District ;: South 24 Parga In the Court of the Learned 1st Addl Civil Judge (Junior Division) At Alipore | Ejectment Suit no- 231 of 2018 | 1) Sri Shyamlai Pandey S/o Lt Ganga Prasad Pandey 2) Sri Biswana-h Pandey ' §/o Shyamlal Pandey 3) Sri Parbati Pandey W/o Biswanath Pandey All residing at ..P No 10\21\4 Naskarhat , Medhyam Para P.O —Tiljala P.S -Kasba Kolkata-70003° District South “4 Parganas .-Plaintiffs Vs" Sri Madan Thakur S/o Lt Kanta Thakur L.P No 10\21\4 Naskarhat . Madham Para P.O -Tijala P.S Kasba Kolkata- 700039 District Sout 24 Parganas Defendant) POSSESSION AND SUIT FOR EVICTION AND RECOVER) FOR MESNE PROFIT VALUED AT RS9000/- The plaintiff abovenamed states :- 3 1. The entire suit premises was purchased by the Plaintiff No 2 and and Smt Gita Devi Pandey since deceased the mother of Plaintiff No 2. After the death of Smt Gita Devi Pandey her husband the Plaintiff No 1 being the karta was accepted as owner. 2. The defendant is a tenant in respect of 1 room with common user of privy details of the suit property are mentioned in the schedule hereunder and hereinafter referred to as suit property ata monthly rental of Rs.220/- payable according to the English calendar under the plaintiffs. 3. The defendant is a habitual defaulter and has defaulted in payment of rent for more three months within a period of twelve months. 4, The plaintiff reasonably requires the suit property for his own use and occupation and for the occupation of his family members. The plaintiff is presently in possession of 5 bedrooms, 1 dining space, 1 kitchen 2 bathrooms with privy.5. The family members of the plaintiffs consist Plaintiff No 2 and 3 and the farther of Plaintiff No 2 being Plaintiff No 1 and four sons of Plaintiff No 2 and Plaintiff No 3 being Sri Shiv Sankar Pandey, Sri Ravi Shankar Pandey, Sri Hari Shankar Pandey, and Sri Uma Shankar Pandey. 6. That the plaintiff No 1 requires one bedroom, plaintiff No 2 and 3 require one flat consisting of minimum two bedrooms, one dining room, one living cum drawing room, kitchen and separate bath with privy similarly each four son requires one flat each. All the four sons of Plaintiff No 2 and 3 are established in life but could not settle a family life due to paucity of accommodation. The Plaintiff No 2 and Plaintiff No 3 have one child who conducts business in the name and style of M/s Payel Telecom and Electronics from the suit property which is x expanding and requires space/rooms for further growth and development. 7. That the plaintiffs are also owners of premises No 32 Panchantala Road P.S Lake P.O Sarat Bose Road Kolkata- 700029. That a, 4 p presently the premises,tenanted and moreover this accommodation is not at all suitable accommodation to the plaintiffs or their family members.8. That the plaintifisthrough thay La Advocate served the notice dated 02.06.2018 upon the defendant but the defendant failed to comply and hence the suit 9. That the cause of action of the Suit arose on and from 01.08.2018 and on all subsequent days at premises L.P 10\21\4 Naskarhat M. A ladhya Para, P.O, Tiljala P.S- Kasba Kolkata 700039 District South 24 Paragans which is within the jurisdiction of the this Learned Court. 10.For the purpose of Court Fees and jurisdiction the suit for eviction and recovery of khas possession is valued at Rs 3000/- being Rs 2640/- as annual rent and for mesne profit tentatively valued at Rs 360/- per diam and ad- valorem court fees are paid herewith. ‘The plaintiff therefore prays 1. for passing a decree for recovery of peaceful vacant khas possession by evicting the defendant ; 2. for passing a decree for mesne profit ; 3. for passing a decree for all costs incidental charges and expenses to the suit ;4. for such further relief or reliefs the plaintiff may otherwise be entitled to in law and in equity SCHEDULE (Description of the Property) ALL THAT south facing one room with common privy at premises No . L.P 10\21\4 Naskarhat Madhya Para, PS. Tiljala P.O- Kasba Kolkata 700039, District South 24 Paragans. Butted and bounded in the following manner, By North - Boundary Wall at distance of 3 Ft By South — Common Passage of 3.5 Ft By East ~ Portion under the plaintiff By West- Boundary Wall at distance of 3 FtList of Documents - Deed of Conveyance Eviction Notice with postal receipt and A/D card. VERERSISRAClACD LOIN, I, do hereby declare that the statements made in Paragraph nos. to _are all true to my knowledge and rests are my submission before this Learned Court and I sign this verification on this the day of 2018.AFFIDAVIT 1, sei Shyamlal Pandey, Son of Lt Ganga Prasad Pandey, aged about 78 years, bY faith - Hindu, by occupation - Retired, residing at Premises No L.P 10/21/4 Naskarhat Road, Madhyam Para P.O -Tiljala P.S -Kasba Kolkata-700039 District South 24Paragans, do hereby solemnly affirm and state as follows:- 1 That I am the plaintiff No 1 in this instant suit and am well conversant with the facts and circumstances of this suit. This is true to my knowledge. 2. That the statements made in paragraph nos. 1 to 12 are all true to my knowledge and rests are my submission before this Learned Court. Prepared in my office:- DEPONENT Advocate. Identified by me