BEFORE THE III ASSISTANT CITY CIVIL COURT AT CHENNAI

O.S. No. 5577 of 2021

1. Prema W/o V. Chandran,

No. 156/7, Washer Varadappa Street,
New Washermenpet, Chennai - 600 081

2. Ganesh Kumar S/o V. Chandran,

No. 156/7, Washer Varadappa Street,
New Washermenpet, Chennai - 600 081

3. Priyadarshini D/o V. Chandran,

No. 156/7, Washer Varadappa Street,
New Washermenpet, Chennai - 600 081

4. Balaji S/o V. Chandran,

No. 156/7, Washer Varadappa Street,
New Washermenpet, Chennai - 600 081

5. Deepan Suresh Kumar S/o V. Chandran,

No. 1, G Block, Muthamizh Nagar,
Tondiarpet, Chennai 600 081
…Plaintiffs
-Vs-

The Tahsildar,
Rettai Kuzhi Street, Tondiarpet,
Chennai 600 081
…Respondent

PROOF AFFIDAVIT FILED GANESH

I, the second plaintiff named Ganesh son of V. Chandran aged about 38 years residing at No

156/7, Washer Varadappa Street, New Washermenpet, Chennai 600081, do hereby solemnly

affirm, submit and state as follows:

1. I submit this affidavit on behalf of other plaintiffs in the above case and as such I am
well acquainted with the facts of the case.
2. I state that the plaintiffs are the legal heirs of the deceased late Mr.V.Chandran S/o
P.R.Venugopal, who died on 8th September 2018. I state that the first plaintiff is the
wife of late Mr.V.Chandran, the second, third and fourth plaintiffs are the sons and
daughter of the first plaintiff and the deceased late Mr.V.Chandran, and the fifth
plaintiff is a son of late V.Chandran and his second wife Mrs.Helen. The said
Mrs.Helen is not impleaded as a party in the present suit since she is not a legal heir of
late Mr.V.Chandran and hence she is not a necessary party to the present suit.

3. I further state that I are in view of getting legal heir certificate for the deceased Mr. V.
Chandran, approached the E-Sevai Center and made a request on 15 th March 2019 via
application number TN7201903152094 by duly enclosing the death certificate of
Plaintiffs’ Husband. I further states that the application number TN7201903152094 has
been rejected for the reason that the deceased Mr.V.Chandran has two wives namely the
first plaintiff and Mrs.Helen respectively.

4. I state that all the plaintiffs are the class I legal heirs of the deceased Mr.V.Chandran
and accordingly the defendant ought to issue legal heir certificate for declaring the
plaintiffs as the lawful legal heirs of the deceased Mr.V.Chandran.

5. I state that there is an internal circular stipulating orders from civil court to obtain legal
heirship certificate in such matters, which has rejected the application, for the reason of
having two wives by the deceased Mr.V.Chandran, and for that I state that 2 nd, 3rd and
4th Plaintiff are the children of mine, born out of wedlock with the deceased
Mr.V.Chandran, and the 5th Plaintiff is the son of the 2 nd Wife of the deceased
Mr.V.Chandran.

6. I state that the marriage between the deceased Mr.V.Chandran and the 1 st Plaintiff was
solemnised on April 26, 1982, at Meenakshi Kalyana Mandapam, Avadi, Madras
600054, and out of the wedlock the 2 nd Plaintiff was born on September 10, 1983, later
the 3rd Plaintiff was born on March 11, 1985, and the 4 th Plaintiff was born on October
02, 1986.

7. I submit that the deceased Mr.V.Chandran had a second wife named Mrs.Helen without
lawful marriage, and out of their relationship, the 5 th Plaintiff Mr.Deepan Suresh Kumar
was born on April 11, 1991, as on the above said, I am constrained to file the suit before
this hon’ble court for declaring the plaintiffs as legal heirs of the late Mr.V.Chandran.
 8. Therefore in the above circumstances, I prayed that this Hon’ble Court may be pleased
to pass a judgement and decree declaring the plaintiffs as the legal heirs of the deceased
Mr.V.Chandran and a consequential injunction directing the defendant to issue a legal
heirship certificate in favour of the plaintiffs and pass such further order or orders in
deem fit and proper circumstances of case and thus render justice.

Solemnly affirmed and signed Before me

at Chennai on this 23rd day of December 2022

Advocate

List of Documents

S. No Date Description of documents Remarks

1 26.04.1982 Marriage Invitation of First Original
Plaintiff
2 26.04.1982 Marriage Photo Original

Counsel for Plaintiff Plaintiff

 BEFORE THE HONBLE
COURT OF CITY CIVIL
JUDGE
O.S.NO. 5577 OF 2021

Prema W/o V.Chandran

& Others

…Plaintiffs

Vs.

The Tahsildar,
Tondiarpet, Chennai

…Defendant

PROOF AFFIDAVIT
FILED BY PLAINTIFF

Karthik Eswaran J
Counsel for Plaintiffs
No.86,First Floor,
South West Boag Road,
T.Nagar, Chennai
600017.