Plaint by Aradhya

IN THE COURT OF HON’BLE CIVIL JUDGE
SENIOR DEVISION, PUNE
CIVIL SUIT NO: 1348/ 2023
BETWEEN
SMT ANJULI
Aged about 60 years, occupation- Retired,
Residing at Flat no. 6, Old Mayur colony,
Paud Road, Hinjewadi, 4th phase
Pune- 411038.........................................................................................PLAINTIFF
AND
SHRI SHIVAM
Aged about 55 years, occupation- Business
Old 113, Nehru society, Anand Vihar
Paud Road, Kothrud
Pune- 41103.......................................................................................DEFENDANT
SUIT FOR DECLARATION AND RECOVERY OF OWNERSHIP TITLE VALUED AT

RS. 15,000/- FILED UNDER THE PROVISIONS OF SECTION 127 OF
MAHARASHTRA LAND REVENUE CODE 1966.
MEMORANDUM OF PLAINT UNDER ORDER 7 RULE 1
READ WITH SECTION 26 OF THE CIVIL PROCEDURE
CODE, 1908
The Smt. Anjuli (herein after referred to as plaintiff) most respectfully submits
as follows:
1. The address of the plaintiff of notices & summon’s etc issued from this
Hon’ble court is as stated in the above cause title and they may be
notified through their advocate Gururaj society, Paud road, Kothrud,
Pune.
2. The address of the defendant for the purpose of notices & summons etc.
issued from the Hon’ble court is may refer to the cause title.
BRIEF FACTS
3. It is submitted that the plaintiff has purchased a plot of land located at
PMC 452/A, Hinjewadi 2nd phase, Pune- Bengaluru express highway,
Pune admeasuring about 90* 80 total measuring 4000 sq. ft which is
situated within the city limits of Municipal corporation of the City of
Pune, and within the jurisdiction of the Sub- Registrar, Taluka Haveli,
District Pune.
Together with all easements, and appurtenances attendant
thereto. The above- described property is hereinafter for the sake of
brevity referred to as the “SUIT PROPERTY”.
4. It is submitted that the scheduled property was purchased by the

plaintiff from Mr. Ravi Kumar for a consideration of Rupees 20 Lakhs 44
thousand on 15th March, 2023. The sale deed bearing its document no.
134 date 15th March, 2023 was registered in the office of Sub Registrar,
Shivajinagar. The copy of the sale deed is enclosed herein with the plaint
as document no. 1
5. It is submitted that the plaintiff is the owner and in possession of the

schedule property from 15th March onwards.
6. It is submitted that all the relevant documents with regard to the said
property were verified thoroughly by Advocates appointed by the
plaintiff before the purchase of the property.
7. It is submitted that the defendant claims to be the owner of the

schedule property and claims to have all the necessary documents to
prove the ownership over the schedule property but has failed to furnish
the same.
8. The defendant also claims that the schedule property is involved in a

partition suit which is between him & his family members.
9. It is also submitted that the defendant has also been harassing the
plaintiff repeatedly to vacate the premises. Furthermore, the defendant
claiming to be the owner with a mala fide intention and has no valid
documents to support his claim. Thus the defendant do not have no
right, title, claim.
10.It is humbly submitted that the plaintiff is the absolute owner and is
currently in possession of the schedule property vide the plaintiff has all
the necessary documents which includes encumbrance certificate,
electricity bill & water bill in the name of the plaintiff which are enclosed
herein with the plaint as document no. 2, no. 3, no. 6 respectively.
11.The cause of action arisen on 15th March, 2023 where the schedule
property was purchased, the schedule property is within the limits of
Pune and within the jurisdiction of this Hon’ble court.
12.There is no pendency of any legal proceedings & litigations either past or

present concerning any part of the subject matter of this suit in any part
of the subject matter of this suit in any court within the knowledge of
the plaintiff.
13.The plaintiff state that this is a suit for recovery of ownership title and as
such appropriate court for stamp is paid here with on valuation of Rs.
15,000/- as per the Maharashtra court fee and suit valuation act and the
requisite court fee has been paid thereon.
The copy of the valuation receipt is enclosed herein with the plaint as
Document No. 7.
PRAYER
THEREFORE, the plaintiff states that this Hon’ble court may be pleased with:-
1. That the present suit be decreed with costs.
2. Declare the plaintiff is the sole, absolute and the rightful owner of the
schedule property.
3. That the Hon’ble court kindly declare that the defendant is causing a
nuisance to the plaintiffs and their family members and the occupants of
the surrounding premises.
4. Pass any other relief which his Hon’ble court may deems fit and proper
in the facts and circumstances of the case be also awarded in favour of
the plaintiff.
PUNE
DATE:
PLAINTIFF
ADVOCATE FOR THE PLAINTIFFS
VERIFICATION
Smt. Anjuli, aged about 60 years, occupation: Retired, the plaintiff do hereby
solemnly affirm that, which is state on oath that the contents of the above
paragraphs are true and correct to the best of the knowledge, information and
believe and nothing has been concealed therein and hence I have signed this
plaint today at Pune.
Place- Pune
Date- 7th May, 2023
PLAINTIFF

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IN THE COURT OF HON’BLE CIVIL JUDGE

SENIOR DEVISION, PUNE

CIVIL SUIT NO: 1348/ 2023

SUIT FOR DECLARATION AND RECOVERY OF OWNERSHIP TITLE VALUED AT

4. It is submitted that the scheduled property was purchased by the

5. It is submitted that the plaintiff is the owner and in possession of the

7. It is submitted that the defendant claims to be the owner of the

8. The defendant also claims that the schedule property is involved in a

12.There is no pendency of any legal proceedings & litigations either past or

ADVOCATE FOR THE PLAINTIFFS

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