Draw up a Plaint in a Suit for Demolition of Construction made by the Defendant on the Plaintiff’s vacant Piece of Land

In the court of Munsif, Allahabad Suit No. of 1951.

Prem Kumar, son of Suraj Prakash, caste…………… Zamindar and resident………………. District

Allahabad………. Plaintiff.

v.

Rajendra Kumar, son of Sri Madan Lai, caste………. resident of………… District

Allahabad………… Defendant.

The above named plaintiff begs to state as follows:

1. That the plaintiff is the owner and zamindar of Mahal…….. Village………… Pargana…………….. Tehsil……….. District, Allahabad.

2. That the plaintiff is the sole zamindar of the Abadi in the said viriage.

3. That the plot No…………. Given at the foot of the plaint lies in the aforesaid Abadi.

4. That the said plot has been lying vacant for a very long time and the plaintiff used it occasionally.

5. That the defendant has built a mud house comprising two rooms without any permission or consent of the plaintiff.

6. That the plaintiff came to know of the said construction two days back through his Mukhatar-i-am and Karinda who, on his inspection tour, saw it and informed the plaintiff.

7. That the defendant has absolutely no title to the said plot of land and his act is wholly unauthorised and illegal.

8. That the defendant has refused to vacate the said plot and to demolish the mud house when asked by the plaintiff’s karinda.

9. That the cause of action arose on the 10th

February, 1951, when the defendant raised the aforesaid construction and the court has jurisdiction to try this suit.

10. That the valuation of the suit for the purposes of jurisdiction and payment of court-fee is Rs. 240/-, market value of the land in suit, and for the prayer of injunction valuation is made at Rs. 20, l/12th of the market value, and a court fee of the value of Rs……….. payable on the said sum of money is being paid.

The plaintiff prays—

(a) That possession of the plot in suit is given to the plaintiff through a decree of the court with directions to the defendant to pull down and remove the mud house and to restore the land to its former condition within a period specified by the court through the court Amin at the expense of the defendant.

(b) A perpetual Injunction by virtue of which the defendant be restrained to interfere with the plaintiffs user of the plot in suit in future.

(c) Costs of the suit are awarded to the, plaintiff.

(Sd.) Prem Kumar.

Boundaries of Plot No.

East

West

North

South

I, Prem Kumar, declare that the contents of paras. 1 to 10 of the plaint are true to my personal knowledge, and information.

Verified at Allahabad on the 12th February, 1951.

(Sd.) Prem Kumar

Advocate.

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