In the Court of Civil Judge Class - I at Delhi

Suit No. 01 / 2020

M/D. Abulais s/o Namuddin Mia

SUKUL PAR TOLA, BELARIYA P.O.

SUKULPAKAR P.S, DISTRICT: SINGHAULI,

EAST CHAMPARAN………………………………….

V/S

1) LATE DHUPAN SINGH S/O LAKSHMI SINGH,

THROUGH MS. LALJHARO DEVI,
WIDOW OF LATE DHUPAN SINGH.

2) BHULAN SINGH S/O DHUPAN SINGH,

VILLAGE SUKUL PAKAR TOLA, BELBARIYA .P.O,
SUKUL PAKAR P.S, DISTRICT: SUGAULI,
EAST CHAMPARAN.

3) INDRAJEET SINGH S/O DHANUKHI SINGH.

4) SRI NARAYAN SINGH S/O DHANUKHI SINGH,

VILLAGE SUKUL PAKAR TOLA, BELBARIYA .P.O,
SUKUL PAKAR P.S, DISTRICT: SUGAULI,
EAST CHAMPARAN.

5) INDRADEV SINGH S/O DHANUKHI SINGH. Page 2 of 7

6) KANCHAN SHAH- EXPUNGE

7) VINOD SHAH(MINOR),
THROUGH ADV. ANIRUDH DUBEY BY THE LEAVE OF THE COURT,
DIST:SUGAULI, EAST CHAMPARAN.
 8) HARINARAYAN SINGH S/O RAMDHANI SINGH.

9) MD. IMAM S/O GULAM MOHAMMAD,

VILLAGE SUKUL PAKAR TOLA, BELBARIYA .P.O,
SUKUL PAKAR P.S, DISTRICT: SUGAULI,

EAST CHAMPARAN.......................................................................DEFENDANT(S).

The plaintiff respectfully states as follows : -

Inducement:
(1) Plaintiff is a farmer working in singhauli. and so on
(2) Respondent is a farmer having an office at

Singhauli Material Facts of the case:

1. That Dhupan Singh (defendant no.1), entered into an agreement with the plaintiff, orally
to sell the suit land measuring 9(nine) kathas 14( fourteen) dhurs, khata no. 111 (fully
detailed in schedule ‘I’ of the plaint), on 20-11-1991, in the presence of the defendants
no.s 2 to 6, 8 and 9 for a consideration of rupees nine thousand only and received
rupees eight thousand out of consideration money.
2. It is further stated that on 27-11-1991 Dhupan Singh in the presence of the defendants
3 to 6, 8 and 9 got the sale deed scribed by the scribe of his choice. The scribe read over
the contents of the sale deed to Dhupan Singh who after fully understanding the
contents thoroughly, puthis L.T.I(left thumb impression) on each page of the sale deed
and got his L.T.Is identified or may attested by his son Bholan Singh(defendant no.2).
Bhulan Singh also went through the contents of the sale deed before he indentified the
L.T.I.s. of his father on the sale deed. Bhulan singh also endorsed his signature as a
witness of execution of the sale deed
3. It is further stated that there was strike of employees in the registration office and
scribing and execution took much time as a result, the working hour was over. So,
Dhupan Singh handed over the said sale deed, to the plaintiff and assured to register the
sale deed once the strike was over. In the sale deed receipt of Rs. 8000/- by the Dhupan
Singh was also recorded and the balance Rs. 1000/- was also mentioned to be paid in
exchange of the receipt of registration.
4. It is further stated that the plaintiff time and again went to Dhupan Singh with Rs 1000/-
, the balance consideration money in the presence of the witness and requested to get
the sale deed registered but every time he evaded.
5. It is further stated that defendant no. 3,4 and 5 are uterine brothers, who are living
separately. Also defendant no. 8 is the cousin of defendant(s ) 3 to 5. Defendant no 3 to
5 and defendant no. 8 are the karta of their respective family. Defendant no. 6 and 9 are
the family members of the defendant no. 3 to 5 and defendant no. 8. Also defendant no.
7 is the minor son of the defendant no. 6.
6. It is further stated that, on 26-01-1992, the plaintiff learnt that the defendants 3 to 9 in
collusion with Dhupan Singh and his son Bhulan Singh have got three sale deed,
executed in their favour from Dhupan Singh with regard to the said suit land, on 30-12-
1991 and 25- 01- 1992 respectively.
7. It is further stated that the plaintiff there on 28-01-1992 suit a notice against Dhupan
Singh requesting him to get the sale deed dated 27-11-1991, registered, but the
defendants managed to get a report endorsed thereon that no man of the name of
Dhupan Singh resides in the village.
8. It is further stated that the defendants keeping full knowledge of the sale deed dated
27-11-1991, got the sale deeds executed and registered during strike period and have
also got three mahdanama dated 16-05-1991 executed.
9. That the present suit for the plaintiff became a necessity as Dhupan Singh on 28-02-92
retired finally to register the sale deed.
10. It is further stated that the plaintiff has always been writing and ready to pay the
balance consideration money and will also be ever ready to pay the same and to get the
 sale deed registered, but due to the ignorance and unwillingness of the Defendant(s) in
this present matter, this suit is a necessity.

Valuation:
9 The suit is valued for the purpose of jurisdiction and court-fee at Rs. 9000/-.

Jurisdiction:
(10) The plot is located in Singhauli, which is within this court's territorial
jurisdiction.

(11) The value of the contract is 9000/- which is within this court's pecuniary
jurisdiction.

Relief Claimed:
(12) The plaintiff, there fore prays that

the court be pleased to order the respondent to perform his part of the contract by
accepting the remaining payment and conveying the said plot to the plaintiff.
the plaintiff be permitted to deposit the balance of consideration in this Hon'ble Court.
the respondent be ordered to pay compensation for mental harrasment, loss of wages,
and cost of this litigation.

Place: …………………. (Signature of

the plaintiff)
Date: …………………..

Advocate

Verification

I, , do hereby solomnly verify that the contents from paras 1 to 4 are correct
and true to the best of my knowledge and contents from para 5 to 12 are based on
legal advice, which I believe to be correct. Affirmed at Delhi this 4th Day of January
2020.
(Signature)
Plaintiff