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IN THE COURT OF THE DISTRICT MUNSIF OF HOSUR.

O.S. No: /2017

1. Mr. Ravindran
2. Mr. Rajendran
3. Mr. Sasindran
4. Mr. Manoharan
5. Mr. Surendran . . . . Plaintiffs

-/ Versus /-

The Tahsildar,
Taluk Office,
Hosur . . . . Defendant

PLAINT FILED ON BEHALF OF THE PLAINTIFF UNDER ORDER VII RULE 1

AND SECTION 26 OF THE CIVIL PROCEDURE CODE 1908: -

1.PLAINTIFFS: -
1) Mr. Ravindran S/o. Dhamodaran, aged about 62 years
2) Mr.Rajendran, S/o. Dhamodaran aged about 56 years
3) Mr.Sasindran, S/o. Dhamodaran aged about 54 years
4) Mr.Manoharan, S/o. Dhamodaran aged about 51 years
5) Mr. Surendran, S/o. Dhamodaran aged about 49 years

The address for service of the plaintiffs 1 to 5, as stated above and that
care of their Counsel Thiru. D. JAYAPRAKASH, B.COM., M.C.A., M.B.A., LL.B.,
Advocate, Hosur.

2. DEFENDANT:-

The Tahsildar, Taluk office, Hosur – 635 109.

3. The Plaintiffs 1 to 5, submit that they all are brothers of Late. D. Subramani
S/o. Dhamodaran, who was a physically challenged and he died on :
24-09-2017, at Door No. 13/35H, Shanthi Nagar, Hosur - 635 109, The copy
of death certificate filed herewith. That may be read as part and parcel of the
plaint.

4. The plaintiffs 1 to 5, submit that Late. D. Subramani, not married and he

physically challenged. Taken care by the plaintiffs 1 to 5, and they were
providing all the amenities to Late. D. Subramani, till his death. The plaintiffs
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1 to 5 submit that their father and mother also died long back. The copy of
death certificate of father and mother filed herewith. That may be read as
part and parcel of the plaint.

5. The said D. Subramani, was residing along with plaintiffs 1 to 5. It is

submitted that after the death of D. Subramani, the plaintiffs 1 to 5,
approached the Tahsildar of Hosur, for the issuance of legal heir certificate as
they are only legal heirs of the deceased D. Subramani, the said Tahsildar, of
Hosur, issued a letter No. 9285/2017A2 dated : 24-10-2017, stating that
the plaintiffs 1 to 5 are third grade legal heirs. Hence, the plaintiffs 1 to 5
should approached the court and get their succession certificate. The plaintiffs
1 to 5 are his only legal heirs as per Hindu Succession Act 30/1956. The copy
of legal heirs certificate of their father and mother filed herewith. That may
be read as part and parcel of the plaint.

6. The plaintiffs 1 to 5, submit that first they approached this defendant for
issuance of legal heir certificate. Whereas, the said defendant issued a letter
stating that the plaintiffs are third level of legal heirs. Hence, they have to
approach only to the appropriate court. The copy of letter issued by Tahsildar
is filed herewith. That may be read as part and parcel of the plaint.

The cause of action for this suit arose on when the said D. Subramani,
died on : 24-09-2017, leaving behind the plaintiffs 1 to 5, as his only legal
heirs and when the plaintiffs 1 to 5 approached the defendant for issuance of
legal heir certificate of D. Subramani, on 13-10-2017, the said defendant
issued a letter stating that the plaintiffs 1 to 5 are third level legal heirs. They
have to approached the appropriate court. This Honourable court has a
jurisdiction.

The plaintiff values the suit for the purpose of the Court Fee and
Jurisdiction at Rs. and paid a Court Fee of Rs. Under Section
25(d) of the Tamil Nadu Court Fees and Suit Valuation Act 1955 as per the
particulars of valuation given below: -
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9. The plaintiff 1 to 5, therefore prays that this Honourable Court may be

pleased to pass Judgment and Decree;
(a) Declaring that the plaintiffs 1 to 5 are the legal heirs of the
deceased D. Subramani.
(b) Directing the defendant to issue of legal heir certificate to the
plaintiffs 1 to 5; and
(c) Pass any other relief or relief’s as this Honourable Court may
deem fit and proper in the circumstances of the case.

1.

2.

3.

4.

Advocate for plaintiffs 1 to 5. 5.

We, the plaintiffs 1 to 5, do hereby declare that the facts stated above
are true to the best of our knowledge and belief we sign this verification on :
23-11-2001.

1.

2.

3.

4.

5.
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List of document filed on behalf of the plaintiffs Under Order VII Rule
14(i) of the CPC: -
1. Death certificate of Mr. K. Damodaran Nair father of Plaintiffs 1 to 5,
dated : 25-05-1988
2. Death certificate of Mrs. K. Ammaniyammal, mother of Plaintiffs 1 to 5,
dated : 17-06-2013
3. Death certificate of Mr. D. Subramani, brother of Plaintiffs 1 to 5
dated : 25-09-2017.

4. Legal heir certificate of Late. K. Damodaran.

5. Legal heir certificate of Late. K. Ammaniyammal.

6. 24-10-2017 dated of Letter issued by Tahsildar, Hosur.

Advocate for plaintiffs

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Verified address for service filed Under Order VI Rule 14-A of the CPC: -

PLAINTIFFS: -
1) Mr. Ravindran S/o. Dhamodaran, aged about 65 years
2) Mr.Rajendran, S/o. Dhamodaran aged about 56 years
3) Mr.Sasindran, S/o. Dhamodaran aged about 54 years
4) Mr.Manoharan, S/o. Dhamodaran aged about 51 years
5) Mr. Surendran, S/o. Dhamodaran aged about 49 years
All are residing at : at Door No. 13/35H, Shanthi Nagar, Hosur - 635 109

DEFENDANTS: -
The Tahsildar,
Taluk Office,
Hosur - 635 109

1.

2.

3.

4.

Advocate for plaintiffs. 5.

We, the plaintiffs 1 to 5, do hereby declare that the facts stated above
are true to the best of our knowledge and belief we sign this verification on
behalf of our self at Hosur on :
1.

2.

3.

4.

5.