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DUPLICATE PLAINT

IN THE COURT OF LD. CIVIL JUDGE, SENIOR DIVISION,

SONEPAT

1. Kapil
2. Rajesh
3. Rupender sons of Sh. Krishan S/o Ramdia, all residents of
village Guhna, Tehsil and District Sonepat.

--Plaintiffs
Versus
1. Devilal (son)
2. Bansilal (son)
3. Sonu (son)
4. Babli daughter of Sh. Rajbir S/o Ramdia, all Residents
of village Guhna, Tehsil and District Sonepat.

--Defendants

SUIT FOR PERMANENT INJUNCTION U/S 37

And 38 OF THE SPECIFIC RELIEF ACT, 1963

R/Sir/Madam,
The plaintiffs most humbly and respectfully submit as
under:-
1. That parties to the suit are co-related with each other as
the defendants are the cousin brothers of the plaintiffs.
The parties to the suit are Hindu, constitute a joint
Hindu Family and as such they are governed by Hindu
Law in their personal matters of transfer of properties.
2. That the plaintiffs used to be owner in possession to the
extent of 2/7 equal share out of total land measuring 79
Kanal 13 Marle land comprised in Khewat No.443//415,
Khatoni No.550, in Rect. And Killa No.91/16(7-12),
17(8-8), 24(8-0), 25(7-12); 92//19/3(9-13), 20/1(7-16);
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94//9(2-4), 11/1(7-11), 12/1(7-5), 13(1-10), 18/1(5-16),

19/2(7-12)’ 98//10/1(1-14), total measuring 79 Kanal
13 Marla, situated in the revenue estate of village
Guhna, Tehsil and District Sonepat. The copies of
Jamabadi for the year 2021-22 is annexed herewith for
the kind perusal of this hon'ble Court.
3. That as per family settlement, the plaintiffs are in
possession of Rect. And Killa No. 91/16(7-12), 17(8-8),
24(8-0), 25(7-12), since the time of their father. The said
lands had been given to the share of the present
plaintiffs in family settlement effected since the life of
their forefather, since then, the father and thereafter, the
plaintiffs have been in possession of the same and
enjoying the said land as exclusive properties. Abundant
evidence establishes that the present plaintiffs are in
actual possession and enjoyment of the said
properties/land since the said family partition.
4. That defendants filed a suit for partition before the Ld.
Tehsildar/CRO, Sonepat, which is pending and fixed for
________. Now during the pendency of the suit for
partition, the defendants with malafide intention want
take possession illegally and forcibly over the killa
numbers on which the plaintiffs are in possession, for
which the defendants have no right do so, but the
defendants are adamant and have also threatened to
create third party interest over the property in question
in order to defeat the rights of the plaintiffs and in case
the defendants succeeds in her evil design, in that event
the plaintiffs will suffer an irreparable loss and legal
injury, which cannot be compensated in any manner.
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6. That the plaintiffs have several times requested the

defendants to admit them as owner in possession of the
land mentioned in para no.2 of the plaint in terms of the
said family settlement and not to take possession
forcibly and illegally, but the defendants are adamant
and has now finally refused to admit the genuine request
of the plaintiffs one week before. Hence this suit.
7. That the cause of action to file the present suit firstly
arose to the plaintiffs filed the suit when the defendants
tried to take forcibly possession on the Killa number
mentioned above and lastly one week before, the day of
last refusal of the defendants to admit the genuine claim
of the plaintiffs.
8. That plaintiffs have filed a suit for partition involving the
same land/property except this no any suit or
proceeding are pending before any court of law or before
any court throughout country.
9. That the suit land/property as described in para No.1 of
the plaint is situated in the Revenue Estate of village
Guhna, Tehsil and District Sonepat, which is well within
the territorial jurisdiction of this Hon'ble court, hence
this Hon'ble court has got jurisdiction to try and
entertain the present suit.
10. That the value of the suit for the purpose of court fee
and jurisdiction is assessed Rs.200/- each relief on
which a prescribed court fee of Rs.25/- has been affixed
on the plaint.
It is, therefore, humbly prayed that in view of the
above mentioned facts and circumstances the Hon'ble
court may kindly be pleased to pass a decree for
permanent injunction in favour of the plaintiffs and
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against the defendants by restraining the defendants

from interfering in the peaceful possession of the
plaintiffs in the killa numbers fully described in para
no.2 of the plaint forcibly and illegally till the final
decision of the partition suit filed by the defendants, in
the interest of justice.
Any other relief, which this Hon'ble court may
deem fit and proper be also awarded in favour of the
plaintiff.

Verification Plaintiffs
Verified that the contents of 1. Kapil
para no.1 to 7 the above 2. Rajesh
plaint are true and correct the 3. Rupender sons of Sh.
best of my knowledge and Krishan S/o Ramdia, all
para no. 8and 10 are correct residents of village
to my belief and last para is Guhna, Tehsil and
prayer clause. District Sonepat.
Verified at Sonepat
On

Through Counsel