DUPLICATE PLAINT

BEFORE THE COURT OF Ld. PRINCIPAL DISTRICT JUDGE, JAMMU

Pritam Kumar,
S/o Lt. Sh. Lakshmi Chand,
R/o Krishna Nagar, Jammu.
…………….Plaintiff
Vs.

Sh. Anil Choudhary,

S/o sh. Sardar Singh,
R/o Patoli Brahmana,
Tehsil and District, Jammu.

Sh. Subash Chander Sharma,

S/o Sh. Vaidya Ram Sharma,
R/o Patoli Brahmana,
Tehsil and District, Jammu.

Sh. Rajinder Singh

S/o Sh. Ram Singh
R/o Machhlian, Nagbani, Tehsil and District Jammu
…….....Defendants

IN THE MATTER OF:-

Suit for permanent prohibitory injunction restraining the defendants, their authorised
agents, representatives, assigns, administrators etc. from un-authorised encroaching
and illegal interference in the peaceful possession with respect to the land measuring 1
Kanal 12 Marlas comprised under Khasra No. 314, Khewat No.-8, Khata No. 67
situated at Machhlian, Tehsil and District Jammu belonging to the plaintiff.

May it please your Honour,

The plaintiff respectfully submits as under:-

1. That the plaintiff is the registered owner of the land measuring 1 Kanal 12
Marlas comprised under Khasra No. 314, Khewat No.-8, and Khata No. 67
situated at Machhlian, Tehsil and District Jammu.

2. That the said land was purchased by the plaintiff from the defendant no. 1, as
per the sale deed dated 12th day of December 2008 which was duly registered
in the court of the Sub-Registrar, Jammu on 13 th day of December 2008, where
the plaintiff presented himself and the defendant no. 1 was represented through
his attorney holder i.e. the defendant no. 2, before the Sub-Registrar, Jammu
with respect to the registration of the said land in the name of the plaintiff.
(Copy of the registered sale deed dated 13 th December 2008, along with the
Fard along and the site plan is enclosed herewith as ANNEXURE – P1.

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3. That the plaintiff accordingly after the registration of the land got the land
mutated on his name in the concerned department. Copy of the Mutation /
‘Intkaal’ is enclosed herewith as ANNEXURE – P2.

4. That the Plaintiff after the registration and mutation of the said land raised a
boundary wall and also installed a metal gate on the said land measuring 1
Kanal 12 Marlas.

5. That few days back on 30th of April 2011, with the intention to raise
construction of a room on the said land, the plaintiff accumulated some
building material like Cement, Bricks, Bolder Stones, Sand on the said land
which is still there on the land.

6. That the intentions of the defendants seemed to be suddenly changed when the
defendants first tried to stop the unloading of the building material on the said
land, failing in which, all the limits were crossed and all the social, moral and
legal barriers were broken on 8th May 2011 when the defendants along with
some head strong men and with some goons of the area where the land
situates, entered into the said land by crossing the boundary wall and soon
after that the defendants along with their goons broke some part of the
boundary wall and also made the metal gate fallen on the ground in a very
illegal manner by appointing labourers also.

7. That after the incident the plaintiff approached the defendant no. 1 and 2 who,
inspite of being generous to the plaintiff, threatened him for his life and also
put the plaintiff under the influence of the local goons of the area where the
land situates.

8. That after receiving threats from the defendants, the plaintiff approached the
area Police station where the plaintiff was told by the police officials of the
concerned Police Station that they have nothing to do in this matter and due to
their inclined behaviour towards the defendants and reluctant behaviour
towards the plaintiff, the plaintiff was left with no other option than to
approach the Hon’ble Court.

9. That the cause of action has been accrued to the plaintiff to prefer the present
suit on 8th Day of May 2011, when the defendants along with their goons
entered into the peaceful possession of the Plaintiff and broke the boundary
wall and the metal gate, hence the present suit.

10. That the value for the purpose of court fee and jurisdiction is fixed at Rs.400/-.

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11. That the suit property situates and the parties to this suit reside within the
territorial jurisdiction of this Hon'ble Court, hence this court has the territorial
and pecuniary jurisdiction to try this suit.

It is, therefore, most respectfully prayed that a decree of permanent prohibitory

injunction may be passed thereby restraining the defendant, its agents, representatives,
assignees, administrators etc. or any such person representing the defendants etc. from
un-authorised encroaching and illegal interference in the peaceful possession with
respect to the land measuring 1 Kanal 12 Marlas comprised under Khasra No. 314,
Khewat No.-8, Khata No. 67 situated at Machhlian, Tehsil and District Jammu
belonging to the plaintiff.

Any other relief which this Hon’ble court may deem fit be also passed in favour of the
plaintiff.

PLAINTIFF
Through counsel

(J.P. Nanda and Associates)

Advocates

VERIFICATION :-

Verified at Jammu on this 11th day of May, 2011 that the

averments made from para No.1 to 8 are true and correct rest
of the paras are believed to be correct as per records and legal
information received from my counsel.

PLAINTIFF

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