In the court of Civil Judge Sr.

Division Jalandhar

Smt. Prem Kanta Mohindru Widow of Dr K.C Mohindru R/o Kothi No : 10, Seth Hukam
Chand Colony, Jalandhar.

v/s

1. Sh. Rajiv Mohindru S/o Dr K.C. Mohindru

2. Sh. Sanjeev Mohindru S/o Dr K.C. Mohindru
3. Smt. Geeta Khanna D/o Dr K.C. Mohindru
4. Smt. Anu Murti D/o K.C Mohindru,

All residents of Kothi No : 10, Seth Hukam Chand Colony, Jalandhar

Suit for declaration to the effect that the plaintiff is the owner in possessionon the basis
of WILL dt 08.05.2009 executed by her husband of the kothi having No : 10, Seth Hukam
Chand Colony, Jalandhar bounded as under

East : Kothi No 9.

West : Kothi No : 11

North : Kothi No : 13

South : Road

Situated at Seth Hukam Chand Colony Jalandhar

And

The property situated in village Nijjran, Tehsil Jalandhar as per Jamabandi 2004-05
Khevat No : 215/208, Khasra No: 20//9/2 (1 Kanal 11 marlas), 10(5 Kanal 16 Marlas), 11
(7 Kanal 7marlas) Kitta 3 meauring 14 Kanal 14 marlas out of this land total land 4 kanal
7.5 marlas vide sale deed dt 27.07.2010 out of which 3/5 share of the property that is 4
Kanal 7.5 marlas as per WILL dt 08.05.2009

Sir,

It is submitted as under :-

1. That the plaintiff is the widow of Dr. K.C Mohindru since deceased copy of the
death certificate is attached.
 2. That the husband of the plaintiff purchased the property in his name as per sale
deed measuring 1 kanal 1 marlas 153 sq feet having kothi No : 10, Seth Hukam
Chand Colony, Jalandhar vide sale deed dt 18.02.1970 having No 2096, Photocopy
of sale deed attached.

3. That the husband of plaintiff Dr K.C Mohindru purchased another property in

village Nijjran vide Sale deed dt 27.07.2010 having No : 2852. Photocopy of the
sale deed attached. Photocopy of the jamabandies are attached.

4. That Dr K.C. Mohindru husband of the plaintiff executed legal & valid WILL duly
registered in the office of Sub Registrar Jalandhar, vide Dt 08.05.2009. Photocopy
of the same is attached. The WILL was executed with his free will and without
coercions.

5. That in the WILL it was clearly mentioned that the future property if any
purchased by the husband of the plaintiff will be owned and possessed by the
plaintiff i.e his wife.

6. That the defendants were also told by the plaintiff and even by her husband prior
to his death.

7. That the defendants have totally refused to admit the WILL in question and had
created clouds on the WILL.

8. That the plaintiff requested to defendants to admit the WILL Dt 08.05.2009.

9. The defendants totally refused and started claiming their share in the property and
clearly stated that the WILL is waste paper and is not binding upon the defendants.

10. That the acts of the defendants is illegal, ultra virus and against the law.

11. The defendants are the sons & daughters of the Dr. K.C. Mohindru.

12. That the cause action arose to the plaintiff on different dates and finally day for
yesterday when the defendants refused to admit the claim of the plaintiff.

13. That the property is situated at Jalandhar hence the civil court of jalandhar has
jurisdiction to entertain and decide the suit.

14. That the value of the suit is Rs 500/- is fixed court fee of Rs . 50/- is affixed on the
plaint.

15. That no such suit is pending nor filed regarding the property in dispute.

It is therefore prayed that suit of plaintiff regarding the properties I.e. Kothi having No :
10, Seth Hukam Chand Colony, Jalandhar and the another property situated in village
Nijjran, Tehsil Jalandhar as per Jamabandi 2004-05 Khevat No : 215/208, Khasra No:
20//9/2 (1 Kanal 11 marlas), 10(5 Kanal 16 Marlas), 11 (7 Kanal 7marlas) Kitta 3 meauring
14 Kanal 14 marlas out of this land total land 4 kanal 7.5 marlas vide sale deed dt
27.07.2010 out of which 3/5 share of the property that is 4 Kanal 7.5 marlas be passed in
favour of the plaintiff against the defendants.

Plaintiff

VERIFICATION: - Verified that the content of paragraph No. 01 to 12 of this plaint is base

on the personal knowledge and belief of the plaintiff while the content of paragraph No.

12 to 15 plaint is base on the legal advice given to me and I believe to this advice to be

true and correct.

Verified on this day of October, 2013 at Jalandhar.

Plaintiff

Through

Neeraj Thakur Advocate

 Affidavit

I Prem Kanta Mohindru Widow of Dr K.C Mohindru R/o Kothi No : 10, Seth Hukam Chand
Colony, Jalandhar do hereby solemnly affirm as under:-

1. That the deponent has filed the abovenoted Suit for Declaration before this
hon,ble court. That the contents of this plaint from para no 1 to 12 may kindly be
read as part and parcel of this affidavit while the content of paragraph No. 12 to 15
plaint is base on the legal advice given to me and I believe to this advice to be true
and correct in compliance of the relevant provisions of CPC for filing a suit.

Deponent

Verification :- Verified that the contents of my above affidavit are true to best of my
knowledge and belief and nothing is concealed there in.

Verified at Dt. Jalandhar.

Deponent