LIST OF DATES & EVENTS

DATE EVENTS
17.03.200 That the father of plaintiff and defendant died intestate.
1
29.09.201 That the Lt. Smt. Laxmi devi executed a Will under the undue
4
influence of defendants No 1 & 3 in their favour (First will).
20.09.202 Late Laxmi Devi makes a police complaint against their son’s
2
and Daughter in law’s.
06.01.202 The termination of will (First will) was published as Public
3
Notice in Komi Patrika.
06.01.202 That the mother of the plaintiffs executed a will (Second will) in
3
Favor of all his legal heirs for equal division of her estate.
16.02.202 The alleged false, fabricated will (Third will) was executed in
3
favour of Defendants No 1, 2 & 3.
23.02.202 Lt. Smt. Laxmi Devi left for her heavenly abode.
3
24.04.202 That the plaintiffs serve the legal notice to defendants for
3
partitioned the scheduled suit property through their legal
counsel
10.11.2023 That the plaintiffs filed application under O.23 R.3 b of Code of
Civil Procedure to withdrawn the previous suit with liberty to
file fresh suit because of technical defect in the previous suit
05.01.202 Hence the present Suit
4
 SYNOPSIS
That by virtue of the instant suit, the plaintiffs seek from this Hon’ble court a
decree of partition, possession and permanent injunction of immovable
properties (hereinafter referred to as “scheduled suit Property”)

That the parties of the present suit are Plaintiff No 1, Plaintiff No 2 & Plaintiff
No 3 are daughters of Late Laxmi Devi. Defendants No 1 & 3 are sons of late
Laxmi Devi. Defendant No 2 is the wife of Defendant No 1 And Defendant No
4 is the wife of Defendant No 3 and Daughter In law of Late Laxmi devi. That
the Lt. Shivchand was the husband of Lt. Laxmi Devi and father of both
Plaintiffs and defendant, he was the karta of the Hindu Undivided family till his
demise. That the father of plaintiff and defendant died intestate on 17.03.2001.
That after the demise of his husband Lt. Laxmi Devi is looking the estate of his
Husband and became the sole owner of the scheduled suit property for being the
Class-I legal heirs of his husband. That the plaintiff mother being uneducated
lady she was unable to work she depends upon the rent of their Lt. husband
estate in order to take care of his children and for household expenses.

That the Lt. Smt. Laxmi devi executed a Will dated 29.09.2014 under the undue
influence of of defendants No 1 & 3 in their favour latter on Lt. Smt. Laxmi
Devi terminated the said will due to some personal reason. The termination of
will was published as Public Notice in Komi Patrika 06.01.2023. latter on
mother of the plaintiffs executed a will dated 06.01.2023 in Favor of all his
legal heirs for equal division of her estate. That Lt. Laxmi devi left for heavenly
abode on 23.02.2023 after her death will be dated 06.01.2023 came into force
and both plaintiffs and defendants No 1 & 3 are entitled for1/5 th share in the suit
property.

There after the plaintiff made several requests to the defendants to amicably
partition the property by metes and bounds in harmonious atmosphere such that
lawful rights of each of the heirs is well protected but the same was repeatedly
& bluntly refused by the defendants on several occasions so plaintiffs through
his legal counsel sent legal notice for partition of suit property. That the
plaintiffs surprisingly and astonishingly came to know about the another forged
and fabricated will when defendants filed their written statement in the previous
suit which was withdrawn by the plaintiffs after taking due permission form the
Hon’ble court. That the alleged will dated 16.02.2023 is false, fabricated and
obtained in suspicious circumstances by fraudulently by defendants. That the
husband and sons of plaintiff have seen that Defendants No 1 & 3 taking the
thumb impression of deceased Laxmi Devi on blank paper in the cremation
when deceased Laxmi devi was already died and about to be criminated.

There was no need to execute a will dated 16.02.2023 as the similar will was
executed by Late Laxmi Devi in favor of defendant no 1 & 3 which was already
revoked by her. That the alleged will was executed 7 days prior to the death of
Lt. Smt Laxmi Devi i.e., 16.02.2023 in favour of Defendants No 1, 2 & 3. That
the Lt. Laxmi Devi was a bedridden old lady she was suffering from asthma,
she was alive only on oxygen support system she was not in such conditions to
execute the will.