to them but the plaintiff has refused with the remark that as the plaintiff is a Housing Society and not a business concerned therefore the question of selling the property in suit to the defendants does not arise, and hearing this version of the plaintiff the defendant started to ill felling towards the plaintiff.

  8. That on...............the defendants...

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