BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

OS NO /2023

PLAINTIFFS : ASWATHY AND 1 ANOTHER

DEFENDANT : G PRASANNA KUMARI

PLAINT MOST RESPECTFULLY FILED U/S.26 AND ORDER IV & VI OF

CODE OF CIVIL PROCEDURE 1908 FOR ON BEHALF OF THE PLAINTIFF

Plaintiffs : 1.Aswathy aged 27,

D/o Sujatha,
Mavila House,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally, Village, Kollam.
Representing through the 2nd plaintiff

2. Suresh Babu aged 55,

S/o Madhavan
Mavila House,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally, Village, Kollam
(All the notices and processes to the plaintiffs from this court may be sent to the above-
mentioned addresses or that of their counsel Advocate Parippalli Anil Kumar Lekshman
& Arun R Advocates, Kollam-13 , respectively).

Defendant : G Prasanna Kumari aged 66

W/o Babu,
Parayil Veettil,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally Village, Kollam
(All the notices and processes to the defendant from this court may be sent to the above-
mentioned address respectively)

1. That the 1st plaintiff is the absolute owners of landed property comprised in Re-
Survey 164/7-11 of Parippally Village of a total extend of 06 Ares 42 Square
Meters. The 2nd plaintiff is the maternal uncle of the 1 st plaintiff, now studying in
the USA, prevented her from preferring the suit herself before this court. The 1 st
plaintiff got absolute right over the said property through Settlement I/1588/2023
dated 19-06-2023 of Chathannur SRO executed by the 2nd plaintiff. The 2nd
plaintiff is handling the property of the 1st plaintiff. A copy of the Sale Deed is
produced herewith. The said property is detailed as plaint A scheduled property.
There were coconut trees, banana saplings, teak trees, etc keep growing in the A
scheduled property. There were boundary stones on all the sides.

2. The above numbered suit is filed for a permanent prohibitory injunction.

3. The defendant is residing on the Western side of Plaint A scheduled property. The
property of the defendant is described as plaint B scheduled property. She
purchased the B scheduled property from the 2nd defendant in the year 2021.

4. That on 25-10-2023, the defendant had tress passed into the north-western side of
A scheduled property and tried to encroach the said portion in order develop the
pathway using by the defendant to on the north-western corner of the A scheduled
property adjacent to the Panchayath road and the defendant and the nearby
Anganwadi were using the pathway for the conveyance. The defendant again on
01-11-2023 along with her henchmen tress passed into the A scheduled property
and caused damages to the vegetation planted therein for the convenient usage.
Since the time when the defendant purchased the property had been trying to cause
nuisance against the peaceful enjoyment of the A scheduled property and also
committing waste and trying to alter the material condition on the north western
side of the A scheduled property. Hence the plaintiffs are approaching this
Hon’ble court for an order of permanent prohibitory injunction restraining the
defendant and her men from committing any material alteration on the north-
western side of the plaint A scheduled property and also restraining the defendant
and her men from committing any waste, nuisance or tress pass into the A
scheduled property.

5. that the occupation and use of the A scheduled property as part of the conveyance
of the defendant is an unauthorized act it would cause irreparable loss and injury
to the plaintiff hence the plaintiff are filing an interim injunction application along
with the suit restraining the defendant from her misadventure till the final disposal
of the suit. . Hence an order of temporary injunction against the defendant is
highly necessary. The defendant is pretty well aware the absence of the 1 st
plaintiff.

6. That the cause of action had arisen on 19-06-2023 the date on which the 1st
plaintiff got absolute right over the plaint A scheduled property and on 25-10-2023
the date on which defendant encroached the north-western portion of the A
scheduled property and on 01-11-2023 the date on which the defendant again tried
to encroach and committed trespass into the A scheduled property and tried to
committed nuisance and damages to vegetation in the plaint A scheduled property
and on all th subsequent days and the A scheduled property which is situated in
the Parippally Village is well within the territorial jurisdiction of this Hon’ble
court.

7. For Court fee and Suit valuation, this suit is valued Rupees 1000/- for an order of
permanent prohibitory injunction a fee of Rs.50/- is remitted herewith u/s.27 (c) of
the Kerala Court fees and Suit Valuation Act and a fee of Rs.100/-is remitted
herewith as legal benefit fund fee and a total fee of 150/- is affixed herewith.

Reliefs

i) To pass a decree of prohibitory injunction restraining the defendant and her

men from trespassing into the plaint A Schedule property or committing
 any nuisance, mischief’s into the plaint schedule property and the
vegetation therein:

ii) To pass a temporary prohibitory injunction against the defendant and her
henchmen from tress-passing into the plaint A Schedule property or
committing any nuisance, mischief’s into the plaint schedule property and
the vegetation therein till the disposal of this suit;

iii) To pass an order of cost of the proceedings from the defendant to the
plaintiffs;

AND

iv) Allow such other reliefs the court may think deem fit and necessary for the
proper adjudication of this case.

All facts above stated are true and correct to the best of my
knowledge information and beliefs.

Dated this the day of November 2023

2nd Plaintiffs: Suresh Babu

I Suresh Babu aged 55, S/o Madhavan, Mavila House, Karumbalurkonothu

Cherry, Puthenkulam Parippally, Village, Kollam the 2nd plaintiffs above named
do hereby verify that the contents of this plaint from paragraph 1 to 5 are true and
correct to my personal knowledge and paragraphs 6 and 7 are believed to be true
and correct according to the legal advice received to me

Signed and verified on 4th November, 2023 at Kollam.

2nd Plaintiff Suresh Babu

Advocates:Mayyand R Arun

&

Anil Kumar Lekshman

List of documents:

1. Copy of Settement Deed dated No I/1588/2023 dated 15-06-2023

2. Copy of Tax receipt issued from Parippally Village dated 17-10-2023.

A SCHEDULE PROPERTY
District - Kollam
Sub-District - Chathannur
Village - Parippally
Thandapper No - 20206
 Re- Survey Block. No. 164/7-11 an extend of 06 Ares 42 Sqr Meters of land and
the plants and trees situated in Parippally Village

East : Property of Chandra Bose

North : Property of Panchayath Way
West : property of defendant and Agnganwadi
South : Property of Basheer

B SCHEDULED PROPERTY

Property of the defendant situated on the western side of the A scheduled property

All the facts above described are true and correct to our best of knowledge
information and belief.

2nd Plaintiff: Suresh Babu

 BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

OS NO /2023

PETITIONERS/PLAINTIFFS : ASWATHY AND 1 ANOTHER

RESPONDENTS/DEFENDANT : G PRASANNA

AFFIDAVIT

I Suresh Babu aged 55, S/o Madhavan, Mavila House, Karumbalurkonothu

Cherry, Puthenkulam Parippally, Village, Kollam the 2nd Applicant/Plaintiffs
above named do hereby do hereby affirms and states as follows:-

1. That the 1st plaintiff is the absolute owners of landed property comprised in Re-
Survey 164/7-11 of Parippally Village of a total extend of 06 Ares 42 Square
Meters. I am the maternal uncle of the 1st plaintiff, now studying in the USA,
prevented her from preferring the suit herself before this court. The 1st plaintiff
got absolute right over the said property through Settlement I/1588/2023 dated 19-
06-2023 of Chathannur SRO executed by me.. I was entrusted to handling the
property of the 1st plaintiff. A copy of the Sale Deed is annexed in the plaint. The
said property is detailed as plaint A scheduled property. There were coconut trees,
banana saplings, teak trees, etc keep growing in the A scheduled property. There
were boundary stones on all the sides.

2. The above numbered suit is filed for a permanent prohibitory injunction.

3. The defendant is residing on the Western side of Plaint A scheduled property. The
property of the defendant is described as plaint B scheduled property. She
purchased the B scheduled property from me in the year 2021.

4. That on 25-10-2023, the defendant had tress passed into the north-western side of
A scheduled property and tried to encroach the said portion in order develop the
pathway using by the defendant to on the north-western corner of the A scheduled
property adjacent to the Panchayath road and the defendant and the nearby
Anganwadi were using the pathway for the conveyance. The defendant again on
01-11-2023 along with her henchmen tress passed into the A scheduled property
and caused damages to the vegetation planted therein for the convenient usage.
Since the time when the defendant purchased the property had been trying to cause
nuisance against the peaceful enjoyment of the A scheduled property and also
committing waste and trying to alter the material condition on the north western
side of the A scheduled property. Hence the plaintiffs are approaching this
Hon’ble court for an order of permanent prohibitory injunction restraining the
defendant and her men from committing any material alteration on the north-
western side of the plaint A scheduled property and also restraining the defendant
and her men from committing any waste, nuisance or tress pass and encroachment
into the A scheduled property.
5. that the occupation and use of the A scheduled property as part of the conveyance
of the defendant is an unauthorized act it would cause irreparable loss and injury
to the plaintiff hence the plaintiff are filing an interim injunction application along
with the suit restraining the defendant from her misadventure till the final disposal
of the suit. . Hence an order of temporary injunction against the defendant is
highly necessary. The defendant is pretty well aware the absence of the 1st
plaintiff.

6. That the cause of action had arisen on 19-06-2023 the date on which the 1st
plaintiff got absolute right over the plaint A scheduled property and on 25-10-2023
the date on which defendant encroached the north-western portion of the A
scheduled property and on 01-11-2023 the date on which the defendant again tried
to encroach and committed trespass into the A scheduled property and tried to
committed nuisance and damages to vegetation in the plaint A scheduled property
and on all th subsequent days and the A scheduled property which is situated in
the Parippally Village is well within the territorial jurisdiction of this Hon’ble
court.

7. That the nuisance, mischief and trespass of the defendants and their men over the
plaint scheduled property are continuing. For the preservation, protection and
proper enjoyment of the scheduled property an order from this Hon’ble court is
highly necessary.

8. Hence an order from this Hon’ble Court is highly necessary to restrain the
defendants and their henchmen from trespassing into the plaint schedule property
and also causing any harm to the peaceful life and enjoyment of our property by an
order of permanent prohibitory injunction. We are also filed an interim application
for temporary injunction, restraining the defendants and their henchmen from
committing any nuisance trespass mischiefs to the plaint scheduled property and
the building therein till the disposal of the suit.

9. That the balance of convenience is infavor of us and the same time is against the
defendants and every chance to succeed our case against the defendants. Prima
facie the case is against the defendants. If an order of temporary injunction is not
passed it will cause irreparable loss and injury to me and the other applicants. For
the same I filed a separate Application and it may kindly be allowed.

All the facts above stated are true and correct to my best of knowledge
information and belief.

Deponent: Suresh Babu

Solemnly affirmed and signed this before me by the deponent who is

personally known to us at our office at Kollam on this the …… day of November
2023

Advocates Mayyanad R Arun

&

Anilkumar Lekshman MA, LLB

 BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

IA NO. /2023

IN

OS NO /2023

Applicants/ Plaintiffs : 1.Aswathy aged 27,

D/o Sujatha,
Mavila House,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally, Village, Kollam.
Representing through the 2nd plaintiff
2. Suresh Babu aged 55,
S/o Madhavan
Mavila House,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally, Village, Kollam

Respondent/Defendant :
G Prasanna aged 66
W/o Babu,
Parayil Veettil,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally Village, Kollam
APPLICATION FOR TEMPERARY INJUNCTION MOST
RESPECTFULLY FILED U/O XXXIX RULE 1 R/W SECTION 151 OF
CODE OF CIVIL PROCEDURE, 1908 BY ADVOCATE ARUN.R FOR
AND ON BEHALF OF THE APPLICANTS.

For the reasons stated in the accompanying affidavit this Hon’ble court may
be pleased to pass a temporary prohibitory injunction against the defendant and his
henchmen from tress-passing into the plaint A Schedule property or committing
any nuisance, mischief’s into the plaint schedule property and the vegetation
therein till the disposal of this suit;, to secure the ends of justice.

Dated this the day of November 2023

Advocates Mayyanad R Arun

&

Advocate Anilkumar Lekshman MA, LLB

Roll No K/4025/2022

A SCHEDULE PROPERTY

District - Kollam
Sub-District - Chathannur
Village - Parippally
Thandapper No - 20206

Re- Survey Block. No. 164/7-11 an extend of 06 Ares 42 Sqr Meters of land and
the plants and trees situated in Parippally Village

East : Property of Chandra Bose

North : Property of Panchayath Way
West : property of defendant and Agnganwadi
South : Property of Basheer

B SCHEDULED PROPERTY

Property of the defendant situated on the western side of the A scheduled property

All the facts above described are true and correct to our best of knowledge
information and belief.

Applicant/Plaintiff: Suresh Babu

Advocate: Advocate Anilkumar Lekshman MA, LLB

Roll No K/4025/2022

BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

 OS NO /2023

Petitioners/plaintiffs : Aswathy and 1 another

Respondents/defendant : G Prasanna

AFFIDAVIT FILED U/S 26(2) of CODE OF CIVIL PROCEDURE, 1908

I Suresh Babu aged 55, S/o Madhavan, Mavila House, Karumbalurkonothu

Cherry, Puthenkulam Parippally, Village, Kollam the 2nd Applicant/Plaintiffs
above named do hereby do hereby affirms and states as follows:-

1. That the 1st plaintiff is the absolute owners of landed property comprised in Re-
Survey 164/7-11 of Parippally Village of a total extend of 06 Ares 42 Square
Meters. I am the maternal uncle of the 1st plaintiff, now studying in the USA,
prevented her from preferring the suit herself before this court. The 1st plaintiff
got absolute right over the said property through Settlement I/1588/2023 dated
19-06-2023 of Chathannur SRO executed by me.. I was entrusted ti handling the
property of the 1st plaintiff. A copy of the Sale Deed is annexed in the plaint.
The said property is detailed as plaint A scheduled property. There were coconut
trees, banana saplings, teak trees, etc keep growing in the A scheduled property.
There were boundary stones on all the sides.

2. The above numbered suit is filed for a permanent prohibitory injunction.

3. The defendant is residing on the Western side of Plaint A scheduled property.

The property of the defendant is described as plaint B scheduled property. She
purchased the B scheduled property from me in the year 2021.

4. That on 25-10-2023, the defendant had tress passed into the north-western side
of A scheduled property and tried to encroach the said portion in order develop
the pathway using by the defendant to on the north-western corner of the A
scheduled property adjacent to the Panchayath road and the defendant and the
nearby Anganwadi were using the pathway for the conveyance. The defendant
again on 01-11-2023 along with her henchmen tress passed into the A scheduled
property and caused damages to the vegetation planted therein for the convenient
usage.. Since the time when the defendant purchased the property had been
trying to cause nuisance against the peaceful enjoyment of the A scheduled
property and also committing waste and trying to alter the material condition on
the north western side of the A scheduled property. Hence the plaintiffs are
approaching this Hon’ble court for an order of permanent prohibitory injunction
restraining the defendant and her men from committing any material alteration
on the north-western side of the plaint A scheduled property and also restraining
the defendant and her men from committing any waste, nuisance or tress pass
into the A scheduled property.

5. That the occupation and use of the A scheduled property as part of the
conveyance of the defendant is an unauthorized act it would cause irreparable
loss and injury to the plaintiff hence the plaintiff are filing an interim injunction
application along with the suit restraining the defendant from her misadventure
 till the final disposal of the suit. . Hence an order of temporary injunction against
the defendant is highly necessary. The defendant is pretty well aware the absence
of the 1st plaintiff.

6. That the cause of action had arisen on 19-06-2023 the date on which the 1st
plaintiff got absolute right over the plaint A scheduled property and on 25-10-
2023 the date on which defendant encroached the north-western portion of the A
scheduled property and on 01-11-2023 the date on which the defendant again
tried to encroach and committed trespass into the A scheduled property and tried
to committed nuisance and damages to vegetation in the plaint A scheduled
property and on all th subsequent days and the A scheduled property which is
situated in the Parippally Village is well within the territorial jurisdiction of this
Hon’ble court.

7. That the nuisance, mischief and trespass of the defendants and their men over the
plaint scheduled property are continuing. For the preservation, protection and
proper enjoyment of the scheduled property an order from this Hon’ble court is
highly necessary.

8. Hence an order from this Hon’ble Court is highly necessary to restrain the
defendants and their henchmen from trespassing into the plaint schedule property
and also causing any harm to the peaceful life and enjoyment of our property by
an order of permanent prohibitory injunction. We are also filed an interim
application for temporary injunction, restraining the defendants and their
henchmen from committing any nuisance trespass mischiefs to the plaint
scheduled property and the building therein till the disposal of the suit.

All the facts above stated are true and correct to my best of knowledge
information and belief.

Deponent: Suresh Babu

Solemnly affirmed and signed this before me by the deponent who is

personally known to me at my office at Kollam on this the …… day of November
2023

Advocate Anilkumar Lekshman MA, LLB

Roll No K/4025/2022
 BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

OS NO /2023

Petitioners/plaintiffs : Aswathy and 1 another

Respondents/defendant : G Prasanna

AFFIDAVIT FILED UNDER ORDER VI RULE 15(4) OF CODE OF CIVIL

PROCEDURE, 1908.

I Suresh Babu aged 55, S/o Madhavan, Mavila House, Karumbalurkonothu

Cherry, Puthenkulam Parippally, Village, Kollam the 2nd Applicant/Plaintiffs
above named do hereby do hereby affirms and states as follows:-That I am the 1st
Applicant/1st plaintiff in the above named suit. The 2nd applicant/2ndplaintiffs is
my husband. I am swearing this affidavit myself and also for my husband.

1. That I am well conversant with the facts of the case.

2. This suit is filed for permanent prohibitory injunction against the defendants
from trespassing into or committing any nuisance, mischief’s to the plaint
scheduled property.

3. That the averments written in Para 1 to 9 are true and correct to my best to my
knowledge and belief.

All the facts stated above are true and correct to the best of my knowledge,
information and belief.

Dated this the day of November 2023.

Deponent: Suresh Babu

Solemnly affirmed and signed this before me by the deponent who is

personally known to me at my office at Kollam on this the …… day of November
2023

Advocate: Anil Kumar Lekshman

BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

 IA NO. /2023
IN
OS NO /2023

Applicants/ Plaintiffs : 1.Aswathy aged 27,

D/o Sujatha,
Mavila House,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally, Village, Kollam.
(Representing by the 2nd plaintiff)

2. Suresh Babu aged 55,

S/o Madhavan
Mavila House,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally, Village, Kollam

Respondent/Defendant : G Prasanna aged 66

W/o Babu,
Parayil Veettil,
Karumbalurkonothu Cherry,
Puthenkulam
Parippally Village, Kollam

APPLICATION FOR APPOINTING AN ADVOCATE COMMISSIONER FOR

LOCAL INSPECTION MOST RESPECTFULLY FILED U/O XXVI RULE 9 R/W
SECTION 151 OF CODE OF CIVIL PROCEDURE, 1908 BY ADVOCATE ANIL
KUMAR LEKSHMAN FOR AND ON BEHALF OF THE APPLICANTS.

For the reasons stated in the accompanying affidavit this Hon’ble court may be
pleased to pass an order for appointing an advocate commissioner for local inspection
and prepare a Report and Scene Plan of the plaint A schedule property to secure the
ends of justice.

Dated this the day of November 2023

Advocate: Mayyanad R Arun

&

Anil Kumar Lekshman

Things to be ascertained:-

1. Prepare a report regarding the nature, lie and the boundary separating other
properties with the plaint A scheduled property.

2. Take note on the present material condition on the north western side of the A
scheduled property.

3. Such other things requested by the petitioners during the site inspection of the
property.
 4. Prepare a rough sketch of the plaint scheduled property.

. Advocate: Anil Kumar Lekshman

BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

OS NO /2023
 Petitioners/plaintiffs : Aswathy and 1 another

Respondents/defendant : G Prasanna Kumari

I Suresh Babu aged 55, S/o Madhavan, Mavila House, Karumbalurkonothu

Cherry, Puthenkulam Parippally, Village, Kollam the 2nd Applicant/Plaintiffs
above named do hereby do hereby affirms and states as follows:-

1. That the 1st plaintiff is the absolute owners of landed property comprised in
Re-Survey 164/7-11 of Parippally Village of a total extend of 06 Ares 42
Square Meters. I am the maternal uncle of the 1st plaintiff, now studying in the
USA, prevented her from preferring the suit herself before this court. The 1st
plaintiff got absolute right over the said property through Settlement
I/1588/2023 dated 19-06-2023 of Chathannur SRO executed by me.. I was
entrusted ti handling the property of the 1st plaintiff. A copy of the Sale Deed
is annexed in the plaint. The said property is detailed as plaint A scheduled
property. There were coconut trees, banana saplings, teak trees, etc keep
growing in the A scheduled property. There were boundary stones on all the
sides.

2. The above numbered suit is filed for a permanent prohibitory injunction.

3. The defendant is residing on the Western side of Plaint A scheduled property.

The property of the defendant is described as plaint B scheduled property. She
purchased the B scheduled property from me in the year 2021.

4. That on 25-10-2023, the defendant had tress passed into the north-western side
of A scheduled property and tried to encroach the said portion in order develop
the pathway using by the defendant to on the north-western corner of the A
scheduled property adjacent to the Panchayath road and the defendant and the
nearby Anganwadi were using the pathway for the conveyance. The defendant
again on 01-11-2023 along with her henchmen tress passed into the A
scheduled property and caused damages to the vegetation planted therein for
the convenient usage. Since the time when the defendant purchased the
property had been trying to cause nuisance against the peaceful enjoyment of
the A scheduled property and also committing waste and trying to alter the
material condition on the north western side of the A scheduled property.
Hence the plaintiffs are approaching this Hon’ble court for an order of
permanent prohibitory injunction restraining the defendant and her men from
committing any material alteration on the north-western side of the plaint A
scheduled property and also restraining the defendant and her men from
committing any waste, nuisance or tress pass into the A scheduled property.

5. That the occupation and use of the A scheduled property as part of the
conveyance of the defendant is an unauthorized act it would cause irreparable
loss and injury to the plaintiff hence the plaintiff are filing an interim
injunction application along with the suit restraining the defendant from her
misadventure till the final disposal of the suit. . Hence an order of temporary
injunction against the defendant is highly necessary. The defendant is pretty
well aware the absence of the 1st plaintiff.
6. That the nuisance, mischief and trespass of the defendants and their men over
the plaint A scheduled property are continuing. For the preservation, protection
and proper enjoyment of the A scheduled property an order from this Hon’ble
court is highly necessary. I have filed a commission application for appointing
an advocate commissioner for ascertaining nuisance and tress pass committed
by the defendant. For the same I have filed a separate Application and it may
kindly be allowed. If the application is not allowed it will cause irreparable loss
and injury to us.

7. A report of the advocate commissioner is highly necessary for the proper

adjudication of the case.

All the facts stated above are true and correct to the best of my
knowledge, information and belief.

Deponent: Suresh Babu

Solemnly affirmed and signed this before me by the deponent who is

personally known to me at my office at Kollam on this the …… day of November
2023

Advocate: Anil Kumar Lekshman

BEFORE THE HON’BLE MUNSIFF’S

COURT PARAVUR
 OS NO /2023

Plaintiffs : Aswathy and 1 another

Defendant : G Prasanna Kumari

PLAINT MOST RESPECTFULLY FILED

U/S.26 AND ORDER IV & VI OF CODE OF
CIVIL PROCEDURE 1908 FOR ON BEHALF
OF THE PLAINTIFF

BEFORE THE HON’BLE MUNSIFF’S

COURT PARAVUR

IA /2023
 IN

OS NO /2023

Plaintiffs/Applicant : Aswathy and 1 another

Respondent/Defendant: G Prasanna Kumari

APPLICATION FOR TEMPERARY

INJUNCTION MOST RESPECTFULLY
FILED U/O XXXIX RULE 1 R/W SECTION
151 OF CODE OF CIVIL PROCEDURE, 1908
BY ADVOCATE ARUN.R FOR AND ON
BEHALF OF THE APPLICANTS.

BEFORE THE HON’BLE MUNSIFF’S

COURT PARAVUR
 OS NO /2023

Plaintiffs : Aswathy and 1 another

Defendant : G Prasanna Kumari

AFFIDAVIT FILED U/S 26(2) of CODE OF

CIVIL PROCEDURE, 1908

BEFORE THE HON’BLE MUNSIFF’S

COURT PARAVUR
 OS NO /2023

Plaintiffs: Aswathy and 1 another

Defendant: G Prasanna Kumari

AFFIDAVIT FILED UNDER ORDER

VI RULE 15(4) OF CODE OF CIVIL
PROCEDURE, 1908.

BEFORE THE HON’BLE MUNSIFF’S COURT

PARAVUR

IA /2023
 IN

OS NO /2023

Plaintiffs/Applicant : Aswathy and 1 another

Respondent/Defendant: G Prasanna Kumari

APPLICATION FOR APPOINTING AN

ADVOCATE COMMISSIONER FOR LOCAL
INSPECTION MOST RESPECTFULLY
FILED U/O XXVI Rule 9 R/W SECTION 151
OF CODE OF CIVIL PROCEDURE, 1908 BY
ADVOCATE ANIL KUMAR LEKSHMAN
FOR AND ON BEHALF OF THE
APPLICANTS.

BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

OS NO /2023
 Petitioners/plaintiffs : Aswathy and 1 another

Respondents/defendant : G Prasanna Kumari

LIST OF DOCUMENTS MOST RESPECTFULLY FILED BY ADVOCATE

ARUN.R

Serial No.

1. Plaint original ……………………………………

2. Plaint Duplicate…………………………………

3. Plaint copy……………………………………

4. Vakkalath………………………………………

5. Court fee memo…………………………………

6. Injunction Application & Affidavit…………….....

7. Injunction Application & Affidavit copy……...

8. Affidavit u/s 26 (2)…………………………………

9. Affidavit u/r 15(4)……………………………………

10. Application for accepting photo copy……………..

11. Documents………………………………………………

12. Copy of the documents…………………………………

13. Address Memo…………………………………………

14. Process memo……………………………………………

15. Summons forum with duplicate………………………..…

16. Notice forum with duplicate…………………………..…...

Dated this the day of November, 2023

BEFORE THE HON’BLE

MUNSIFF’S COURT PARAVUR
 OS NO /2023

Petitioners/plaintiffs : Aswathy and 1 Ors

Respondents/defendant:G Prasanna Kumari

LIST OF DOCUMENTS MOST

RESPECTFULLY FILED BY
ADVOCATE

BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

OS NO /2023

PLAINTIFFS : ASWATHY AND 1 ANOTHER

 DEFENDANT : G PRASANNA KUMARI

LIST OF DOCUMENTS MOST RESPECTFULLY FILED BY ADVOCATE ARUN.R

All the notices and process to the plaintiffs may be send to the below mentioned
address of the plaintiffs

1.ASWATHY AGED 27,

D/O SUJATHA,

MAVILA HOUSE,

KARUMBALURKONOTHU CHERRY,

PUTHENKULAM

PARIPPALLY, VILLAGE, KOLLAM.

REPRESENTING THROUGH THE 2ND PLAINTIFF

2. SURESH BABU AGED 55,

S/O MADHAVAN

MAVILA HOUSE,

KARUMBALURKONOTHU CHERRY,

PUTHENKULAM

PARIPPALLY, VILLAGE, KOLLAM

Dated this the day of November 2023

BEFORE THE HON’BLE MUNSIFF’S

COURT PARAVUR

OS NO /2023
 PLAINTIFFS: ASWATHY AND 1 ANR

DEFENDANT: G PRASANNA KUMARI

LIST OF DOCUMENTS MOST

RESPECTFULLY FILED BY
ADVOCATE ARUN.R

BEFORE THE HON’BLE MUNSIFF’S COURT PARAVUR

OS NO /2023
 PLAINTIFFS : ASWATHY AND 1 ANOTHER

DEFENDANT : G PRASANNA KUMARI

PROCESS MEMO MOST RESPECTFULLY FILED BY ADVOCATE

ARUN.R

Plaintiff hereby remitting process fee stamp of rupees 10/- as process fee for
sending notice to the defendant and also producing postage fee and cover along with
this

BEFORE THE HON’BLE MUNSIFF’S

COURT PARAVUR
 OS NO /2023

PLAINTIFFS: ASWATHY AND 1 ANR

DEFENDANT: G PRASANNA KUMARI

PROCESS MEMO MOST RESPECTFULLY

FILED BY ADVOCATE ARUN.R