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Clarification of main Judgment against District Judge Ballia ( In t he court of II Additional District Judge Ballia) Present.

Shri
Satish Kumar, H.J.S. Civil Appeal No.- 347 of 1982

In the High Court of Judicature at Allahabad Second appeal no. 108 of1985 under section 100 code of Civil Procedure Distt-Ballia
Apeal Dated 10-09-1984 submitted on 9th August 1984.

PART 1ST- TRUE FACTS OF APILANT

Point No. I

Issue No-2 Pedigree No- 1 for U P State only

Ram Karari Mishra

Sadhu Saran Mishra Satrughan Mishra

Narsingh Mishra Parasuram Mishra Mst Mukhiya Devi


Registered will executed on 16-02-57 in favour of
Dharamdeo Sarweshwar & Rajendra probate granted by
Girija mishra District Judge Ballia
 Sarwheshwar
 Rajendra
 Brijendra Mst bhola devi

Sachchidanand Mishra
Registered will executed on 12-08-67 in favour
of Sarweshwar, Rajendra and Brajendra, probate
granted by District Judge Ballia.

We are thankful for accepting our above pedigree otherwise Munsif court forgot to discuss and consider it and he
skipped this point, as Mst Bhola Devi also did not give the name of Mst Mukhiya devi and Parashuram Mishra and his
son Sachchidanand Mishra because her interest was affected. It was 1st biggest mistake of Minisif court which is
corrected by the District court and accepted the above pedigree.

Point No. II

Issue No.- 3, 5, 10, 11, 12 and next -12 13, 14 and 15 realated with the will of Mst Mukhiya Devi i.e. in favour of
Surweshwar and Rajendra Mishra.

I appreciate district Judge who accepted that the disputed property is ancestral property and this house is built by
Ram Karari Mishra and so the share of Mst Mukhiya is 1/2 Sachchida Nand 1/4, Dharamdeo 1/8 and Bhola Devi 1/8
but court did not accept that Mst Mukhiya has any right to issue a will in favour of Sarweshwar and Rajendra Mishra
because she will be governed by Hindu Succession Act 1925, because it is assumed without any proof and base that about
30 years back Satrughan Mishra expired and Mst Muhiya Devi governed by Hindu succession Act 1925 and this Act only
provide limited interest to a widow so she cannot execute a will in favour of Sarveshwar and Rajendra. It is only a fraud
to forcibly acquire the property of Mst Mukhiya Devi W/o Satrughna Mishra.

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NOW I EXPLAIN THAT HOW MST MUKHIYA DEVI BECOME FULL OWNER AND SHE CAN EXECUTE A
WILL AND SEAL AND GIFT THE PROPERTY ALSO.

Hindu Succession Act 1956 came in force and at the same time she become FULL OWNER. It is well known that
will comes in to Act after the death of a will executer. Mst Mukhiya Devi W/o Satrughan Mishra executed will in 1957
and were in possession. Mst Mukhiya has Written in her will that till I am alive , I shall be owner of my all movable and
immovable property and after her death Sarweshwar Mishra and Rajendra Mishra son's of Dharmadeo Mishra will
become the owner of her property .

After her death probate was also granted by the honorable District Judge of Ballia. He examined the will
thoroughly and summoned the person who were witness of the will (I)- Yamuna Pandey and (II) Uma Shankar
Upadhyay and will found genuine and probate was granted. That time there was not any problem to anyone in my
family all members i.e. Sachchidanand Mishra, Bhola Devi and Dharmdeo Mishra even Paras Mishra. Whose family has
been settled in west Bengal for ever supported the will and no, one was against the will, Girija Mishra and Shivanand
Mishra son's of Shri Narsingh Mishra were already expired before the death of Mst Mukhiya Devi W/o Satrughana
Mishra.

All the confusions created regarding the will of Mst Mukhiya Devi which was discussed in the court argument
during rejecting the will, following points will help to understand the matters properly:-

LAW OF SUCCESSION AND WILL (page no 201)

A) INLARGEMENT OF LIMITED INTEREST.

After commencement of Hindu Succession Act 1956 limited interest of disputed property would enlarge into
absolute interest by virtue of section 14 of the Act. (Smt Chandrama v/s Anjinamma AIR 2015 Kar -27,.)

Law of succession and will page no 220 :-

following main important point to be noted -"Hindu Succession act -1956 Act -14-1 property of a female Hindu to be her
absolute property.

"Any property possessed by a female Hindu whether acquired before or after the commencement of the Act shall be held
by her as a FULL OWNER there of and not as a limited owner."

Main points of its explanation is necessary to read and understand the sub section and act accordingly:-

EXPLANATION-

In this sub section property includes both movable and immovable property acquired by a female Hindu by
inheritance or device or a partition or in lue of maintenance or arrears of maintenance or by gift from any persons
whether a relative or not before at or after her marriage or by her own skill or exertion or by purchase prescription or in
any other manner WHAT SO EVER and also any such property held by her as a stridhan immediationely before
commencement of this Act-

Revenue record (Khasara and Khatouni) of Mst Mukhiya Devi W/o Satrughan Mishra were recorded with her
name. It was also shown in the probate order. It means she never remain under limited owner, Always she remain full

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owner before 1956, ie before commencement of the Act and also after the commencement of the Act . ZA Act 1950 Act 169
as provide full owner to a widow.This Act does not differentiate between male and Female. It is a view of High Court.

In this dispute only it is the question of share of the family member name Mukhiya Devi W/o Satrughana Mishra
is 1/2 share in the whole property and like this Sachchidanand Mishra S/o Parasuram Mishra is 1/4 share and Dharmdeo
Mishra S/o Narsingh Mishra is 1/8 share and Bhola Devi w/o Girija Mishra is 1/8 share as accepted herself in her
depostion in this case i.e. in record also

By dividing the share of Mst Mukhiya Devi the court has committed a blander. The Court has acted against the
law.

Original will paper No. 86A-1 and its probate paper no 67 -c-1 both the documents paper are more then 20 years
old when it was filed so under 90 (1) Indian Evidence Act as introduced in the state of U.P. it is not necessary to certify it
even then we proved its genuineness by granting the probate order and again by re evidence of the witness of the will
Shri Umashankar Upadhyay and Shri Yamuna Pandey. Also their deposition was recorded in the court to prove the will.

Also we have explained that Hindu succession Act 1925 ie women's limited interest enlarged by Hindu
Succession Act 1956 to full owner.

Further following rulings also may be considered and main points to be high lighted

(1) A9R - 2815 - Karanatka - 27 (2) A 9 R - 1977 (Supreme Court) page 1944 . (3) AWCZ - 1996 page 961
(4) RD 1981 Page No 319 and \ RD -2006 (100) - 552, RD -2007 page 072 RD -2009 - page 237, RD 1987-444, RD 1988
Page No 141, RD 1991-page 509, RJ 1987 - page 238, RJ 1992 page 70,

" When a widow becomes FULL OWNER" after receiving the property from her husband any compromise which
affect the widows interest it will be illegal and null.

So that whatever and whenever the decision against widow is given by the lower court or any court is treated as ,
nul and void so for District Judge court and Munsif Courts decision is also null and void and illegal and the Judgment is
in effective.

When the will of Mst Mukhiya Devi w/o Satrughan Mishra dated 16-02-1957 was under verification and proving
process of West Bengal one evidence paper for the court of JUNIOR LAND REVENUE OFFICER BULBUL CHANDI
(MALDA) WEST BENGAL has been submitted, which notary oath is available with me, It also may be considered.

Going against the widows will District Judge cancelled it giving the reason of limited interest of Hindu
Succession Act 1925 and ignored Hindu Succession Act 1956, Act -14-1 and also ignored by this , ZA Act -1950 -52 Act-
169. Widow can sell or execute a will, she has full right to do it because this act does not differentiate between male and
female.

B- ZA Act 1950 (Act 169) is ignored by consolation officer and not considered by the consolation officer is a great
mistake and Munsif Court as well as District court ignored and given to preference to C.O. order.

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This Act also has given the power to a widow to excute the will this power was given by ZA Act in 1950 -52 when
the Zamindari Act was abolished and after that its power of law is existing. This Act does not differenciate between Male
and female. It is stated by High Court.

I request the honorable court that please rectify this mistake and give the right of a widow as already supreme
court and also high court has given to several widows cases.

C- Seniority schedule of succession as per Z.A. Act 1950 and succession Act 1956 also ingnored. It is also a great
mistake of the court:-

Mst Mukhiya has recorded property as shown in the probate order and whatever property was in the name of
Mst Mukhiya . Along with other property even house also treated as a stridhan and her share could not be devided to the
other share holders. She had full power to give anyone by will or gift or by sale deed.

Important - In this case there are two widows 1st Mst Mukhiya Devi W/o Satrughan Mishra and IInd Mst Bhola
Devi W/o Girija Mishra Bhola Devi get power to sell the property but Mst Mukhiya Devi did not got any right or any
power. How two different laws imposed to two same category of widows in same family and same case and same
disputes. While their husbands expired nearly the same time.

Any how, Mst Mukhiya Devi got the ancestral property being the family member of Ram Karari Mishra and
being the wife of Satrughana Mishra. It does not have any meaning that how she got the property but it is true that she
got share in the property of Ram Karari Mishra without any objection during her whole life. and remains full owner as
shown in revenue record and probate order also.

Also she sold some part of land along with other share holder Dharam Deo Mishra, Girija Mishra and Sachchida
Nand Mishra to Ram Das Haridas and Lakhichand Gupta . The sold share was 1/2 of Mst Mukhiya Devi, 1/4 share of
Sachchidanand Mishra, 1/8 share of Dharmdeo Mishra and 1/8 share of Bhola Devi W/o Girija Mishra.

I want to inform your honour that we have ancestral property in West Bengal also and Mst Mukhiya Devi got 1/2
share in West Bengal also as per pedigree and as per will of Mukhiya Devi Sarweshwar and Rajendra got 1/2 share. Now
the question arise that if we got share in West Bengal property then why will not got the share in house hence will be
allowed to Sarweshwar and Rajendra Mishra .

Issue No 13 - that the will paper no-85 A-2 does not disclose that in which capacity she has become the owner of the
movable and immovable property of her husband Satrughan Mishra. This will does not give detail of the properties. In
herited or aquired by Mst Mukhiya. Only mentioned the word that she will remain owner of all moveable and immovable
property during her lifetime and after her death Sarweshwar Mishra and Rajendra Mishra will be owner of my all
movable and immovable property.

All the details are given in probate order issued by District Judge Ballia and after proving the genuineness of the
will any court will not examine again and again and accept its genuineness and give the right as per will next time any
court will not examine deeply and provide order in the favour of executer of the will. While it is not done accordingly.

House and land both comes in immovable property. As per record Mst Mukhiya was full owner of her property.
Already she had sold some lands to Haridas, Ram das and Lakhichand Gupta along with Sachchidanand Dharmadev and
Girija Mishra. This property is inherited. The will comes in force after the death of deceased.

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Hindu Succession Act 1956 gives full ownership to a widow after commencement of this act. She become full
owner and limited interest of a widow enlarged to full owner and she got full legal right to execute a will. The situation
may WHAT SO EVER word is used in the explanation of Hindu succession Act 1956. Full explanation in given on page no
4.

ZA Act 1950 Act 169 also gives legal right to a widow to execute a will because this Act does not differentiate
between male and female and so for she executed a registered , will which probate was granted and will found genuine.
so this will can not be challenge at any cost. Unfortunately during typing 131 house no is not typed in probate order but
except it all the nos of land is mentioned in probate order right from U.P. situated land to West Bangal situated lands
Anyhow Judgment will be as per will probate is only to know the wills genuineness only and court has not any power to
ignore or reject the probate granted in will (related ruling. RD. 1992 page 82.)

The District Judge has forgot that this will is not written out of our family. We are the sons of Shri Dharmdeo
Mishra and we are the successor of this house and other all property.

Succession will be as per given pedigree. When Mst Mukhiya expired following persons were alive and legl
harirs 1- Sachchidanand Mishra, 2- Dharmdeo Mishra beside it other family members were expired before the death of
Mst Mukhiya.

Beside it when Sachchidanand Mishra s/o Parasuram Mishra., expired only Dharamdeo Mishra was alive and
rest all persons of my family before it has been expired.

So for all movable and immovable property of Sachchidanand Mishra goes to Dharamdeo Mishra S/o Narsingh
Mishra.

Succession Act 1956 v/s 1925

All the aspects of Succession Act 1956 is explained herewith very well while 1925 Succession Act is illegal and not
applicable.

1. Widows limited interest of 1925 Succession act is INLARGE TO FULL OWNER SHIP and widows become full
owner.
2. Succession Act 1925 is rendered by 1956 Act- 14(1) as per High court (RD -1991-page 509).
3. Hindu Succession Act 1956 -14-1 property of a female Hindu to be her ABSOLUTE PROPERTY.
4. ZA Act 1950 is also affected and Succession Act like 1925 is also amended as per Succession Act 1956.
5. Over all court must obey the Succession Act 1956 in place of 1925 because a widows power is inlarged to FULL
OWNERSHIP by Hindu Succession Act 1956 in place of limited interest of Succession Act 1925.

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Point No III-

Issue No 16 is related with only the will of Shri Sachchidanand Mishra S/o Parasuram Mishra.

Again I thank to District Judge who did not ignore this will of Sachchida Nand Mishra otherwise it was
completely ignored by Munsif. It was not discussed by Munsif court. It was a very big mistake, Sachchidanand Mishara
S/o Parasuram Mishra executed a will in favour of Sarweshwar Mishra, Rajendra Mishra and Brajendra Mishra on dated
12-08-1967. Its probate order was granted by the District Judge of Ballia to prove its genuineness.

In the C.O. Court of Chakbandi, Dharamdeo v/s Bhola Case no 2389 Act II Chakabandi village Bharakhara when
this case was under hearing to C.O. level, two witness were produced before in the court namely Kamalakar Mishra and
Laxmi Choudhary. The C.O. court (Concilation officer) examined the will thoroughly and found satisfactory and proved
thoroughly.

When the probate order was granted by District Judge Ballia this will was given properly proved and found
genuine and so probate was granted we may say that this will was twice or thrice properly proved.

It is also not true to say that this will has not been proved in accordance with the provision contained Under
section 60 of the Indian Evidence Act.

It is also very very wrong to say that the suit was filed on the basis of under section 90(2) because this will was
only 13 years old when it was submitted.

Regarding proving of the document which is enclosed in the record.

"Revenue court Order paper no 79 C -2 has been filed (page no -11 Point No 20.)

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In spite of this one process was followed in the West Bengal also, two witness 1-Kamlakar Mishra and IInd-
Laxmi Choudhary gave their witness on dated 6-09-1975 for the court of Junior land revenue officer Bulbul Chandi,
Malda, West Bengal, Oath by notary. Their original evidence also again submitted for your kind consideration.

Concillation officer (C.O. Chakbandi) found correct and satisfied with the will and he favored us and he ordered
in, favour of will. This will was accepted and 1/4 share of Late Sachchidanand Mishra S/o Parasuram Mishra transferred
to Sarweshwar Mishra , Rajendra Mishra and, Brajendra Mishra sons of Dharmdeo Mishra. One separate Chuck (plot)
(portion of land) given to us by the same revenue court paper no 79C -2 already submitted by opponent, Rameshwar
Sharma has been filed (page no 11 point no 20).

Before it a gift deed was also given to Shri Dharmdeo Mishra S/o Shri Narsingh Mishra by Shri Sachchidanand
Mishra S/o Parasuram Mishra . Like this complete share of Shri Sachidanand Mishra 1/4 share come in favour of
Sarweshwar Mishra, Rajendra Mishra and Brajendra Mishra, By gift to Dharmdeo Mishra S/o Shri Narsingh Mishra from
Sachchidanand Mishra S/o Parasuram Mishra was allotted in a separate Khata No 50 in Khatuni and its chuck (plot) is
also provided to us. Its details is given in the Judgement copy of SOC dated 31-03-1975, page no 2 attached and submitted
by opponent paper no 79 C -2 page no 11.

Now the question arise that if we got the property of Sachchidanand Mishra in land then why share will not be
given in the house?

Now we are telling about the injustice of district judge.

In our will it is written that "When till I live, I shall be owner of my property and after my death Sarweshwar,
Rajendra and Brajendra S/o Dharamdeo Mishra will be the owner of my property.

These are the main point of the will executed by Sachchidanand Mishra on dated 12-08-1967. "Probate of this will
granted by District Judge Ballia.

The aim of granting the probate is to ensure the genuineness of the will and found the will genuine and throughly
prooved.

Unfortunately by mistake of advocate or typist we could not note the house no 131 in probate application.
Making the base of this short coming. The district Judge. Saheb forgotten the main point of will and only catch this point
that house no 131 is not mentioned in the probate and so that 1/4 share of house will not be given to Sarweshwar,
Rajendra and Brajendra Mishra.

As we have an ancestral property in West Bangal also Sachchidanand Mishra 1/4 share given to Sarweshwar,
Rajendra and Brajendra Mishra as per pedigree and as per will. There also same question arise that we got the share in
West Bengal as well as in U.P. then why not 1/4 share, will be given in the house of U.P.

It is fact that in the probate any number neither land number ror house number was given in the application of
probate. The reasons was that already 1/4 share land was recorded in the name of Dharamdeo Mishra on the base of gift
deed, As above Khata No 50 was saperately allotted.

Only land record of West Bengal was mentioned and probate was granted.

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Considering about the will of Mst Mukhiya Devi w/o Satrughan Mishra wrong Judgment was imposed upon us
by concellation officer giving the argument about the limited interest of a widow and her property distributed in the
favour of Dharamdeo Mishra, Girija Mishra and Parasnath Mishr and Sachidanand Mishra.

Now as per will of Sachchidanand Mishra 1/4 share was given in favour of Sarveshwar Mishra, Rajendra Mishra
and Brajendra Mishra sons of Dharamdeo Mishra like this I got the share inland given by C.O. as well as S.O.C. but
munsif court and district Judge of Civil court was not agree to give the share in house because its number 131 was not
mentioned in the probate order while probate is granted to verify its geniuses.

How is it possible that Sachchidanand Mishra 1/4 share given in the land but not given in the house. There is no
reason that can stop in the share in the house of Sachchidanand Mishra and there successor Sarveshwar, Rajendra and
Brajendra Mishra and as per will of Sachchidanand Mishra.

Above successor word should be remember . It remind that will is not written to outsider. We are legal owner in
the house by will, by Z.A. Act 1950 Act -169, and by Hindu Succession Act 1956 and as per pedigree also.

In this case it is a notable point that lower court become in assumption and ignoring the real and legal fact and
even documentary fact also. See point no 11 about the family living jointly governed by mitakshra school and issue no 12
and next issue no 12 (double)

Issue No 16

The court (District Judge) quoted following points-

The document is not prooved simply by the evidence of PW1 Rajendra whose signature was not found on the
will. For these reasons this will can not be relied upon as it is not properly prooved.

It is matter of surprise that what for signature is required and how signature of Rajendra will prove the document
of will whether he has not any relation regarding proving the will. I think that District Judge confused and he is not clear
that what does he want to say. When will was executed by Mst Mukhiya Devi, that time Rajendra was a minor of 2 years
child and Sarweshwar was also a minor child 10 years .

To decide the share and partition C.O. and S.O.C. court decision is also done. The decision of C.O. is followed as
it is by S.O.C., so for I appealed in the court of D D C case no 389 is waiting for decision but one decision about the will of
Shri Sachchidanand Mishra was same of both the court. The Judgment of C.O. court is submitted in the High Court
(Revenue Court Order paper no 79 C -2 has been filed page no 11, Point no 20.)

In this Judgment, of the will of Sachchidanand Mishra 1/4 Share holder accepted as per written will and one
saperate chuck (Area) plot was alloted to Sarweswar, Rajendra and Brajendra Mishra sons of Dharamdev Mishra.

It means it is wrong to assume that only share was given to Dharamdev Mishra and Girija Mishras wife Bhola
Devi 1/2 share each.

So it is prove that still this property is joint property and sofar nither partition was done nor partition wall was
constructed and neither land nor house was divided.

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In this house Bhola Devi lived Dharamdeo Mishra lived and Sarveshwar, Rajendra and Brajendra Mishra lived.
Looking to these all above points it is clear that this. Sale-deed is illegal and likely to be cancell with cost and punished
the culprit.

Point No. IV

Issue No 20

Explanation about Paras Nath Mishra Pedigree no 2 for West Bengal only.

Ram Karari Mishra

Sadhu Saran Satrughana Mishra

Narshing Parasuram Mst Mukhiya Devi

Sachchidanand

Dharam Deo Girjia Shiva Nand

Rajendra Mst Bhola Devi Paras Nath

Sarweshwar

Brajendra Narsingh Mishra settled to


Shivanand in West Bengal foraver by a family settlement /will executed on
dated 06-06-1947 on 50 Annas Revenue stamp

As previously explained that two pedigree is used in my family. One for UP and Second for West Bengal.
Pedigree No 1 is submitted by us without the name of Shivanand Mishra but pedigree no 2 is submitted by Paras Nath
Mishra separately in the court of C.O. and SOC in Chakbandi case.

Paras Nath S/o Shiva Nand Mishra's pedigree is as under this pedigree is shortained by Paras nath Mishra to
hide the fact ie illegal.

Shri Narsingh Mishra

Shivanand Girija Dharamdeo

Paras Mst Bhola Devi

Above pedigree shows that Paras nath never demanded any share from Mst Mukhiya Devi and Sachchida nand
Mishra. He wanted only share from Narsingh Mishra.

It is shown in the paper against the judgement of SOC court judgement dated 31-03-75 page no 2 attached
herewith.

All the family members accept that Shiva nand Mishra was the son of Narsingh Mishra, I accept it Bhola Devi has
also accepted it by her pedigree i.e. giving reply of my claim application on in Munsif court. Munsif court also and the
District Judge also accepted this fact. Also Bhola Devi had accepted that Shiva Nand Mishra was settled in West Bengal
for ever. Acctual fact and details are given below:-

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Shri Narsingh Mishra settled his elder son Shiva Nand Mishra in West Bengal for ever by giving his share of
Uttar Pradesh village Bharakhara, Tehsil Bansdih Paragana Kharid Distt.- Ballia by executing a family settlement will.
This family settlement will is a family settlement letter in which he explained that Shiva Nand Mishra will not get any
share in the property of Uttar Pradesh. The property will be distributed in only his two sons namely Dharamdev Mishra
and Girja Mishra. So there is no question of Shiva nand Mishra share in Uttar Pradesh property. One land was purchased
in West Bengal district Malda, P.S. Habibpur Village Sankail against his share of Uttar Pradesh.

This document will/ family setteltment letter written by Narsingh Mishra S/o Shiva Nand Mishra is more than
20 years old and before this will, Shiva nand Mishra living in West Bengal along with complete family with his son Paras
Nath Mishra. According to this document till now we all fallows. Paras Nath Mishra claimed for his share in UP during
chakbandi. The case is still waiting for judgment in the court of DDC in Chakbandi Court.

As per Supreme Court, Provision it is provided that after getting the benefit of joint family after getting his share
if again any dispute aries between the share holder he could not get any share again.

So that about discussing and thinking about his share, It is illegal.

If possessions continuity break is also main reasons. If possession continuity remain broken more than the
decades then possession ended as per estoppels and as per High Court and Supreme Court. Paras Nath did not remain
here more then many decades along with his parents since 1947 when he was a child to till date as per will and
compromise and family settlement by Narsingh Mishra .

This will is a family settlement letter executed on the revenue stamp paper of 8 annas which was written / signed
by Narsingh Mishra and Bidyarthi Mishra and Harihar Prasad both our neighbour. Who are t he witness of this will.
Our family member Sachchidanand Mishra purchesed this revenue stamp paper of eight annas during these period his
name remain unrecorded in the revenue record since 1947 till Date, so it is clear that Shiva Nand Mishra and his son Paras
Nath Mishra don't have any share in U.P’S. property, so it is proved that Paras Nath did/ not surrender any property or
any share to Bhola Devi. It is only an assumption because, Shivanand himself has not any share in U.P. then how could
his son Paras Nath Mishra provide transfer his share to any other person. It is only an attempt to justify the excessive sale
of Bhola Devi .

As per supreme court fasali 1356 the base year of recording in revenue record. Its entries in record in fasali 1356 is
not done by any reason. any one not get the share. This year is a base for recording in revenue record Shiva Nand Mishra
could not record entries in Fasali year 1356 , 1359, 1362 . These are the settlement years in which any correction may be
done but Shivanand was satisfy and so that he had not any complaint against this compromise will written by Narsingh
Mishra Whole family accepted the will of Shri Narsingh Mishra S/o Sadhu Saran Mishra and acted accordingly, since last
- 73 years hence No share was given to Shivanand Mishra and his son Paras Nath Mishra, also he agreed and satisfy. but
when Chakbandi started in my village some villagers including defender no 1 to 5 who is my enemy call Paras Nath from
West Bengal and involve us in the case wide is case no 389 still waiting for justice in DDC court since long time.

There is not any proof that Shiva Nand Mishra stayed ever any time, even Shivanand Mishra's son Paras Nath
Mishra also never stayed in U.P. He never paid any revenue in U.P. He did not have any house or any room in village
house. He does not have any name in the record of voter list. All this show that there is not any concern with the property
of U.P. even his name was not recorded in Kutumb Register also. When complete family's name is recorded (Its called
Birth and death register). During last 73 years since 1947. He never got Rasan card or Rasan from food department. even

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then district judge and munsif and Mst Bhola Devi also supported our view that family of Paras Nath Mishra did not
stayed in U.P. So he did not got any share in Uttar Pradesh.

Paras Nath Mishra is aware of his position in detailed and so for he did not appear in the court so that it is clear
that Paras Nath Mishra has not any connection with the property of U.P. Paras Nath Mishra & his family is out of touch
since 1947 to till date since last 73 years.

Related Rulings (1) RD 1966, page -174, (2) R.D. 1977 page 4362, (3) R J - 1992 page 68, (4) AWC - 2006 (5) Page
4216

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Point No. V

UNTRUE STATEMENT OF DEFFENDERS AND FRAUD AND ITS CLARIFICATION BY APELANTS

Issue no 5, 7 , 17

UNVAILING OF BLACK MAGIC OF PARTITON AND PARTION WALL.

Imagination of a lie partition wall is a very very big fraud of this case whose Munsif court as well as district court
failed to find the truth and ignore the facts.

I am describing about the lie bundle of a partition and partition wall. Actually in the sketch where a simple
straight line is drawn from north end to south end practically there is not any such wall constructed. It is stated by our
witness Haridwar that a wall is there. It means wall is there. There is not any partition wall. Any wall can not be a
partition wall. Every room have 4 no of walls in which one side contains doors and wall.

Please see, page no 4-5 evidence of Bhola Devi. Herself Bhola Devi denies that any partition wall is not
constructed.

Please see her original words.

1. esjs o eqnb;ku ds chp dksbZ vnkyrh caVokjk ugha gqvk gSA


There is not any legal partition held in the court between our family.
2. caVokjs dk dksbZ dkxt Hkh ugha fy[kk x;k gSA
There is not done any written partition.
3. iwjs edku dk Nktu ,d gh esa gSA
All the roofs of house is connected with each other or each one.
4. njoktk vyx vyx gSA
Each door were made separately.
5. fgLlksa ds chp dksbZ fnokj dk;e ugha dh x;h gSA
No wall is constructed between the share holders.
6. lgqfy;r ds fglkc ls eSa vkSj eqnbZ;ku fookfnr edku easa jgrs gSaA
As per there one facility, I (Bhola Devi) and we, (Dharaa Deo, and Sarweshwar, Rajendra, Brajendra , Shiv
Kumari Devi lived in the house.
7. esjs o eqnbZ;ku ds ifjokj ds vykok edku utkbZ esa dksbZ vU; O;fDr ugha jgrk gSA
Except my self (Bhola Devi) and applicant's family (Dharam Deo Mishra ) with her wife Shiv Kumari Devi, and
Son's Sarwehsar , Rajendra and Brajendra lived in this house.

This above all seven points evidence of Bhola Devi proof that neither any partition was done nor any partition
wall was constructed.

8. Beside this Bhola Devi accepted about the family who lived in this house is given below:-
Evidence of Bhola Devi page no 4 point no 5

Ram Karari Mishra has two sons Satrughan Mishra and Shadhu Saran Mishra, the wife of Satrughan Mishra was
Mst Mukhiya Devi .

Page 12 of 29
Sadhu Saran Mishra has two sons Narsingh Mishra and Parasruram Mishra, Sachchidanand Mishra was the son
of Parasuram Mishra . Dharam Dev Mishra and Girija Mishra were the son's of Narsingh Mishra . Sarweshwar Mishra ,
Rajendra Mishra and Brajendra Mishra the Son's of Dharam Deo Mishra . I the Bhola Devi W/o Girija Mishra.

This evidence clearly explain that after the death of Satrughana Mishra Mst- Mukhiya Devi w/o Satrughana
Mishra 1/2 Share holder.

Sachchidanand Mishra S/o Parasuram Mishra 1/4 share holder. Dharamdev Mishra S/o Narsingh Mishra 1/8
share holder and Bhola Devi w/o Girija Mishra 1/8 share holder were living in the dwelling house . How is it a talk of
foolishmess that District Judge assumed only two share and 1/2 share given to Dharamdeo Mishra and 1/2 share was
given to Bhola Devi/ while above all family member was living in above dweling house together.

All written evidence is ignored and share of all persons divided in to two shares without any proof.

Judgment is done on the solid base not on assumption:-

So it is clear that neither any partition was done nor any partition wall was constructed.

9. As Bhola Devi says that all the roofs are together and doors are separate . It means walls supporting the roofs are
there, it may called the wall only. It is wrong to say it partition wall. Also our evidence Haridwar’s statement is
highlighted by District Judge that there is a wall, means roof supporting wall. It is wrong to say it partition wall.
Further Bhola Devi says in her evidence that doors are separate it means it is very very clear that doors are between
the rooms. towards both court yards both side is open. If any partition wall constructed it will first closed the open
doors of eastern side court yard because in the map false partition straight line is drawn towards eastern court yard
from north to south. All the doors are separate and opened so roof supporting walls can’t be partition wall. Furthur
Bhola Devi’s statement that there is not made any partition wall to separate the share between the share holders as
stated on back page. How great proof is it that there was not made any partition wall containing door’s Roof
supporting wall never be partition wall .

Further Bhola Devi says that "There was not any saperation between Bhola Devi and Dharamdev Mishra, between
both the parties. Further Bhola Devi says that there was not written any paper by the court, It means there was not
done any legal partition by any court.

Further Bhola Devi says that as per own facilities both the parties lived together further she says that we both
lived together in the same house and no one els lived in the house.

The meaning of these lines to be clear and understood perfectly. The District Judge and Munsif both understand
that only two persons Dharamdeo Mishra and Bhola Devi living in the house together, But Dharamdev Mishra share
1/8 is combind with Sarweshwar Mishra and Rajendra Mishra’s share of Mukhiya Devi 1/2 share and again
combined share Sarweshwar, Rajendra and Brajendra 1/4 share of Sachchidanand Mishra’s share means 1/8 + 1/2 +
1/4 = 7/8 share of Dharmdeo Mishra and there son's Sarweshwar, Rajendra and Brajendra.

Bhola Devi having only one room as per her 1/8 share . It is a matter of surprise that without any proof how can
court assume 1/2 equal share of Dharmdeo Mishra and Bhola Devi against there 1/8 share each. While no one
demanded such wrong share distribution.

Page 13 of 29
This above all proves that neither partition was done nor partition wall was constructed . So for partition line of
map is a fake line and confused the whole case and District Judge as well as munsif both were misguided and
confused and kept far away with right decision.

So for it is clear that there was not constructed any partition wall to separate eastern portion and western portion
of the house.

Commissioner’s report does not says that there was any partition wall constructed between west and east
courtyard.

In reply of Bhola Devi against my application there was not mentioned anywhere about partition. As per fraud
map all the doors shown closed but practically all the doors are opened even today. There are two no of doors opened
in Eastern courtyard as well as western court yard which connect the eastern court yard and western court yard
through two rooms and their doors.

In this map where partition fake wall is shown, one straight line from North to South up to last end crossing the
room of Sachchidanand Mishra but his room is as it is because there is not any partition wall. The map which was
produced before the court of Munsif also its date is not clear and found over writing creating suspicion.

The commission report does not match or tally with the map so it is a part of fraud so produced map by defender
is not acceptable.

10. Bhola Devi W/o Girija Mishra defendant No.5 herself accepted in her evidence in this case that " fookfnr
edku esa igys ujflag ij'kqjke o eqf[k;k nsoh jgrh Fkh " It means before the dispute and before the death of Satrughna
Mishra, Narsingh Mishra S/o Sadhu Saran Mishra, Parashuram Mishra S/o Sadhu Saran Mishra and Mst
Mukhiya Devi W/o Satrughan Mishra was living in this disputed house.

If before 30 years partition was done and partition wall was constructed and due to partition wall separate rooms
door were closed then how does Narsingh Mishra and his family, Parasuram Mishra, and his family and Mst Mukhiya
Devi and her family lived together? Above 10 points clearly shows that nither partition was done nor partition wall was
constructed.

Now also it is clear that Narsingh Mishra's son's Dharmdeo Mishra and Girija Mishra lived in this house and
Parasuram Mishra's son Sachchidanand Mishra also lived in this house and Mst Mukhiya Devi W/o Satrughana Mishra
also lived in this house. It is proved that the disputed dwelling house is undevided or unportitioned and all the above
share holders were living in the undivided dwelling house together. Though this it is proved that the share of Mst
Mukhiya is 1/2 Sachchidanand Mishra is 1/4 and Dharamdev Mishra is 1/8 and Bhola Devi share is only 1/8 like this
total share of Sarveshwar Mishra, Rajendra Mishra and Brajendra Mishra is 1/2+1/4+1/8=7/8 and Mst Bhola Devi share
is 1/8. Bhola Devi had only one room as per her own requirement of one person, and other rooms are resided by
Mukhiya Devi, Dharamdev Mishra and Sachchidanand Mishra etc.

It is a matter of surprise that without any proof how does court assume 1/2 equal share to Dharamdev Mishra
and Bhola Devi? without describing and considering other persons of family.

This all above points proof that neither partition wall was constructed between eastern portion and western
portion of both courtyard to separate the same nor partition wall was constructed.

Page 14 of 29
As C.O. Court case judgment is submitted in this court and same case is undertrial in the court of D.D.C. and its
judgment is pending it is a question that what for this case is being tried? Its answer is very clear that the case is being
tried for share of Mst Mukhiya, Sachchidanand, Dharamdev, Bhola Devi and Paras Nath.

This pending case in DDC court itself is a big proof that there was not any division between the share holders so
it is also clear that neither partition was done nor partition wall was constructed in the house.

Here fallowing phrase is correct “Thief left any sign behind hime.” But here thiefs left many sign behind him

Internal portion of the house is given here and show that how the joint family lived in this house only six rooms were
usable and Mukhiya Devi Dharmadeo mishra, Schchidanand Mishra, Bhola Devi, Sarweshwar Mishra, Rajendra Mishra
and Brajendra Mishra and Gaitri Devi, Savitri Devi, Janeshwari Devi 10 family member of Joint family were living in this
house.

There are three ruins also in this house which ownership was of all and all 10 members living jointly. In this
situation how partition is possible in this house. It means neither partition was done nor any partition wall was
constructed.

Given Map of house clears that position of dwelling house and the persons living in this room as follows:-

Room No Personal leaving in the Bhola Devi


1 Bhola Devi
2 Sachchidanand Mishra
3 Mukhiya Devi
4 Dharmadev Mishra
5 Janeshwari Devi Sister of Dharmadev and Girija
6 Mukhiya Devi and kids
7 Dharam dev and family

Bhola Devi herself accepted in her evidence that case is pending between us in the chakbandi court . The case is
pending in the court of DDC then how the partition is accepted . It means neither partition was done nor partition wall
was constructed.

I am giving herewith the extra statement and evidence of Bhola Devi page no 5 point no 6

1. eqf[k;k bl edku esa vk/ks dh fgLlsnkj Fkh]


Mukhiya Devi was 1/2 share holder in this house.
2. lfPpnkuUn feJ bl edku ds vk/ks ds vk/ks ds fgLlsnkj FksA
Sachchidanand Mishra was share holder of 1/4 share.
3- eSa bl eqdnesa esa dksbZ dkxt ugha yxk;k gSA
I have not submitted any proof in this case.

This point to be kept in mind that in t his case Judgment is given without any proof on the base of imagination.
4- fookfnr edku esa igys ujflag feJk ij'kqjke feJ o eq0 eqf[k;k jgrs Fks
In this disputed house Narsingh Mishra, Parsuram Mishra and Mst Mukhiya Devi lived.
5- eqf[k;k o lfPpnkuUn us esjs i{k esa dksbZ dkxt ugha fy[kk gSA
Mst Mukhiya and Sachchidanand Mishra did not write any compromise letter in my favour.
6- fookfnr edku esa lHkh yksx bdV~Bk jgrs FksA
All family members lived together in this disputed house.
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7- ujflag feJ dh 'kk[kk esa esjk vk/kk fgLlk gSA
I am a half share holder in the Branch of Narsingh Mishra.
8- esjs o eqnbZ;ku ds chp esa dksbZ vnkyrh caVokjk ugha gqvk gSA
There was not done any legal partition between Bhola Devi and appellant through any court of law.
9- caVokjs dk dksbZ dkxt Hkh ugha fy[kk x;k gSA
There was not written any compromise letter.
10- iwjs edku dk Nktu ,d gh esa gSA
All the roofs of this house is under one roof connected.
11- fgLlksa ds chp dksbZ fnokj dk;e ugha dh x;h gSA
Any partition wall between the share holders was not constructed.
12- lgqfy;r ds fglkc ls eSa vkSj eqnb;ku fookfnr edku esa jgrs gSA
We live in this disputed house as per own facility.
13- eSausa dHkh eqnb;ku ls cspus dh ckr ugha fd;k FkkA
We did not talked with the appellant for selling the house.
14- f'kokuUn us vius fgLls dk dksbZ dkxt esjs gd esa ugha fy[kk gSA
Shivanand Mishra did not write any compromise letter to surrender any share in my favor.

Above all fourteen points support us so it may be considerd again because these evidence clears their case
automatically and it is proved that whataver I says the statements of Bhola Devi confirm it, so it is proved that my all
statement is true and valid and legal so my all request may be accepted.

Issue no -5 It is assumed by the defendant no 1 to 5 also that one partition was done before, 20 years, 30 years or
50 years ago when the case was started, means 1980-50=1930, so Succession Act 1925 was imposed and wrong judgment
was given. It is to be understood that Mst Mukhiya 1/2 share holder, Sachchidanand Mishra 1/4 share holder, and Girija
Mishra 1/8 share holder, and Dharamdev Mishra 1/8 share holder, total 4 family was leaving in this house along with
other family members and kids as explained in the map House No. 131.

Is it possible that, that time when partition was done Mst Mukhiya and Sachchidanand Mishra remained keep
mum and only share was given to Girija and Dharamdev? It clearly show, that there was neither any partition was done
nor any partition wall was constructed.

The question arise that why this story was fabricated. The only reasons was that fear of 1956 Hindu
Succession Act whose Act 14-1 given power to a widow to full ownership. So they try to escape from this Act and so for
wrong Hindu Succession Act 1925 Imposed by knowingly wrong imagination.

Beside it due to same reason ZA Act 1950-52 Act 169 not considered by any revenue Court (co.or soc. Level)

Written document shows that revenue record was noted in favour of Mst Mukhiya and Sachchidanand
Mishra and Dharamdev Mishrta and Girija Mishra according to their share, 1/2, 1/4, 1/8 and 1/8 respectively so it is
proved that neither any partition, was done nor partition wall was constructed.

All the assumption is lie and false and it reason is only to impose the Hindu Succession. Act 1925 ie illegal
as per High Court.

Hindu Succession Act 1956 RENDERED all earlier Acts. R.D. 1991 page 509.

Page 16 of 29
It is a big question that why did partition was assumed. Its reason is clear that this risk was taken to impose,
Succession Act 1925 to escape from application of Hindu Succession Act 1956.

It is a matter of thaught that as per defendent no 1 to 5 it says that partition was done in about 1948 means 2020-
1948= 72 years back and till the date house no 131 remain the same and partition was done in 1948 and still the house
number remain same 131, is it is not changed. It shows that neither any partition was done nor any partition wall was
constructed. It is a big fraud of opponent.

Important Point-

I want to notice and explain the following point which was very very old matter and it also struck the thinking
and assumption of partition and partition wall. When we started to search old record we found the name of Rama
Shankar Mishra S/o Satrughana Mishra and Mst Mukhiya Devi. Being the wife of Satrughana Mishra got the property
but between the death of Satrughana Mishra and Mst Mukhiya Devi. Rama Shankar Mishra S/o Satrughana Mishra and
Mukhiya Devi remain alive and their name was found in the old revenue record one khatoni of revenue recoverd fasali
1345 is submitted which is issued on dated 13-01-1941. As a prove where the name of Rama Shankar Mishra s/o
Satrughana Mishra is recorded. Rama Shankar expired before the death of Mst Mukhiya .

After Z.A. Act 1950 as per record he was alive. It shows that assumption of partition and construction of partition
wall is lie so it is clear that neither partition was done nor any partition wall was constructed only pack wall was
assumed.

By this proof it is clear that Mst Mukhiya Devi living in this house with her husband Satrughana Mishra and her
son Rama Shankar Mishra. The ownership was transfer from Satrughana Mishra to his son Rama Shankar Mishra after his
father's death as per succession and after the death of Rama Shankar Mishra, ownership was transferred to Mst Mukhiya
Devi and after the death of Mst Mukhiya Devi after about 1959 Sarveshwar and Rajendra Mishra become owner of the
property of Mst Mukhiya Devi as per her executed will date 16-02-1957 and as per granted probate by district judge after
passing Hindu Succession Act 1956.

This Act clears that it will not be questioned that how a widow acquired her property?

Please see explanation of Hindu Succession Act 1956 as given at back page no 4. It is a part of fraud of opponent
defender no 1 to 5 it is also a reply of Munsif and district Judge questions- This fact was known to us when we tried to
find the reply of questions of the both court Munsif court and District Judge Court.

Mst Bhola Devi was oldest and elder lady of my family and she covered with the curtain of fraud. She
intentionally did not disclose the name of Rama Shankar Mishra, son of Satrughana Mishra and Mst Mukhiya Devi. The
motive was only to prove (the fraud) of partition and partition wall but actually facts come in light and darkness will go
back. Now matter is clear that how 1925 was imposed against succession Act 1956.

About sale deed of Mst Mukhiya Devi

After getting the property being the wife of Satrughana Mishra Mukhiya Devi get recorded in the revenue record in her
name with other share holder Sachchidanand Mishra, Dharmdev Mishra and Girija Mishra share 1/2, 1/4, 1/8 and 1/8
respectively. She sold some joint property along with other share holder revenue record is given herewith. Property was

Page 17 of 29
sold to Ramdas, Haridas and Lakhichand Gupta in approximate year 1956 is less than 30 years . It also shows that there
was not such partition between the share holders. It is also clear that neither partition was done nor partition wall was
constructed.

Now it is necessary to explain and understand that why partition is assumed and this partition wall is assumed.
The aim is very clear that commencement of Hindu Succession Act after 1956 Mst Mukhiya Devi become full owner and it
was not possible to break this law except fraud. It was not possible to impose the women's limited interest without
imposing Succession Act 1925 and so for 30 years back partition was assumed and declared and illegal partition act 1925
imposed. It is the act of a little knowledge persons having negative attitude and thinking and belief only in committing
fraud. Here it is also clear that partition before 32 years back and partition wall construction before 30 years back is a lie
and nothing except fraud and there is not any proof also it depends upon the basis of verbal talking one hand we have
given written proof which is not consider and another hand on verbal talk it is accepted as a proof.

It is very clear that which proof is solid and believable verbal or written?

Issue no - 18,

About Commisner Report

The report of the advocate commissner Shri Ramadhar Tiwari paper no 23c-2 and the Map no 18-c-2 attached with it also
support the view that partition on the spot and the plaintiffs and Smt Bhola Devi defendant No . 5 are living in saperate
portion. It is true that Bhola Devi's room is situated in eastern part and Dharmadeo Mishra room is in the middle portion.
both the rooms are situated in North side of the house and both are connected with double door between eastern and
western courtyard. Being Dharmdeo Mishra rooms is situated in middle of the both court yard this room is connected
with western court yard. So for it is wrong to say that Bhola Devi and Dharamdev Mishra living separately. It does not
prove that any partition was done only between Dharmdeo Mishra and Bhola Devi and there was not done with Mukhiya
Devi and Sachchidanand Mishra. This all shows that neither any partition was done nor any partition wall was
constructed .

Already this dwelling house was made by Ram Karari Mishra in two section as clearly shown in map. It is also
true that our family remain joint it means there was not done any partition.

Evidence of Hardiwar is highlighted by District Judge It does not say that partition was done and partition wall
was constructed. Rajendra never says that any partition was done. This all statement is assumed by defenders.

Now we talk about PW-3 Baleshwar Sharma's evidence. It is effectless because the favouring of his real brother
Rameshwar Sharma who is the father of Rajesh, Brijesh and Laxmikant Sharma. His evidence can not be reliable.

Tilted sentence and tilted word will not prove the partition and partition wall which is not present in site. It is
assumed that partition wall which is not even hanging in air also. Existing of this wall is zero.

It is said that partition held before 30-32 years back when Mukhiya Devi and Sachchidanand Mishra alive then
why does their share 1/2 and 1/4 respectively not given to them. While both regularly remain in the house till there
death.

Issue no 19.

Page 18 of 29
It is saying again and again that still Bhola Devi is living in her house that still Dharamdeo Mishra sons also
living in this house and Mukhiya Devi's property owner and Sachchidanand Mishra property owners Sarweshwar,
Rajendra and Brajendra Mishra are also living in this house from eastern court yard to western court yard.

It is true that Bhola Devi was living in room no 1, It was her right but selling of Ruin no 1 which is combined
property of all it illegality is clear that Bhola Devi sold the others share and was living in her one share which she got
before the life of her husband, Girija Mishra under kitchen separation only.

Issue No 21:

It is accepted by District Judge that the ancestral dwelling house of Rama Karari Mishra has come only to the share of
Dharamadev the father of plaintiffs and Girija husband of Bhola Devi. It makes it clear that Dharamdeo and Girija both
has equal share in the disputed house. After the death of legal heirs.

Legal hairs has not been explained properly. The question is that who are the legal heirs. After the death of
Narsingh Mishra Dharamdeo and Girija was legal heirs but before the death of Shri Narsingh Mishra. How many legal
heirs was living in this house?

In her evidence Bhola Devi had already accepted that Mst Mukhiya Dvi 1/2 share holder was living in this house
and also 1/4 share holder Shri Sachchidanand Mishra was living in this disputed dwelling house. If this fact is accepted
then in this dwelling house Mst Mukhiya Devi’s share 1/2 + Sachchidanand Mishra’s Share 1/4 + Dharmadev Mishra’s
share 1/8 and Bhola Devi’s share is only 1/8. So that Rajendra Mishra and Sarweshwar Mishra’s share 1/2 after the death
of Mst Mukhiya as per her will and as per Hindu Succession Act 1956 who rendered the all earlier acts so dealing as per
Hindu Succession Act 1925 is clearly illegal, This fraud should be rectied immediately. Similarly Sarweshwar , Rajendra
and Brajendra Mishra's share is 1/4 after the death of Sachchidanand Mishra as per their will. Sachchidanand Mishra
share is not given because District Judge did not accept the will reasoning that will is not prooved while this will is
several times proved and as per Supreme Court" once the will is prooved or examined than there is not need to examine
again and again and deeply and property should be transferred as per WILL.

So it is also to be rectify and Dharmadeo Mishra share is 1/8 not 1/2 and Bhola Devi share is also equal to
Dharamdev Mishra share 1/8. Like this our share is 7/8 and Bhola Devi share is 1/8, like this District Judge as well as
Munsif given wrong Judgement and by accepting only 1/2 share to Dharamdeo and 1/2 share to Bhola Devi. It must be
rectify and all legal heirs must gate there legal share.

Issue No. 22, 23- does not clear any sence which may prove any sence in our case. It is tried to entangle the
statement and also tried to misguide to real matter this sales document is not valid document 1st our all valid point
should be considered than it should be considered about the validity. This sale deed document is full of errors. Regarding
explanation sold area 13 khata 12 dhoor and house no - 131. This words does not mean that partition is accepted.

Issue No. 24:

The provision of section 4 of partition Act is attracted in the present case. Bhola Devi already accepted that there is neither
legal partition of dwelling house nor any partition wall is constructed. This house is made by Ram Karari Mishra. As per
Bhola Devi evidence Mukhiya Devi, Sachchidanand Mishra living in this house together as per their own facility with
Bhola Devi. So this house was ancestral property. Dwelling house is undivided property and ancestral property. This
house is single dwelling unit and its division is not done, As herself Bhola Devi accepted many times in her evidence that

Page 19 of 29
all other family members were living in this dwelling house as per their own will and own facility as usually joint family
live together.

Issue No. 25:

It is proved by our legal points that any partition was not done. sale deed of (Rajesh, Brijesh, Laxmikant) the son's of
Rameshwar Sharma was executed by Bhola Devi connivengly. So this sale deed is likely to be cancelled. Secondly the
value of t he property is Rs. 900/- only. Which is too low. It is too low in comparession of its actual price caused revenue
loss. Besides it more area is assumed so that more land can be written but in actual less land was written and after that
remaining land was captured like this full tax was not given and losses given to government . Also these are the above
reasons that this sale deed may be cancelled.

This sale deed is under a big froud because 1/2 share of Mst Mukhiya has cancelled . 1/4 share of Sachchidanand
Mishra has also ignored and cancelled. This 100% property is divided in only two hands (Dharmadeo Mishra and Bhola
Devi) and she became 1/2 share holder without any document and proof Mukhiya Devi share 1/2 and Sachchidanand
Mishra share 1/4 Total 3/4 share was cancelled and ignored even than partition is assumed and partition wall is
assumed.

Justice is based and depends upon the ral fact and not at assumption. It is also assumed by District Judge that
PERHAPS she got more share and sold some share. It means District Judge himself is under dout and confused because
he use word perhaps it shows that himself district Juj is under dought.

The use of word PERHAPS prooves that this sale deed is based on assumption and not depend on the ral fact and
in the absence of the ral fact and reality this judgment is wrong and under doubtful and so for this sale deed is likely to be
cancelled.

Issue No. 17

Evidence of D W 3 Baleshwar Sharma S/o Dhani Sharma is the real Brother of Rameshwar Sharma is a also Father of
Rajesh Brijesh and Laxmi kant. Baleshwar Sharma deposed that the disputed house has been partitioned some 30, 32
years back it means 1980-32 =1948. So that Succession Act 1925 may be imposed easly but it is meaning less because Mst
Mukhiya Devi's will was executed in 1957 and Hindu succession Act 1956 was passed before the writing of will and
widows limited interest was enlarged to full ownership and without any proof partition and construction of partition
wall can not be proved.

DW 3 Baleshwar Sharma was a young when this evidence was recovered in 1980 when case was started 1980-25 =
1955. Means that time evidence was not born and he gave evidence behind 30 years back it means fake evidence was
recorded.

Other evidence young man Dahari Mishra as say that before 30-32 years. Partition was done between
Dharmadeo Mishra and Bhola Devi (1980- 32= 48 years) when Satrughana Mishra expired and Mst Mukhiya Devi got
limited interest while Mst Mukhiya Devi W/o Satrughana Mishra got property from his son Ramashankar Mishra S/o

Page 20 of 29
Satrughana Mishra and as per Z.A. Act 1950-52 - Act -169 and after passing Hindu Succession Act 1956. She become full
owner like this assumption of froud by Defender No. 1 to 5 is not effective.

Issue No. 4, 6, 7, 8, 9 already discussed under above points and need not be repeated it again and again.

Point No VI

Munsif court issue already discussed with issue of District Judge Any how some issue of Munsif is left without
discussion. We are trying to discuss in brief so that his ideas and issues may be understand clearly.

As discussed below:-

Munsif issue No. 6

When I knew about the sale deed executed by Bhola Devi we put an application to the Munsif court in writing
and request that we are ready to refund the amount of Rs. 900/- but both the court did not give attention to this legal
matter and avoided it.

Herself Mst Bhola Devi state in her evidence Page no 4-5- extra narration no - 15

" I did not talk with appellant about sale of joint house. I sold half share of her house at Rs. 900/-. Further she says
that if he could give back to us Rs. 900 than I would backed written the sale deed in favour of appellant."

It is clear that as per law I have 1st purchasing right because I am family member of joint family of Bhola Devi
Supreme Court also support my Ist purchasing right refer ruling……

Bhola Devi gives different statement at a time. First she says that I did not talk about the sale of property to us
and immediately at the some time , She says that if they could give us the price of the house I could sale house to him
also.

This sale deed was executed on dated 02-06-1980 but she did not notice us. It was hidden so that we could not
purchase it this above statement she says that. " I sold half portion of my house at Rs. 900/- to Rameshwar Sharma."

Half share means half of 1/8 is 1/16 share. Means as per her statement only she sold 1/16 share.

(ii) It is said that the advocate did not reply the question and kept silent. It does not means that, he accepted the
wrong things. It is not said that at what point he did not reply and he accepted. It was lawful. What ever point was
accepted is it as per law correct? It should be noticed again and should be clarified.

Every thing is in writing and all the proof are provided and each and every things are clear. If an advocate does
not reply and not prepare for argument about the case. He will be unable to explain the points properly. It does not mean
that he accepted the wrong points, and judgment will be given against without self realization. This point only create
cloud.

The reason of advocate silence may be the lack of knowledge of succession Act 19956 which Mst Mukhiya Devi.
become full owner as many does not knows about it till now and knowledge of Z.A. Act 1950 .Act 169 provide the power
of will to a widow. This act does not differentiate between man and woman (male and female).

Page 21 of 29
Issue No., 8 Munsif

The argument is totally wrong. The argument is so far than the real point.

The real point is that defendant no- 5 Bhola Devi come under the approach of defender no 1 to 4 and ask her to
envolve us under the chakbandi case still this case is under Judgment in D.D.C. Court at Ballia. Like this he purchased
the portion of my dwelling house and involve me in such a case that my whole life is spoiled to follow behind the court
for waiting the judgment. I am a man of 75 years of age and it seems that these cases will be finished after my life so for I
am hopeless and expect your mecry.

So for this sale deed it is likely to be concelle here phrase " Beating about the bush" is correct and characteries.

Additional Statement no - 10 of Bhola Devi is given below:-

This house was constructed by Shri Ramkarari Mishra his family was living regularly in this house. His sons
Sadhu Saran Mishra and Satrughan Mishra were living in this house with their family. The widow of Satrughan Mishra
Mst Mukhiya Devi was living in this house her share was 1/2. She lived up to nearlys 1958 means her whole life she lived
here in this house. Now the question arise that was she living in the house without her right? Was she not full owner of
her property in 1957 when will was executed and even after the Succession Act 1956 passed?

Like this Sadhu Saran Mishra had two son's Shri Narsingh Mishra and Prasuram Mishra. In Eastern Court Yard
South side house was occupied by Parasuram Mishra and his son Sachchidanand Mishra. His share was 1/4 then
question arise that is he lived in this house without any right?

How is it possible that only Shri Narsingh Mishra's sons were entitled to get 100% share 50% Dharamdeo Mishra
and 50% share Girija Mishra in 1948. Because partitions was assumed before 30 years of sale deed of Bhola Devi while
actual share of Dharamdeo Mishra and Girija Mishra was 1/8 each respectively. Though no such claim was preferred by
any of them.

Partition was assumed and Mukhiya Devi share 1/2 + Sachchidanand Mishra share 1/4 = 3/4 total share was
distributed to Dharamdev Mishra and Girija Mishra without any proof and without any evidence and without any order
of authority and without any Demond that too 30 years before.

"What may be other so great lie?"

Additional Narration no -13 also a big lie where 30 years before partition and partition wall and its possession was
assumed. Strongly. I oppose this above fraud. There is not any sign of partition wall.

It is a great failure of Court who could not find such things and failed to investigate.

Issue No 10 Musif court

Page 22 of 29
If this point is accepted the Bhola Devi's share will be divided in to 3 share and it will be more less then her
present share 1/8 i.e. 12.5% to reduced to share 25% /3 = 8 % .

It is matter of surprise that District Judge gave equal share 1/2 to Dharamdev Mishra and Mst Bhola Devi.
Whereas we are saying that Dharamdeo Mishra's share is only 1/8 and wrongly 1/2 is given, We are not agree with this
fraud because not a single person’s of my family requested ordemond such illegal share’s. How other share holders as
Mukhiya Devi ½ Share and Sachchida Nand ¼ total ¾ share holders share is distributed.

Also it’s a matter of Surprise that inspite of not providing any document or proof regarding any partition by
opposition court gave Jugement in favour of opposition. Ever district Judge accepted that this property is ancestral
property of Ram Karari Mishra eventhan he distributed property between Dharamdeo and Girija equally ½ share and
egnor all other share holders who alive.

Munsif court issue no 11 page no 3

As per T.P. Act 41 provide security when sale deed is done in hormoniuos relation on the defender has seen since
several year that Bhola Devi living in the estern parts of house. then why did not see Sachchidanand who was also living
in the eastern part of the house and similarly why he could not see Mst Mukhiya Devi and Dharmadeo Mishra. Who were
living in the central portion which doors open in both eastern and western court yard in the rooms and they were also
share holder of this complete dwelling house because this is joint property and till the date this house is undivided
property .

One case is under judgment in the court of DDC which is not finalised this case is running only for the partition
and all the partners are waiting for partition till now.

DDC court case itself is a biggest proof that all the property is undivided and still to be divide and it is under
process till now.

Further it is said by Munsif that as per T.P. Act 41 sale and purchase is done in harmony Court provided shelter
to purchaser Here after, the sale dispute is occured, froud and greeds crossed the limit. The power and right of a women
is snatched .Many share holders name from family pedigree is hidden also complete pedigree of Parashuram Mishra and
his son Sachchidanand Mishra and Mst Mukhiya Devi is kept out from the Pedigree. And danger is created sticks and
guns came out panic was created in the family and tried to attack on life by the defender. Sticks are sawared at my mother
gun are shown and fired at my family and quarrel reached at high levels. rights of a women and rights of many share
holders were stolen and snatched and now it is said by munsif that sale and purchase was done in a harmony and as per
rule. Imagine this type of harmony.

T.P. Act No- 4 is also not considered and is ignored.

Page 23 of 29
Point No. VII

Frouds in Brief

Important frauds done by Mst Bhola Devi and defender's No 1 to 4

Fraud No. 1 : Bhola Devi did not mentioned the name of Mst Mukhiya in her reply. complete half share is not mention
in her pedigree in the court of munsif but district Judge accepted our given pedigree.

Fraud No.2 : Bhola Devi defender no - 5 did not mention the branch of Parasuram Mishra who is brother of Sadhu
Saran Mishra, and Parasuram Mishra's Sons Shri Sachchidanand Mishra having 1/4 share ie also not shown in the
pedigree submitted by Mst Bhola Devi.

Fraud No. 3: Partition was assumed before 30 years back between Dharmdeo Mishra and Girija Mishra and there share
was assumed 1/2 against the actual share as per pedigree is 1/8.

During committing this fraud it was not thought that Satrughan Mishra and her wife. Smt Mukhiya Devi and
their son Rama Shankar mishra, Parasuram Mishra and his son Sachchidanand Mishra, Who was alive where did they
live ?

It is clear that this assumption is wrong and no any partition was done before 30 years in about 1958.

Fraud No. 4

Only one house no 131 given till the date is prove that any partition was not done, no record was submitted
before the court except verbal statement. While all the revenue record was available and no any record is submitted in the
court. All the record was noted as per pedigree and was present in the name of Mst Mukhiya and Sachchidanand Mishra
and Girija Mishra and Dharamdeo Mishra

Fraud No .5: Biggest fraud is the assumption of partition wall where one straight line was drawn in the map from
north end to south end crossing from the centre of the room of Shri Sachchidanand Mishra. This invisible wall is really a
black magic wall which no one can see.

Fraud No. 6 : Mst Bhola Devi is a oldest and elder lady of my family and known each and every facts and old history of
my family . She knows clearly that Satrughana Mishra and Mukhiya Devi had a son who expired before the death of Mst
Mukhiya . The land was recorded in her name after passing ZA Act . She covered with this curtain of fraud. She did not
show the name of Rama Shankar Mishra Son of Satrughana Mishra and Mst Mukhiya Devi w/o Satrughana Mishra and
Sachidanand Mishra S/o Parshuram Mishra. Its motive was only to prove the fraud of partition assumed 30 years back
and construction of partition wall but actual fact is that light will come out and darkness will go back and real matter was
cleared that neither partition was done nor partition wall was constructed. Also it is clear that Mst Mukhiya Devi got
property from his son Rama Shankar Mishra.

Fraud No . 7: Mst Bhola Devi or defender no 1 to 4 did not given me any notice to us. Without any information to us
she sold the part of our house no 131 which was joint property of all members of my family as explained in my given
pedigree.

Page 24 of 29
Fraud No. 8 - DW 3 Baleshwar Sharma witness was a young man when this case was filed in Munisf Court and assumed
that 30 years back partition was occurred and partition wall was constructed. He is tha evidence of the partition wall
while it is to be thought whether was he born that time or not?

Baleshwar Sharma is the real Brother of Rameshwar Sharma and is the father of Rajesh, Brijesh and Laxmikant he
favours his brother's son's.

Fraud No. 9 - Witness Dahari Mishra was also of 30 about years of age and he says that 30-50 year back partition was
done and partition wall was constructed while that time before 30-50 years he was not born. So the evidence of Dahari
Mishra and Baleshwar Sharma is fake. Some says 30 some 32 and some 50 year back partition was assumed timings are
not confirmed or any documentary proof is not given. It clearly shows that it is an attempt to justify the committed froud.

The fact is that when Mst Mukhiya expired her name was recorded in Revenue record as a share holder of ½
share, Sachchida Nand share ¼ was recorded in revenue record as a ¼ share holder and Dharamdeo Mishra’s share was
1/8 which was recorded in revenue record and Mst Bhola Devi was recorded as a 1/8 share holder Till chakbandi started
the revenue record was remain as stated above.

Point VIII –

Regarding C.O. Order

Revenue Court Order no 79-C-2 has been filed page no 11, point no 20) .

This case is not judged fairly and what ever was done by the Munsif court and District Judge court's same
mistake was committed by C.O. Court and SOC court which appeal is under consideration in DDC Court.

Under this judgment of C.O. and SOC court following errors have been committed.

1- Mst Mukhiya Devi W/o Satrughana Mishra will's judgment was not done as per Hindu succession Act 1956 here
also widow's limited ownership was imposed and widows 1/2 share is distributed between family member Mst
Bhola Devi, Dharamadeo and Sachchidanand Mishra even Paras Nath Mishra also and no Share was given to
Sarweshwar and Rajendra Mishra S/o Dharamdeo Mishra becasue C.O.Court ignored Hindu Succession Act 1956
Act 14 - 1 and ZA Act 1950 ACt 169. Also SOC court followed the path of C O Court.
2- When Mst Mukhiya Devi become full owner in 1956 auto matically she become SIRDAR to Bhumidhar but she
treated as a Sirdar which is illegal.
3- When Mst Mukhiya's will was not accepted in C.O.Court and SOC Court. The whole property (land) was divided
to Sachchidanand Mishra, Dharamdeo Mishra and Bhola Devi and Paras Nath Mishra. As both the court, C.O.
Court and SOC Court accepted the will of Sachchidanand Mishra but its validity was applied only at Bhumidhar
land while she become absolute owner of her all property, Bhumidhary and Sridari both but it was applied only
at Bhumidhari land only and sirdari land was not given to us ie illegle.
4- As per the will of Narsingh Mishra executed on dated 06-06-1947 his elder son Shivanand Mishra was settled for
ever in West Bengal and his share was given in West Bengal against the share of U.P. before 1947 and till the date
his son Parasnath Mishra is living there along with his family but again his son Paras Nath Mishra have been
given the share from the property of U.P. while Supreme Court denies and as per Estoppel decision is wrong
because possession continuity breaks more than 10 years the rule estoppel will apply. I request to look on these
matter and order to provide me relief as maximum as possible.

Page 25 of 29
Judgment should be one for all property for house and land both. If Judgment is given for house only than this
Judgment will be half and again. I have to come in high court for the same judgment for land also while will is
written for whole property and law is made for whole property so judgment should be for whole property, not for
partial property.

In this case it is seen clearly that Hindu Succession Act 1956 which was amended to extend powered and
protection to a Hindu women is openly murdered and Law of 1st purchasing right is also strangulated.

In the end we request and Expect the following relief

1st- Cancell the sale deed and provide degree in my favour.

2nd- Explain Hindu Succession act 1956 in such a way that it cover House and land both the properties. (Moveable and
immovable property as per WILL.)

3rd- Stablish our 1st purchasing right.

4rth- Provide compensation till the date.

5th- As per Narsingh Mishra will Shiva Nane Mishra settled in Malda (West Bengal) foraver so ParasNath Mishra
should not get any right in Uttar Pradesh It should be mention clearly in the judgement.

6th- Mischievous mind composed lie story of partition and partition wall to impose Succession Act 1925 should be
criticize strongly

7th- i) Decide present share of Sarveshwar Mishra 1/4, Rajendra Mishra 1/4 against the will of Smt Mukhiya Devi.

ii) Decide the share of Sachchidanand Mishra S/o Parasuram Mishra 1/4 equal to Sarweshwar, Rajendra and
Brajendra as per will/gift of Sachchidanand Mishra.

iii) Dharamdeo Mishra s/o Narsingh Mishra share is 1/8 decide equally in favour of his son's equally to
Sarweshwar, Rajendra and Brajendra Mishra.

As - Sachchidanand Mishra expire his 1/4 share will be distributed to Sarveshwar, Rajendra and Brajendra Mishra as per
there will.

As - Dharamdev Mishra also expired his 1/8 share will be distributed to , Sarweshwar, Rajendra and Brajendra

As- Bhola Devi defender no 5 also expired so her share will be distributed to Sarweshwar Mishra, Rajendra Mishra and
Brajendra Mishra as per pedigree because these are only successor as per pedigree.

Means 1/8 share will be distributed in 3 parts equally.

So for Sarweshwar Mishra share will be 25% +16.66 % = 41.66% and Rajendra Mishra share will be same as above
i.e. 41.66% and Brajendra Mishra share will be in all moveable and immovable property . 16.66%

41.66+41.67+16.67 = 100%

Main points in Brief:-


Page 26 of 29
I. NARSINGH MISHRA- Executed a will for the family settlement on dated 06-06-1947 before passing Z.A. Act
1950. He settled shri Shiva Nand Mishra Elder Son in West Bengal for aver. Also he gave land in West Bengal
in Mauja-Sankail, Tahsil-Habihpur in Distt Malda West Bengal. Like this Shiva nand and there family went to
West Bengal after getting her share from U.P. and he never came back in U.P.

After 31 years Shiva Nand Mishra’s son – Shri Paras Nath Mishra came in U.P. for a few days and he
recorded his name by illeagle means. Also he kept the property with him which was purchased in the
name of his father against the property of U.P. he got double benefit which case is pending in D.D.C.
court

Munshif court and Distt Juj court did not gave any property to Paras Nath Mishra S/o Shiva
Nand Mishra in U.P.

II. (i) Mst. Mukhiya Devi W/o Satrughna Mishra – Executed a Registered will on Dated 16-
02-1957 in favour of Sarweshwar Mishra and Rajendra Mishra sons of Dharam Deo Mishra. After becoming
full owner in 1956 when Hindu Succession Act 1956 was passed.
(ii) As per Zamidari Abolution Act 1950-52 section 169 she had power to excuate a will or gift or sale
the property because this act does not differenciate between male and female.
(iii) After passing Hindu succession Act 1956 a widow become absolute owner and so her Sirdari right also
became Zamidari right.
(iv) After passing Hindu succession Act 1956 her Limited interest inlarged to full owner.
(v) After proving by district Judge any court will not examine deeply and property will be given as
per will.

III. Sachchida Nand Mishra S/o Parasu Ram Mishra executed a will on Date 02-06-1967 infavour of Sarweshwar
Mishra, Rajendra Mishra and Brajendra Mishra.

C.O. and SOC court given ¼ share to Sarweshwar, Rajendra and Brajendra Mishra as per there Gift deed
and will.

IV. (i) As per will of Mst Mukhiya’s ½ share will be distributedto Sharweshwar Mishra’s Share is ¼ and
Rajendra Mishra’s share is ¼.

(ii) As per will and Gift of Sachchida Nand Mishra’s ¼ share will be distributed to Sarweshwar Mishra ¾
Rajendra Mishra ¾ and Brajendra Mishra’s share 3/8.

V. As Bhola Devi is 1/8 share holder sold more than there share 1/3 share, it will be canceled and her share will be
distributed to Sarweshwar, Rajendra and Brajendra 3/8 to each because Bhola devi is expired and only
Sarweshwar, Rajendra and Brajendra is alive in family.

VI. There are two widows in my family at a same time in same case Ist- Mst Mukhiya Devi w/o Satrughana Mishra
who executed a will in 1957 after passing the Hindu Succession Act 1956, when she become ABSOLUTE owner
and 2nd is Bhola Devi w/o Girija Mishra who got the right to seal the property and in this same case she did not
have any right to will the property.

We are unable to understand that how one widow is rightless and other has full right. How does two
different rules Govern to two widow.
Page 27 of 29
Note –

Hearing Dates 14-02-1920, 04-03-2020 listing last listing Date 04-03-2020,

J.J. Munir Bench No. 5145 (L0P0S0) Last Short order.

Contents Page No.


Point No- 1
1- Issue no 2 , Pedigree No - 1 for U P Only 1
2- Share of family members accepted by District Judge. 2
Point No - 2
3 Widow become full owner 2
4 Enlargement of limited interest to full owner. 3
5 Explanation of Hindu succession Act 1956 4
6 Importance of word WHAT SO EVER 4
7 Importance of Word ABSOLUTE owner and 4
RENDERING the all earlier acts
A. Prooving the WILL of Mst Mukhiya Devi
8 Z.A. Act 1950 Act- 169 give power to a widow for executing will, gift or sale deed.
6

7
9 Seniority schedule of succession ignored. 6
POINT 3
10 Will of Sachchidanand Mishra 7
11 Will is not proved under Indian Evidence Act under section - 60 as per district10judge
court
12 C.O. court order (Revenue Court Order paper No 79/C- 2 has been field (Page11no II
Point No 20)
13 Sachchdidanand Mishra wills accepted by C.O. Court which is not considered12by the
Munsif Court or District Court.
14 Gift deed to Dharamdeo Mishra by Sachchidanand Mishra is separate Khata No 12 50.
15 Clarification of Probate where house no 131 is not mention by clerical /Advocate
13
Mistake.
Point No- 4
16 Explanation about Parass Nath Mishra Branch 17
17 Settlement foraver in West Bengal by Narsingh Mishra to his son Shivanand 18 Mishra.
18 Narsingh Mishra's will as a family satellment to settle Shivanand Mishra for ever in
west Bengal.
19 Explanation about legal heirs of property.
19A. Rulling
Point No- 5
20 False Statement about the share of Shivanand Mishra share surrended to Bhola Devi.
21 Section 4 Partition Act attracted in this case.
PART -2 UNTRUE STATEMENT OF DEFENDANT AND FRAUD 3AND CLEARIY FICATION BY
APPELANT.
22 District Court failed to find out the facts and truth of partition wall line.
23 Unwilling of Black magic of Partition wall.
24 True statement of Bhola Devi by her evidence
25 Haridwar evidence explaination / clearification about partition wall.
26 Stright line was drawing in the fake map.
27 Internal view of Ram Karari Mishra dwelling house by map.
28 Internal rooms map and main persons residing in different rooms.
29 After C.O. and S.O.C. Judgment the case is under DDC court to decide there share and
partition.
30 30 years ago partition and partition wall was assumed to escape from the succession

Page 28 of 29
Act 1956 and to impose succession Act 1925.
31 History of Partition and partition wall composed to impose succession act 1925 which
is illegal.
31A Mst Mukhiya Devi being the wife of Satrughana Mishra got her property from her son
Ramashankar Mishra after his deat
32 Joint sale deed prove that partition was not done and partition wall was not
constructed.
33 Joint sale deed proves that Mst Mukhiya Devi had right to execute a will and gift did or
sale deed already she hade done on dated ----------- is less then 30 years.
34 The use of perhaps prove that judgment of sale deed is based on Assumption.
35 After sale deed of Bhola Devi I kept my proposal to pay back Rs . 900/- according to
my 1st purchasing right.
36 About T.P. Act 41
37 DDC court case is a big proof that process of partition is under process. Till now any
partition is not done.
38 Defender no . 5 Bhola Devi accept in her additional Statement no 10 that Shri Narsingh
Mishra, Parsuram Mishra and Mukhiya Devi lived together in the disputed house.
Point No- 6
39 Issue no 6 Munsif court explanation of the acceptance of our advocate Keep silent.
40 The sale deed is not done as per T P Act 41.
41 Issue No II Munsif court it is wrong to say that Sale deed is written in full harmony
under T.P. Act 41
42 T.P. Act 4 is not considered and ignored.
43 Issue No 8 Munsif court defender No 1 to 4 and 5 involved me in Chakbandi case
which is still waiting since years for its judgment.
44 Additional statement no - 10 of Bhola Devi confirm about joint property and the
persons lived in the dwelling house.
45 Paper No- 79 C - 2 has been field , page no 11 Point no 20 in which Sachchidanand
Mishra wills accepted by C.O. and SOC level and now case is running in DDC level
and his complete share is allotted to Sarveshwar, Rajendra and Brajendra Son's of
Dharmdeo Mishra saprately and we made saprerate share holder.
46 C.O. and SOC decision at the will of Sachchidanand Mishra.
Point No- 7
47 Details of 9 Frauds in this case committed by defender No 1 to 5

Page 29 of 29

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