Professional Documents
Culture Documents
..2..
10. Suresh Mahto S/o- Late Loknath Mahto
11. Manoj Mahto S/o- Late Loknath Mahto
12. Prakash Mahto S/o- Late Loknath Mahto
13. Shristi Mahto S/o- Late Loknath Mahto
14. Mithlesh Mahto S/o- Late Loknath Mahto
7 to 14 all by faith-Hindu, by occupation, by occupation-
cultivator R/o Village- Manjhlitand Post- Birni, P.S. – Nawadih
District- Bokaro (Jharkhand).
15. Khedni Devi wife of Baldeo Mahto D/o- Dayal Mahto
Resident of village- Tilayatand, Post- Bhendra,
P.S- Nawadih, District- Bokaro (Jharkhand) – 829144
16. Suchitra Devi W/o- Nandlal Mahto
Resident of Govindpur, Bokaro Thermal, District- Bokaro
(Jharkhand) – 829107
17. Deventi Devi D/o- Late Loknath Mahto, W/o- Baleshwar
Mahto Resident of village- Chaingarha, Barkakana,
District- Ramgarh (Jharkhand) – 829103
18. Radhika Devi D/o- Late Loknath Mahto, W/o- Tarkeshwar
Mahto, Resident of village- Kumardagga, Post- Ramgarh,
District- Ramgarh (Jharkhand) – 829144
19. Rameshwar Mahto Son of Late Thakur Mahto
20. Mohan Mahto Son of Late Govind Mahto
21. Sohan Mahto son of Late Govind Mahto
22. Mahadeo Mahto son of Late Kalicharan Mahto
19 to 22 Resident of Bhedmukka (Dhori) P.S- Bermo, District-
Bokaro (Jharkhand) – 829144
……….. Defendants.
..3..
..4..
..5..
5. That, Karma Kurmi alone sold some land to the Ratan Pal,
Baijnath Saw and Sontobala Devi under Khata No. 83 plot
no. 2479 measuring an area 14 Decimals, 06 Decimals and
04 Decimals respectively of the said village Dhori which
has been fully described item no. II of schedule “B” of the
plaint.
6. That, Karma Kurmi died leaving behind his two sons
namely Punit Mahto and Lalchand Mahto, and two
daughters namely Bhuliya Devi and Laliya Devi who
inherited and succeeded their father Karma Kurmi and they
came in Joint possession of the remaining share of their
decreased father.
..6..
10. That, Laliya Devi also died leaving behind her three sons
namely, Loknath Mahto, Mithlesh Mahto and Dwarika
Mahto and one daughter Khedni Devi who inherited and
succeeded their mother and came in Joint cultivating
possession over the suit land and fully described in
Schedule “A” of this Plaint with other co-sharer without
partition by meets and bounds.
11. That, Churwa Kurmi died leaving behind his five sons
namely, Barhan Mahto, Jailal Mahto (Badhan Mahto),
Govind Mahto, Gujar Mahto and Inder Mahto who
inherited and succeeded their
..7..
father Churwa Kurmi and came in joint cultivating
possession over the entire share of their father with the
other co-sharer over the suit land without partition by meets
and bounds.
12. That, Barhan Mahto and Inder Mahto died issueless and
Jailal Mahto (Badhan Mahto) also died leaving behind his
son namely Khemlal Mahto and three daughter namely
Koshalaya Devi, Ledni Devi and Kalawati Devi who
inherited and succeeded their father Jailal Mahto (Badhan
Mahto), they came in joint possession over the suit land
with other co-sharer without partition by meets and bounds
who are Performa defendants.
13. That, Ledni Devi also died leaving behind her two sons
namely Umesha Mahto and Antu Mahto and two daughters
namely Shanicharya Devi and Geeta Devi who inherited
and succeeded their mother Ledni Devi and came in joint
possession over the suit land with the other co-sharer
without partition by meets and bounds who are Performa
defendants of the suit.
14. That, Govind Mahto died leaving behind his two sons
namely Shyam Sunder Mahto and Khagpat Mahto and a
daughter Asha Devi who inherited and succeeded their
father Govind Mahto and came in joint possession over the
suit land with the other co-sharer without partition by meets
and bounds. It is worth to mention here that Shyamsunder
Mahto
..8..
is an unsound mind thus represented through his only son
Sandeep Kumar who is Performa defendants in the suit.
15. That, Gunja Mahto died leaving behind his two sons
namely Jhari Mahto and Bhim Mahto and a daughter
namely Shanti Devi who inherited and succeeded their
father Gunja Mahto and came in join possession over the
suit land with the other co-sharer without partition by meets
and bounds who are
Performa defendants In this suit. It is also pertinent to
mention here that Bhim Mahto died issuless & aforesaid
descendants of recorded. Tanant have been clarified in
Geonological Table given in foot of this plaint.
16. That, Jhari Mahto also died leaving behind his two sons
namely Gopal Mahto and Binod Mahto and two daughters
namely Sunita Devi and Rekha Devi who inherited and
succeeded their father Jhari Mahto and came in Joint
Possession over the suit land with the other co-sharers
without partition by metes and bounds.
..09..
suit land would not be possible without partition by meets
and bounds.
23. That, the suit is valued at Rs. 50,00,000/- for the purpose of
pecuniary Jurisdiction and court fee since this is a suit for
simple partition, hence the plaintiff paid fixed court fee
thereupon and prays for the institution of the suit.
..10..
iv. Any other relief or relieves for which the plaintiff is entitled in
law and equity be given to the plaintiff.
..11…
Genealogical table
(iii)
Govind Mahto
Sandeep Kumar
..12..
(iv)
Gunja Mahto
(d.iv)
Laliya Devi
Shiva Mahto
Suresh Mahto
Prakash Mahto
Shristi Mahto
SHEDULE “A”
All the lands situated at village- Dhori, Tola- Soutardih, Mauza-
Dhori, Thana No. 68, Pargana – Rampur, District- Hazaribagh at present
District- Bokaro.
Khata No. Plot No. Area in Khata No. Plot No. Area
Acres Acres
Khata No. Plot No. Area in Khata No. Plot No. Area
Acres Acres
SCHEDULE “B”
Item No. 01
All the lands situated at village- Dhori, Tola- Soutardih, Mauza-
Dhori, Thana No. 68, Pargana – Rampur, District- Hazaribagh at present
District- Bokaro.
1761 0.12
1762 0.22
83 1763 0.03
1764 0.33
1765 0.03
1766 0.08
1746 0.03
1747 0.17
1748 0.02
1749 0.08
1750 0.04
83 1752 0.04
1753 0.22
1754 0.23
1755 0.02
..17..
SCHEDULE “B”
Item No. 02
All the lands situated at village- Dhori, Tola- Soutardih, Mauza-
Dhori, Thana No. 68, Pargana – Rampur, District- Hazaribagh at present
District- Bokaro.
VERIFICATION
I, Khagpat Mahto do hereby declare that the statements made
above are true and correct to the best of my knowledge,
Information and belief. I sign this verification at Bermo at
Tenughat on ……………………..
In The Court of Sub-Divisional Magistrate,
Bermo at Tenughat, District- Bokaro
Case No…………/2023
U/S – 144 Cr.P.C.
1. Ram Chandra Gope @ Lala Gope son of Late Prabhu Gope
2. Suresh Gope Son of Late Prabhu Gope
3. Ruplal Gope son of Late Chhatu Gope
4. Rohit Gope Son of Late Chhatu Gope
5. Gouri Gope son of Tili Gope @ Tilu Gope
6. Tulsi Gope Son of Tili Gope @ Tilu Gope
7. Madan Gope Son of Tili Gope @ Tilu Gope
All are by faith- Hindu by occupation- Cultivation Resident of
village- Mahliband, Post- Kathara, P.S- Gomia District- Bokaro
(Jharkhand)
………. Petitioner/1st parties.
Versus
1. Tileshwar Gope son of Late Raghunath Gope
2. Harish Chandra Yadav son of Tileshwar Gope
3. Basudeo Yadav son of Tileshwar Gope
4. Madan Gope son of Tileshwar Gope
5. Ramkrishna Yadav son of Panku Yadav,
All are resident of village- Mahliband, Post- Kathara,
P.S- Gomia District- Bokaro (Jharkhand)
……. Opposite Parties/2nd parties.
..2..
Petition for undertaking 144 Cr.P.C.
The above named petitioners/1st parties
begs to state as follows:-
Most Respectfully Sheweth:-
1. That, the petitioner are peace loving and law abiding citizen of
the state and they are always believe in peace and no committed
no any overt act by the petitioners.
2. That, the 2nd party members are disparate person who have no
regard of law and they have always intention to grab the land
by their muscle power.
3. That, the land in proceeding related of Khata No. 69 Plot No.
923 Area 02 Decimals out of Total area 1.17 Acres (One Acre
Seventeen Decimals) situated at village- Mahlibandh P.S No.
113 P.S- Gomia, District- Bokaro which has been fully
described in Schedule “A” below of this petition has been
recorded in the name of Lumar Gope son of Manbodh Gope
during the last cadastral survey operation.
4. That, the recorded tanent Lumer Gope had valid right title
interest on the entire land of Khata No. 69, Plot No. 923 Area
1.17 Acres.
5. That, after the death of Lumar Gope died leaving behind three
sons namely Prabhu Gope, Chhatu Gope and Tilu Gope.
Prabhu Gope died leaving behind two sons namely
Ramchandra Gope and Suresh Gope. Chhatu Gope died leaving
behind his three sons namely Ruplal Gope, Rohit Gope and
Dharmnath Gope and Tilu Gope died
..3..
leaving behind his three sons Gouri Gope, Tulsi Gope and
Madan Gope they are joint right title interest and possession on
the same.
6. That, in the meantime the landed area 0.54 Acres out of 1.17
Acres under Plot No. 923, Khata No. 69 situated at Mauza-
Mahlibandh, P.S- Gomia District- Bokaro is vested into C.C.L.
under G.M. Kathara.
7. That, it is also place to mention here that in the year 1986
Prabhu Gope, Chhatu Gope and Tilu Gope all son of Lumar
Gope sold and transferred the land in favour of Rajhiya Devi
through the execution of Sale Deed in Khata No. 69, Plot No.
923 area 12 Dc. Under Mauza- Mahliband P.S- Gomia District-
Bokaro (Jharkhand) and the vendee came in possession till her
life time and after the death of Rajhiya Devi her sons Tileshwar
Gope came in possession over the land.
8. That, it is also place to mention here that the sons of Rajhiya
Devi made their home over all the purchased land having area
12 Decimals out of 1.17 Acres in the Plot No. 923 Khata No.
69 of Mauza – Mahlibandh, P.S – Gomia, District – Bokaro and
started living with their family.
9. That, in the meantime all of a sudden on dated. 23.09.2022 1.
Tileshwar Gope son of Late Raghunath Gope 2. Harish
Chandra Yadav, 3. Basudeo Yadav son of Tileshwar Gope 4.
Madan Yadav 5. Ramkrishna Yadav both sons of Punka Yadav
who are second party in this case started digging foundation
over
..4..
Lumar Gope
7. Amount with interest due upon the decree or other relief granted
thereby together with particular of any cross-decree. :- Yes
8. Amount of costs, if any, awarded. :- No.
9. Against whom to be executed.
Against the above named Judgement debtor namely Central
Coalfields Limited & Others.
10. Made in which the assistance of the court required.
Hira Singh Decree Holder pray for recovery of Decreetal amount
of Rs. 2,39,055 which includes cost of suit with an Interest @6%
P.A. of 7 years 4 Months which comes Rs. 1,05,182/- which
comes in total Rs. 3,44,237/- (Rs. Three Lakhs Forty Four
Thousand Two Hundred Thirty Seven Only)
besides other interest till realization of the same be passed
in favor of Decree Holder and against the Judgment Debtor.
That, in case if the judgment debtors failed to pay the said amount
within the period as fixed by the court in that event the court be realize
the same from the Project Officer, C.C.L. Kathara Washery, General
Manager, C.C.L Kathara all Furniture, Vehicle, etc. including the cost
of realization.
Verification
I, Hira Singh do hereby declare that the statements made above in the
affidavit are true and correct to the best of my knowledge, information
and belief. Verified and signed this at Tenughat on 21.12.2022.
In The Court of Principal District &
Sessions Judge, Bokaro
Camp Court, Bermo at Tenughat
A.B.P. No. ……….. /2023
that, the informant will be implicated in false case and as such case
has been lodged by the informant.
5. That, the allegation made in the F.I.R. is totally false and
fabricated.
6. That, no any incident or offence has been done by the petitioners as
alleged in the F.I.R.
7. That, the F.I.R. has been lodged by the informant merely due to
suspicion and the petitioners have no any concern as stated in the
F.I.R.
8. That, all sections are bailable except 379 of I.P.C. and there is no
any recovery from this personal possession of any petitioners.
9. That, there is no specific allegation against this accused petitioners
and there is no any previous criminal history.
10. That, the accused petitioners are local men having house and hearth
and there is no any chance of their absconding.
11. That, the accused petitioners are ready to furnish suitable bailors
for the satisfaction of this court.
12. That, other grounds shall be urged at the time of hearing.
VERIFICATION
I, Jyotilal Manjhi do hereby declare that the statements made
above are true and correct to the best of my knowledge, Information
and belief. I sign this verification at Bermo at Tenughat on
……………...
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AND
1. Jay Prakash Mahto Son of Sri Rameshwar Mahto,
Aged about-38 years, by occupation- Business
2. RAJU KUMAR S/O Sri Rameshwar Mahto, aged about- 28 years,
By occupation Business (Petty Contractor).
3. Koshalya Devi wife of , aged about- years.
All are by Hindu Present Address Vill-Madanpur, P.O.- Kudumba,
P.S- Chandrapura Dist- Bokaro, Jharkhand, Pin-828403
Both Permanent address Vill.- Madanpur, Papalo (Kaluwatand),
P.D.- Tarinari, P.S. Chandrapura, Dist.- Bokaro, Jharkhand Pin-
828403
……….Opposite Parties/Respondents
PETITION FOR MAINTENANCE UNDER SECTION 125 OF
CRIMINAL PROCEEDING CODE
The above named petitioners respectfully
submits as under:-
1. That, the applicants/petitioners are the parents of the
respondents/opposite parties and they are the oldest citizen persons.
2. That, the petitioners submit that:-
(a) The petitioner No.- 01 was an employee of SAIL/Bokaro Steel Plant,
who retired from his service in the year 2018 and petitioner no.- 02 is
the wife of petitioner no. 01 and the mother of the respondents/opposite
parties. They are fully depended upon the respondents/opposite parties.
(c) After retirement, the petitioner No. 01 had received retirement benefit
from SAIL/Bokaro Steel Plant and same has given to
respondents/opposite parties for livelihood, cloth and essential
communities of his family and repayment the loan, who had taken
earlier.
(d) Thereafter respondent no.- 01 has been running whole sale cum retail
grocery business in his village and respondent no.-02 is petty contractor
cum business man.
(e) After same time respondents/opposite parties and their wives have used
filthy language to the petitioners/ applicants but the petitioners had
passed their life anyhow with their family along with the respondents
after thinking that after some time their behavior have been changed
and restored good and cordial relationship.
(f) But their behavior have not changed and respondents along with their
wives have assaulted to the petitioners/applicants after using filthy
language and ousted from the house on 23/09/2020 and since then the
petitioners have passed their life anyhow here and there hence this
application for their maintenance.
(g) Both the petitioners are suffering from several old age diseased like
thyroid, sugar, diabetes, filarial etc.
5. That, the respondents are a person with means and have the following
property monthly and annual income etc.
a. The respondent no.- 01 is businessman and earning monthly more
than of Rs. 70,000.00 (Seventy Thousand) and respondent no. 02 is
petty contractor cum businessman and earning monthly more than
of Rs. 60,000.00 (Sixty Thousand).
b. Agriculture landed property at Village- Madanpur, Papalo
(Kaluwatand) in which respondents earned of Rs. 3,00,000.00
(Three Lakh) per annum.
6. That, it is worth to mention here that the petitioners have earlier filed a
maintenance case before this learned court vide Original
Maintananance Case No. 135/2020 which has been withdrawn by the
petitioner after arriving amicable settle between the Petitioners and
Opposite Parties in local panchayat.
a. That, the local Panchayat of their village has directed the Opposite
Parties to pay a sum of Rs. 2000/- (Two Thousand) each parties but
till today the Opposite Parties didn’t paid any amount of
maintainance to the Petitioners. Hence this necessity of this fresh
maintainance Petition.
7. That, in the circumstances stated above there is no alternative for the
petitioners hence to approach this Hon'ble court for their maintenance.
PRAYER
The petitioners therefore prayed that your honour may be pleased to
pass an order directing the respondents to pay Rs. 30,000.00 (Thirty
Thousand) (Rs.15,000.00 each petitioner) per month towards
maintenance of the petitioners.
Place: Bokaro
Date:
AFFIDAVIT
2. That, the contents of the instant petition has been read over and
explained me in my vernacular. Which I understood the same and
found correct.
VERIFICATION
The statements made above are true & correct, I signed this verification
here at BS. City on 24/11/2020.
In The Court of Civil Judge, Sr. Division – II,
Bermo at Tenughat
Misc. Case No. 19/2018
Sukhdeo Ghansi …………… Petitioner
Versus
Idrish Miyan & others ………….. Opposite parties.
The humble show cause on behalf of
the Opposite Party No. 4 & 5 is as
follows:-
1. That, the aforemention Misc. Case brought by the
Petitioners/Plaintiff is maintainable and the same is fit to be
allowed.
2. That, the present Misc. Case has been filed by the Petitioner with
the period of limitation.
3. That, the statements made in para 1, 2, 7 of the petition are true
and correct and hereby admitted by the answering in toto.
4. That, it is true and correct that the petitioner had feel ill and as a
result of which he remained in medical treatment since 05.01.2018
to 13.08.2018 and when he recovered from his illness he came at
Tenughat on 14.08.2018 and met his conducting lawyer and come
to know that his Misc. Case No. 03/2013 has been dismissed on
default on 12.01.2018.
5. That, there after the petitioner obtained the certified copy of order
dated. 10.01.2018 and filed present Misc. Case to restore this
Misc. Case No. 03/2013 in Title Original file number.
..2..
VERIFICATION
I, Dasai Ghansi do hereby declare that the statements made
above are true and correct to the best of my knowledge,
Information and belief. I sign this verification at Bermo at
Tenughat on ……………………..
In The Court of A.C.J.M.,
Bermo at Tenughat
State
Versus
Chamu Manjhi & Others ……………….. Accused.
U/S 147, 149, 447, 427, 379, 504 & 506 of I.P.C.
follows:-
..2…
1. That, in the aforesaid case the above named petitioners have been
2. That, the petitioners are ready to abide the condition as laid down
3. That, the petitioners are ready to furnish bail bonds to the best
And for this act of kindness accused petitioners shall ever pray.
Dated:- 03.03.2023.
In The Court of A.C.J.M.,
Bermo at Tenughat
State
Versus
Chamu Manjhi & Others ……………….. Accused.
U/S 147, 149, 447, 427, 379, 504 & 506 of I.P.C.
VERIFICATION
I, Pradeep Kumar Verma do hereby declare that the statements
made above are true and correct to the best of my knowledge,
Information and belief. I sign this verification at Bokaro on
……………...
In The Court of Munsif,
Bermo at Tenughat
VERIFICATION
I, Sunil Kumar Jain do hereby declare that the statements made above are
true and correct to the best of my knowledge, Information and belief. I sign
this verification at Bermo at Tenughat on 03.03.2023.
IN THE COURT OF CIVIL JUDGE SENIOR DIVISION- I
1. That, the suit land under Khata no. 83 measuring an area 25.88 Acres under various (67) Plots situated at village- Dhori, P.S-
Bermo District- Bokaro which has been fully described in schedule “A” of the plaint has been recorded in the name of Jodhwa
son of Uttma Kurmi, one share Tekwa son of Khemna kurmi, one share, Karma and Churwa son of Gunawa Kurmi one share
during the last cadastral survey operation.
2. That, the recorded tenant Jodhwa and Tekwa being an issueless given their entire share of the land fully described in Schedule
“A” of the plaint to the Churwa Kurmi during their lifetime and they put the Churwa kurmi in Khas possession over their share
and executed an Unregistered Deed of Gift in favour of the Churwa Kurmi on 15.03.1926 for the land measuring an Area 17.11
Acres which is the part and partial of the suit land.
3. That, thereafter Jodhwa Kurmi and Tekwa Kurmi died issueless. Churwa kurmi remain in cultivating possession over the share
of Jodhwa and Tekwa Kurmi along with his own share.
4. That, Karma Kurmi and Churwa Kurmi jointly sold part and partial of the land fully described in schedule “A” of the plaint to
one Lalman Mahto which has been morefully decribed in item no. I of the Schedule “B” of the plaint.
5. That, Karma Kurmi alone sold some land to the Ratan Pal, Baijnath Saw and Sontobala Devi under Khata No. 83 plot no. 2479
measuring an area 14 Decimals, 06 Decimals and 04 Decimals respectively of the said village Dhori which has been fully
described item no. II of schedule “B” of the plaint.
6. That, Karma Kurmi died leaving behind his two sons namely Punit Mahto and Lalchand Mahto, and two daughters namely
Bhuliya Devi and Laliya Devi who inherited and succeeded their father Karma Kurmi and they came in Joint possession of the
remaining share of their decreased father.
7. That, Punit Mahto also died leaving behind his widow Piyari Devi who inherited and succeeded her husband without partition by
meets and bounds and Lalchand Mahto died issueless.
8. That, Bhuliya Devi died leaving behind two sons namely Somar Mahto and Dilu Mahto and a daughter Lalita Devi who has
inherited and succeeded their father and came in Joint Possession over the share of his father without partition by meets and
bounds who is defendants.
9. That, Dilu Mahto also died leaving behind two sons namely, Dinu Mahto and Teklal Mahto who inherited and succeeded their
father and came in Joint possession over the share of Dinu Mahto without Partition by meets and bounds who are defendants of
suit.
10. That, Laliya Devi also died leaving behind her three sons namely, Loknath Mahto, Mithlesh Mahto and Dwarika Mahto and one
daughter Khedni Devi who inherited and succeeded their mother and came in Joint cultivating possession over the suit land and
fully described in Schedule “A” of this Plaint with other co-sharer without partition by meets and bounds. Loknath Mahto also
died leaving behind his six sons and three daughters who are defendant No. 9 to 14 and 16 to 18.
11. That, Churwa Kurmi died leaving behind his five sons namely, Barhan Mahto, Jailal Mahto (Badhan Mahto), Govind Mahto,
Gujar Mahto and Inder Mahto who inherited and succeeded their father Churwa Kurmi and came in joint cultivating possession
over the entire share of their father with the other co-sharer over the suit land without partition by meets and bounds.
12. That, Barhan Mahto and Inder Mahto died issueless and Jailal Mahto (Badhan Mahto) also died leaving behind his son namely
Khemlal Mahto and three daughter namely Koshalaya Devi, Ledni Devi and Kalawati Devi who inherited and succeeded their
father Jailal Mahto (Badhan Mahto), they came in joint possession over the suit land with other co-sharer without partition by
meets and bounds who are Performa defendants.
13. That, Ledni Devi also died leaving behind her two sons namely Umesha Mahto and Antu Mahto and two daughters namely
Shanicharya Devi and Geeta Devi who inherited and succeeded their mother Ledni Devi and came in joint possession over the
suit land with the other co-sharer without partition by meets and bounds who are Performa defendants of the suit.
14. That, Govind Mahto died leaving behind his two sons namely Shyam Sunder Mahto and Khagpat Mahto and a daughter Asha
Devi who inherited and succeeded their father Govind Mahto and came in joint possession over the suit land with the other co-
sharer without partition by meets and bounds. It is worth to mention here that Shyamsunder Mahto is an unsound mind thus
represented through his only son Sandeep Kumar who is Performa defendants in the suit.
15. That, Gunja Mahto died leaving behind his two sons namely Jhari Mahto and Bhim Mahto and a daughter namely Shanti Devi
who inherited and succeeded their father Gunja Mahto and came in join possession over the suit land with the other co-sharer
without partition by meets and bounds who are
Performa defendants In this suit. It is also pertinent to mention here that Bhim Mahto died issuless & aforesaid descendants of
recorded. Tanant have been clarified in Geonological Table given in foot of this plaint.
16. That, Jhari Mahto also died leaving behind his two sons namely Gopal Mahto and Binod Mahto and two daughters namely
Sunita Devi and Rekha Devi who inherited and succeeded their father Jhari Mahto and came in Joint Possession over the suit
land with the other co-sharers without partition by metes and bounds.
17. That, the plaintiff, defendants and performa defendants are Hindu and they governed by the Mitakchara School of Hindu Law.
18. That, the plaintiff, defendants and Performa defendants are in joint possession over the suit land as per their convenience without
partition by meets and bounds. It is pertinent to mention here that the modification and improvement of the suit land would not
be possible without partition by meets and bounds.
19. That, therefore the plaintiff and Performa defendants demanded the partition of the suit land but the defendants all the time put
off the matter on some the other pretext.
20. That, finally on 05.01.2023, the plaintiff made and approach to the defendants and requested them to make partition of the
suit land by meets and bounds but the defendants totally refused to do so hence the necessity of the suit.
21. That, the plaintiff, Performa defendant and defendants have got unity of title, community of interest in the suit land.
22. That, the plaintiff and Performa defendants are entitled to get 5/6 th share in the suit land fully described in schedule “A” of the
plaint.
23. That, the suit is valued at Rs. 50,00,000/- for the purpose of pecuniary Jurisdiction and court fee since this is a suit for simple
partition, hence the plaintiff paid fixed court fee thereupon and prays for the institution of the suit.
24. That, the cause of action arose on 05.01.2023 when the defendants refused to make partition of the suit land by meets and
bounds and thereafter day to day at village- Dhori, P.s.- Bermo, dist., Bokaro within the territorial jurisdiction of the learned
court.
ii. A survey knowing leader commissioner be appointed to curve out the share of the plaintiffs and Performa defendant from
the suit land and accordingly a permanent decree be prepared in favor of the plaintiff and the Performa defendants be put
in khas possession over their takhta through the process of the court.
iv. Any other relief or relieves for which the plaintiff is entitled in law and equity be given to the plaintiff.
(iii)
Govind Mahto
(iv)
Gunja Mahto
(d)
Karma Kurmi
Shiva Mahto
Suresh Mahto
Prakash Mahto
Shristi Mahto
Khata No. Plot No. Area in Khata No. Plot No. Area in
Acres Acres
VERIFICATION
I, Khagpat Mahto do hereby declare that the statements made
above are true and correct to the best of my knowledge,
Information and belief. I sign this verification at Bermo at
Tenughat on ……………………..