BEFORE THE HONORABLE DISTRICT COURT, JAIPUR,

RAJASTHAN

RAM SINGH
(PLAINTIFF)

V.

MANGAL SINGH AND ORS.

(DEFENDANT)

PLAINT ON BEHALF OF THE PLAINTIFF

SUBMITTED TO: SUBMITTED BY:

Mr. Sheikh Inam UI Mansoor AVIK RAJORIYA
ASSOCIATE PROFESSOR B.B.A.,LL.B
(5th Semester)

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 Before Honourable District Court, Jaipur

Rajasthan

1. Ram Singh S/O Bigram Singh

R/O ABC, Kho-Nagorian, District Jaipur.

--Plaintiff

Versus

1. Mangal Singh S/O Abc Singh

R/O ABC, Kho-Nagorian, District Jaipur.

2. Zeher Singh S/O Kehar Singh

R/O Indira Nagar, Jagatpora, District Jaipur.

3. Sheer Singh s/o Darbar Singh

R/O Pratapnagar, District Jaipur.

4. District Collector DO(R), Jaipur.

5. Sub Registrar (Rural), Jaipur.

6. Tehsildar, Tehsil and District Jaipur.

7. Halqa Patwari, Kho-Nagorian, Tehsil and District Jaipur.

--Defendant

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 PLAINT UNDER ORDER VII

Code of Civil Procedure, 1908

Respected,

The Plaintiff humbly states as under that-

1. The plaintiff inherited his entire estate/property from his farther Bigram Singh situated at

Kho-Nagorian, Jaipur consisting of landed property falling under different survey No’s.

54 (1 Bigha), survey No.55 (3 Bighas), survey No. 56 (2 Bighas) and survey No. 598 (1

Bigha) in total 7 Bighas in addition of other landed property as per the revenue Record).

2. The defendant no.1 has sold the brick kiln at village Kho-Nagorian, Jaipur to defendant

no.2.

3. The brick kiln was operated by the defendant no.1 in the name and style of Mangal Brick

Kiln in the vicinity of plaintiff. The above referred landed estate of plaintiff measuring 7

Bighas falling under above referred survey numbers situated at village Kho-Nagorian,

Jaipur had been taken by the defendant no.1 on lease for five years from 2016 for the

smooth functioning of brick kiln.

4. The lease agreement continued up to 2021 when defendant no.2 purchased the said Brick

Kiln back from the defendant no.1, and started its operation in the new name and style as

zehar Brick Killen at Kho-Nagorian, Jaipur.

5. The defendant no.2 sold his Brick Kiln to defendant no.3.

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6. The plaintiff above referred landed estate had thus continued to be under lease with the

said new owner of the brick Kiln i.e. defendant no.3 therefore the plaintiff after 2021

used to take rentals of the said land from defendant no.3.

7. The defendant no.1 at the time when he sold the brick kiln revealed that the entire land of

Plaintiff above referred had been mutated in his favor vide mutation order No’s. 844 and

846 of village Kho-Nagorian, Jaipur on the basis of alleged Oral Gift.

8. The defendant no.1 once had taken the plaintiff before Patwari Halqa and the plaintiff

was asked to affix his hand on some papers under this assertion that it related to lease of

his land above referred in favor of defendant no.1 for operating of Brick kiln.

9. That the fake and false entry based on alleged oral gift surfaced for the first time when

defendant no.1. had sold his brick kiln to defendant no.2.

10. The intervention of respectable persons including some members brick kiln union were

sought and it was amicably decided that the plaintiff would pay back the money

advanced minus amount of rent due from defendant no.1 till then and thus it was

calculated at Rs. 2,57,000/= payable towards defendant no.1 which off course plaintiff

paid in terms of cash and cheque towards defendant no.1.

11. The defendant no.1 was under obligation to get ratified the revenue record in favor of

Plaintiff restoring the original position and instead with passage of time, defendant No.1

had taken recourse to dilatory tactics.

12. That this property is situated within the territorial limits of this Honorable Court, cause

of action also accrued here, this court has the jurisdiction to try this case.

13. The plaintiff is ready to affix the appropriate court fees.

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14. That the present suit being filed by the plaintiffs against the defendant is the first suit and

no such suit has been previously filed, pending or decided by any court of law on the

same subject matter.

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Prayer:

It is, therefore most respectfuly

prayed that this Honorable Court may be pleased to:

1. A decree for declaration in a suit for cancellation of gift deed

2. Any other relief, which this Honorable Court deems fit which may be granted to the

defendant no.1.

Plaintiff

Verification

I, Ram Singh, the plaintiff above named do hereby verify that the contents of this plaint from

paragraph 1 to 11 are true and correct to my personal knowledge and paragraphs 12 to 14 are

believed to be true and correct according to the legal advice received to me.

Plaintiff