BEFORE THE HONOURABLE MUNSIFF’S COURT, ADOOR

Original Suit No. /2022

BETWEEN
1. Sethu Kumar G
2. Santhosh Kumar G : Plaintiffs
AND
1. Koodal Sree Devi Temple
Administrative Committee
Represented by its President
N. Sudhakaran

2. The Secretary,
Koodal Sreedevi Temple,
Administrative Committee
K. Sasidharan Pillai : Defendants

NAME AND ADDRESS OF THE PLAINTIFFS:

1. Sethukumar G, aged 51 years, S/o Gopalakrishnan Nair, Adersh Bhavan,
Kollanikode, Koodal Village, Koodal P O, Konni Taluk, Pathanamthitta, PIN
689693.
2. Santhosh Kumar G, aged 46 years, S/o Govindhan Nair, Santhosh
Bhavanam, Palloor Thekkekara, Koodal P O, KonniTaluk, Pathanamthita,
PIN 689693.
NAME AND ADDRESS OF THE DEFENDANTS:
1. Koodal Sree Devi Temple Administrative Committee, Represented by its
President N. Sudhakaran, Koodal Sree Devi Temple, Koodal P O, Konni
Taluk, Pathanamthitta District, PIN 689693.
2. The Secretary, Koodal Sree Devi Temple Administrative Committee, K.
Sasidharan Pillai, Koodal Sree Devi Temple, Koodal P O, Konni Taluk,
Pathanamthitta District, PIN 689693.
The address for service of the plaintiffs is on their counsel, K Sreelal and K S
Karunamol, Advocate, Pathanamthitta and that of the defendants are as
follows.
PLAINT FILED UNDER SECTION 26, ORDER VII, RULE I, CIVIL
PROCEDURE CODE, 1908.

Suit for permanent prohibitory Injunction.

1. The plaintiffs are the devotees of the Koodal Sree Devi Temple, which
situates at the Koodal Village, Konni Taluk.
2. The First Defendant is the President and the Second defendant is the
Secretary of the Administrative Committee of the Koodal Sree Devi
Temple who were duly elected.
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3. Even though the defendants term is already expired, they are

continuing in the said posts and discharging the duties as the
President and the Secretary of the Administrative Committee.
4. In respect of the subject matter and relief sought for, there are many
persons having interest that of the plaintiffs and there are many
persons having interest that of the defendants in the subject matter
and relief sought for. There are large number of devotees /persons
who are having interest in the conducting of the festival for the year,
2022 and as such it is practically impossible to implead these
persons who are having interest that of the plaintiffs or that of the
defendants. Hence the suit is being filed in the representative
capacity of the plaintiffs representing those persons having interests
in the plaintiffs. The defendants are also sued as the representatives
of the persons having interest of the defendants. So a separate
petition is being filed to institute the suit in representative capacity.
5. Even though the period of the said Administrative Committee was
over for more than 2 years the election 2 years, the election to the
same is being postponed on the pretext Covid-19 Pandemic.
6. The annual festival of the temple is being celebrated from the
‘Chathayam Naal’ of Kumbham Malayalam month of every year.
Accordingly the said Annual Festival has been conducted by the
temple from time immemorial and has been the custom prevailing
with respect to the conducting of the said Annual Festival.
7. There exists a custom known as ‘Pallivetta’ which is being pertained
on the 6th day of Annual Festival and which is known as ‘Bharani
Mahothsavam’ signifying the ‘Nal’ on which the same is celebrated.
So said ‘Pallivetta’ has been conducted at the ‘Aalthara Mandapam’
which situates at the Kanal Junction of Kolyanikkodu. The said
‘Pallivetta’ is being conducted from time immemorial, as such the
said practice has acquired and developed as a custom.
8. Now it is reliably learnt that the defendants are taking hasty
preparations to change or alter the said predominant custom by
shifting the venue of the ‘Pallivetta’ to a place of their own choice, for
which they have no manner of right. The Festival Notices issued by
the defendants herein, from the year 2019, 2020, 2021 to the
devotees including the plaintiffs are produced; wherein the venue of
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conducting of “Pallivetta’ is shown as “Altharamandapam” at

Kollyanikkode Kanal Junction.
9. As a preclude to accomplish the above said unlawful objects of the
defendants, they have published ‘the Pamlet’ with respect to the
Annual Festival of the said temple without specifying the venue of
the ‘Pallivetta’. The above said apprehended act of the defendants
are per-se illegal and actionable. The Festival Notice issued by the
defendants, wherein the venue of conducting the “Pallivetta” is not
mentioned. None of the defendants or anybody under them have any
manner of right to shift the venue of Palllivetta, unilaterally on their
own whims and fancies.
10. The plaintiffs being the hardcore devotees of Koodal Sree Devi
Temple, they are entitled to get a decree of Permanent Prohibitory
Injunction restraining the defendants or anybody under them from
shifting the venue of ‘Pallivetta’ to be held on 07/03/2022; to any
other place other than the “Altharamandapam” of Kolyanikkode
Kanala Junction. The plaintiff is entitled to for a relief of ad interim
injunction of like nature. Hence the suit.
11. The cause of action for the suit originated on 13/02/2022; the
date on which the plaintiffs have received reliable information that
the defendants are planning to shift the venue of “Pallivetta Festival”
from “Altharamandapam” of Kolyanikkode Kanal Junction. The
plaint schedule property is situated in Koodal Village which is
within the territorial jurisdiction of this Hon’ble Court.
12. For the purpose of court fees and jurisdiction, the suit is valued at
Rs.500/- and for the relief of injunction a court fee of Rs. 20/- is
paid as per Section 27 [c] of the Kerala Court Fees and Suits
Valuation Act. An amount of Rs.100/- is payable under Section 76(2)
of the Act towards the Legal Benefit Fund and the same is also paid
herewith.
13. Therefore, it is most humbly prayed that this Hon'ble Court may be
pleased to pass a decree of Permanent Prohibitory injunction
against the defendants or anybody under them by allowing the
followings:
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RELIEFS
Hence it is most respectfully prayed that the Hon’ble Court may be
pleased to pass a decree of permanent prohibitory injunction in favour
of the plaintiff’s
a) restraining the defendants or their henchmen from shifting the venue
of ‘Pallivetta’ to be held on 07/03/2022 of Koodal Sree Devi Temple,
Koodal; to any other place other than the “Altharamandapam” of
Kolyanikkode Kanala Junction.
b) Award the costs of the suit to the plaintiffs; and such other relief as the
court deems fit and proper.
Dated this day the 25th day of February, 2022.

K Sreelal 1. Sethukumar G
Advocate

2. Santhoshkumar.G
(Plaintiffs)

VERIFICATION
We, 1) Sethukumar.G, aged 51 years, S/o. Gopalakrishnan Nair,
AdershBhavan, Kollanikode, Koodal Village, Koodal P O,Konni Taluk,
PathanamthittaPIN 689693, and 2) Santhosh Kumar G, aged 46 years, S/o.
Govindhan Nair, Santhosh Bhavanam, Palloor Thekkekara, Koodal P O, Konni
Taluk, Pathanamthitta, PIN 689693, do hereby solemnly affirm and declare
that what all stated above are true and correct to the best of my knowledge,
information and belief.

Plaintiffs : 1. Sethukumar G

2. Santhoshkumar G

LIST OF DOCUMENTS
Sl. By whom To whom Description Date of Point
N executed executed of the document s to
o document be
prove
d
1. The The Plaintiffs Festival Plaint
Defendants Notice 2019 Claim
(Original)
2. The The Plaintiffs Festival Plaint
Defendants Notice 2020 Claim
(Original)
3. The The Plaintiffs Festival Plaint
Defendants Notice 2021 Claim
(Original)
4. The The Plaintiffs Festival Plaint
Defendants Notice 2022 Claim
(Original)

K Sreelal
Advocate
 DUPLICATE

BEFORE THE HONOURABLE

MUNSIFF’S COURT, ADOOR

Original Suit No. /2022

BETWEEN

Plaintiffs
1.Sethukumar.G
2. Santhoshkumar.G

AND

Defendants
1. Koodal Sree Devi Temple
Administrative
Committee, Represented
by its President N.
Sudhakaran,

2. The Secretary, Koodal

Sree Devi Temple
Administrative
Committee, K.
Sasidharan Pillai,

PLAINT FILED UNDER

SECTION 26, ORDER VII,
RULE I, CIVIL
PROCEDURE CODE, 1908

As per section 27 (c) of Court fees

and Suit valuation Act
Suit is Valued at : Rs. 500/-
Court fee paid :Rs. 20/-

Legal benefit Fund paid: 100/-

Presented by:

K Sreelal
Advocate
Pathanamthitta