Amended Plaint

IN THE COURT OF DISTRICT MUNSIF AT POONAMALLE
O.S.No.509 of 2016
1. SAROJA,D/o. Chellapa Achari & W/o. Vairakkannu,

2. LALITHA @LALLIAMMAL (Died on 04.06.2019)
D/o. Chellapa Achari & W/o. Rathinam,
3. K.KOTTEESWARI, D/o.Chellapa Achari & W/o.Kandaswamy,
4. R.Kalyanakumar
S/o. Radhakrishnan
No.7/4, Shankara Madam Street,
Perambur, Chennai-600 011.
5. R.Murugan,
S/o Radhakrishnan,
No.8/32, Shankara Madam Street,
6. Muthulakshmi
W/o.Kalaivanan,
D/o.Radhakrishnan,
No.20A, Venkatachalam Street,
Arcot, Vellore-632 503.
7. Lakshmi
W/o.Ganesan
D/o.Radhakrishnan,
No.44/3, Rangasai Street,
8. Nagaraj
S/o.Radhakrishnan,
Plot No.29, Agathiar Street,
Santhosapuram,
Vengaivasal, Seliyur,
Chennai- 600 073.
9. Venkatesh,
S/o.Radhakrishnan,
No.9/2/39/1, Neelam Garden 3rd Street,
Sembium, Chennai-600 011.
10. Jamuna,
W/o. Kumar,
D/o.Radhakrishnan
No.40, New No.46, Theeti Thottam,
4th Street, Perambur, Chennai-600 011.
11. Sheela,
W/o.Baskar,
D/o.Radhakrishnan,
No.20A, Venkatachalam Street,
Arcot, Vellore-632 503.
4 to 11 son and daughter of late Radhakrishnan & Komalammal
12. K.Manikandan,
S/o.Kumar,
Grandson of late Radhakrishnan & Komalammal,
No.40, New No.46, Theeti Thottam,
4th Street, Perambur, Chennai-600 011.
13. Velu,
S/o.Natarajan,
No.30/26, Thyagarayar Street,
7 wells, Chennai-600 001.
14. Manickam,
S/o.Natarajan,
15. Balaji
S/o.Natarajan,
Grandson of Natarajan & Thangammal,
16. Ananthi,
W/o.Late Suresh
Daughter in law of Thangammal,
17. S.Krishna
S/o.Late Suresh,
18. Brinda,
D/o. Late Suresh,
(Plaintiff 4 to 18 are added as per order of IA.No.449 of 2019)
19. Murugan
S/o. Rathinam
S/o. Smt.Lalitha @Lalliammal
No.291, Kamarajar Street,
Villupuram, Villupuram District 605 602.
20. Ganesan
S/o. Rathinam
No.291, Kamarajar Street,
21. R.Kannan,
S/o. Rathinam
No.11, Pavendar Street,
Sanjai Gandhi Nagar,
Thennansalai, Puducherry 605 013.
22. Balaraman
S/o. Rathinam
No.7, Vandimedu, Old SBI colony,
23. Priya
D/o. Smt.Lalitha @Lalliammal
W/o.Sundaresan
No.1, Middle Street, Nerkunam,
Orukodi, Villupuram District 605 301.
24. Thulli
Daughter in law of Smt.Lalitha @Lalliammal
W/o Muthzhagu,
No.45/54, New Street,
25. Dicana Heman Kumar,

Grandson of Smt.Lalitha @Lalliammal
S/o Muthzhagu,
No.45/54, New Street,
......Plaintiffs
Versus
1. Dhanammal W/o Ettiappan

2. Ettiappan S/o. Sarangan
3. Eggavalliammal W/o. Agambharam(Died)
4. Krishnaveni Ammal W/o. Late Munuswami
5. Chellappan S/o. Late Rathinam(Died)
6. Jayaraman S/o. Late Rathinam
7. Swaminathan S/o. Late Rathinam(Died)
8. Mohan S/o. Munusamy
9. Devi W/o. Janakiraman,
10. Kumar S/o. Munuswamy
11. Sukumar S/o. Munuswamy
12. Vijayakumar S/o. Munuswamy
13. Rajkumar S/o. Munuswamy
14. Krishnamurthy S/o. Munuswamy
15. Govindasamy Naidu S/o. Kuppa Naidu(S.L.B.Bricks) (Died)
16. Gopinath S/o. Chandiran
17. Dhayalan S/o. Chandiarn
18. The Sub Registrar, Poonamalee,
19. K.Ashok Kumar,

S/o.Kanagasabai,
No.1/6, Vijayalakshmi Nagar,
Kolathur, Chennai-600 099.
20. K.Malathi,
D/o. Kanagasapai
W/o.Kalyanakumar,
No.7/4, Sankara Madam Street,
21. R.Mahalakshmi,
D/o.Kanagasabai,
W/o.Ramkumar,
No.16/2, Sundaravinayagar Koil 1st Street,
22. K.Shakila,
D/o.Kanagasabai,
W/o.Kumar,
No.2/134-1, Puzhalendhi Salai,
Mogappair, East, Chennai-600 037.
23. Vijaya,
D/o.Umapathy,
W/o. Radhakrishnan,
No.92, Bharathi Nagar,
Veppampatu, Tiruvallur Distrcit-602 024.
24. Latha,
D/o.Umapathy,
W/o.Tamilarasan,
No.92, Bharathi Nagar,
Veppampatu, Tiruvallur Distrcit-602 024.
......Defendants
(Defendant 19 to 24 are added as per order of IA.No.450 of 2019)
AMENDED PLAINT FILED UNDER SECTION

ORDER VI RULE 17
The Plaintiff above named states as follows:-

(1) The 1st Plaintiff SAROJA, D/o.Chellapa Achari & W/0.Vairakkannu,
Hindu, aged 63 years, residing at No.6, New No.13, Munusamy Street, Perambur,
Chennai, within the Jurisdiction of Small Cause Court, Chennai.
The 2nd Plaintiff LALITHA @ LALLIAMMAL, D/o.Chellappa Achari &
W/o.Rathinam, Hindu, aged 57 years, residing at No.295, Kamarajar Street,
Vilupuram, Pin-605 602, within the Jurisdiction of District Munsif Court,
Vilupuram.
The 3rd Plaintiff K.KOTTESWARI, D/o.Chellapa Achari &
W/o.Kandaswamy, Hindu, aged 60 years, No.8/32, Shankara Madam Street,
Perambur, Pin-600 011, within the Jurisdiction of Small Cause Court, Chennai.
The 4th Plaintiff is R.Kalyanakumar, S/o. Radhakrishnan, Hindu, aged about
57 years, residing at No.7/4, Shankara Madam Street, Perambur, Chennai-600 011.
The 5th Plaintiff is R.Murugan, S/o Radhakrishnan, Hindu, aged about 57
years, residing at No.8/32, Shankara Madam Street, Perambur, Chennai-600 011.
The 6th Plaintiff is Muthulakshmi, W/o.Kalaivanan, D/o.Radhakrishnan,
Hindu, aged about 50 years. residing at No.20A, Venkatachalam Street, Arcot,
Vellore-632 503.
The 7th Plaintiff is Lakshmi, W/o.Ganesan, D/o.Radhakrishnan, Hindu, aged
about 47 years, residing at No.44/3, Rangasai Street, Perambur, Chennai-600 011.
The 8th Plaintiff is R.Nagaraj, S/o.Radhakrishnan, Hindu, aged about 55
years, residing at Plot No.29, Agathiar Street, Santhosapuram, Vengaivasal,
Seliyur, Chennai- 600 073.
The 9th Plaintiff is Venkatesh, S/o.Radhakrishnan, Hindu, aged about 49
years, residing at No.9/2/39/1, Neelam Garden 3 rd Street, Sembium, Chennai-600
011.
The 10th Plaintiff is Jamuna, W/o. Kumar, D/o.Radhakrishnan, Hindu, aged
about 40 years, residing at No.40, New No.46, Theeti Thottam, 4 th Street,
The 11th Plaintiff is Sheela, W/o.Baskar, D/o.Radhakrishnan, Hindu, aged
about 40 years, residing at No.20A, Venkatachalam Street, Arcot, Vellore-632 503.
The 12th Plaintiff is K.Manikandan, S/o.Kumar, Grandson of late
Radhakrishnan & Komalammal, Hindu, aged about 23 years, residing at No.40,
New No.46, Theeti Thottam, 4th Street, Perambur, Chennai-600 011.
The 13th Plaintiff is N.Velu, S/o.Natarajan, Hindu, aged about 48 years,
residing at No.30/26, Thyagarayar Street, 7 wells, Chennai-600 001.
The 14th Plainiff is N.Manickam, S/o.Natarajan, Hindu, aged about 47 years,
The 15th Plaintiff is N.Balaji, S/o.Natarajan, Hindu, aged about 46 years,
The 16th Plaintiff is Anandhi, W/o.Late Suresh, Daughter in law of
Thangammal, Hindu, aged about 46 years, residing at No.30/26, Thyagarayar
Street, 7 wells, Chennai-600 001.
The 17th Plaintiff is S.Krishna, S/o.Late Suresh, Hindu, aged about 20 years,
The 18th Plaintiff is S.Brinda, D/o. Late Suresh, Hindu, aged about 20 years,
The 19th Plaintiff is Murugan, S/o. Rathinam, S/o. Smt.Lalitha
@Lalliammal, Hindu, aged about 51 years, residing at No.291, Kamarajar Street,
The 20th Plaintiff is Ganesan, S/o. Rathinam, S/o. Smt.Lalitha @Lalliammal,
Hindu, aged about 50 years, residing at No.291, Kamarajar Street, Villupuram,
Villupuram District 605 602.
The 21st Plaintiff is R.Kannan, S/o. Rathinam, S/o. Smt.Lalitha
@Lalliammal, Hindu, aged about 47 years, residing at No.11, Pavendar Street,
Sanjai Gandhi Nagar, Thennansalai, Puducherry 605 013.
The 22nd Plaintiff is Balaraman, S/o. Rathinam, S/o. Smt.Lalitha
@Lalliammal, Hindu, aged about 45 years, residing at No.7, Vandimedu, Old SBI
colony, Villupuram, Villupuram District 605 602.
The 23rd Plaintiff is Priya, W/o.Sundaresan, D/o. Smt.Lalitha @Lalliammal,
Hindu, aged about 33 years, residing at No.1, Middle Street, Nerkunam, Orukodi,
Villupuram District 605 301.
The 24th Plaintiff is Thulli, Daughter in law of Smt.Lalitha @Lalliammal,
W/o Muthzhagu, Hindu, aged about 30 years, residing at No.45/54, New Street,
The 25th Plaintiff is Dicana Heman Kumar, Grandson of Smt.Lalitha
@Lalliammal, S/o Muthzhagu, Hindu, aged about 28 years, residing at No.45/54,
New Street, Villupuram, Villupuram District 605 602.
The address for service of all notice and process to the PLAINTIFF is that of
their Counsel M/s.S.JAYACHANDRAN & G.SURESH, at Bar Association(Civil),
Poonamallee, Chennai-600 056
(2) The 1st Defendant DHANAMMAL, W/o.Ettiappan, Hindu, aged 83 years,
residing at No.69. Thirumanam, Village, Sithukadu, Pattabiram, Chennai-600 072,
within the jurisdiction of this Hon’ble Court.
The 2nd Defendant ETTIAPPAN, S/o.Sarangan, Hindu, aged about 92 years,
residing at No.69. Thirumanam, Village, Sithukadu, Pattabiram, Chennai-600 072,
within the jurisdiction of this Hon’ble Court.
The 3rd Defendant EGAVALLIAMMAL, W/o.Agambharam, Hindu, aged
about 79 years, residing at No.14, Thirumanam Village Colony, Pattabiram,
Chennai-600 072, within the jurisdiction of District Munsif Court, Ambatur.
The 4th Defendant KRISHNAVENI AMMAL, W/o.Late Munuswami,

Hindu, aged about 78 years, residing at No.31/11, Sivasankarapuram Street,
M.T.H.Road, Thirumulliavoyal, Chennai-600 062, within the Jurisdiction of
District Munsif Court, Ambattur.
The 5th Defendant is CHELLAPPAN, S/o.Late Rathinam, Hindu, aged about
72 years, residing at No.228, Lakshmi Amman Koil Street, J.J.Nagar,
Annakaducherry, Pattabiram, Chennai-600 072, within the Jurisdiction of his
Hon’ble Court.
The 6th Defendant is JAYARAMAN, S/o.Late Rathinam, Hindu, aged about
63 years, residing at No.248, Thullukanamman Koil Street, Thirumanam, Village,
Sithukadu, Pattabiram, Chennai-600 072, within the Jurisdiction of this Hon’ble
Court.
The 7th Defendant SWAMINATHAN, S/o.Late.Rathinam, Hindu, aged
about 67 years, residing at No.355, Thullukanamman Koil Street, Thirumanam,
Village, Sithukadu, Pattabiram, Chennai-600 072, within the Jurisdiction of this
Hon’ble Court.
The 8th Defendant MOHAN, S/o.Munuswamy, Hindu, aged about 52 years,
residing at Old No.30/1, New No.162, Sivasankarapuram, S.M.Nagar Post,
Thirumullaivoyal, Chennai-600 062, within the jurisdiction of District Munsif
Court, Ambatur.
The 9th Defendant DEVI, W/o.Janakiraman, Hindu, aged about 36 years,
residing at No.6, Vaishnavi Nagar, 8 th Street(Near E.B. Transformer)
Court, Ambatur.
The 10th Defendant KUMAR, S/o.Munusamy, Hindu, aged about 31 years,
residing at Old No.30/1, New No.162, Sivasankarapuram, S.M.Nagar Post,
Court, Ambatur.
The 11th Defendant SUKUMAR, S/o.Munusamy, Hindu, aged about 48
years, residing at Old No.30/1, New No.162, Sivasankarapuram, S.M.Nagar Post,
Court, Ambatur.
The 12th Defendant VIJAYAKUMAR, S/o.Munusamy, Hindu, aged about
46 years, residing at Etiswara Koil Street, Maduravoyal Post, Mel Ayananpakkam,
Chennai-600 095, Maduravoyal Taluk, within jurisdiction of this Hon’ble Court.
The 13th Defendant RAJKUMAR, S/o.Munuswamy, Hindu, aged about 44
years, residing at No.6, Vaishnavi Nagar, 8th Street(Near E.B.Transformer),
Thriumullaivoyal, Chennai-600 062, within the jurisdiction of District Munsif
Court, Ambatur.
The 14th Defendant KRISHNAMURTHY, S/o.Muniswamy, Hindu aged
about 31 years, residing at No.162, S.M.Nagar Post, Sivasankarapuram,
C.T.H.Main Road, Thirumullaivoyal, Chennai-600 062, within the jurisdiction of
District Munsif Court, Ambatur.
The 15th Defendant GOVINDASAMY NAIDU(S.L.B.Bricks) S/o.Kuppa
Naidu, Hindu, aged about 66 years, residing at No.5, Kothiyambakkam, Vellavedu,
Near V.A.O office, Thirumazhisai, Chennai-600 124, within the Jurisdiction of this
Hon’ble Court.
The 16th Defendant GOPINATH, S/o.Chandiran, Hindu, aged about 42
years, residing at No.3/100, Ambedkar Street, Thirumanam Village, Chennai600
072, within the Jurisdiction of this Hon’ble Court.
The 17th Defendant DHAYALAN, S/o.Chandiran, Hindu, aged about 36
years, residing at No.3/100, Ambedkar Street, Thirumanam Village, Chennai600
072, within the Jurisdiction of this Hon’ble Court.
The 18th Defendant SUB REGISTRAR, Poonamallee Village & Taluk,
Chennai-600 056, within the Jurisdiction of this Hon’ble Court.
The 19th Defendant is K.Ashok Kumar, S/o.Kanagasabai, Hindu, aged about
52 years, residing at No.1/6, Vijayalakshmi Nagar, Kolathur, Chennai-600 099.
The 20th Defendant is K.Malathi, D/o. Kanagasapai, W/o.Kalyanakumar,
Hindu, aged about 51 years, residing at No.7/4, Sankara Madam Street, Perambur,
Chennai-600 011.
The 21st Defendant is R.Mahalakshmi, D/o.Kanagasabai, W/o.Ramkumar,
Hindu, aged about 49 years, residing at No.16/2, Sundaravinayagar Koil 1 st Street,
The 22nd Defendant is K.Shakila, D/o.Kanagasabai, W/o.Kumar, Hindu,
aged about 46 years, residing at No.2/134-1, Puzhalendhi Salai, Mogappair, East,
Chennai-600 037.
The 23rd Defendant is Vijaya, D/o.Umapathy, W/o. Radhakrishnan, Hindu,
aged about 44 years, residing at No.92, Bharathi Nagar, Veppampatu, Tiruvallur
Distrcit-602 024.
The 24th Defendant is Latha, D/o.Umapathy, W/o.Tamilarasan, Hindu, aged
about 43, residing at No.92, Bharathi Nagar, Veppampatu, Tiruvallur Distrcit-602
024.
(Defendant 19 to 24 are added as per order of IA.No.450 of 2019)
The address for service on defendants is same as above respectively.
(3) The plaintiffs respectfully submits that the Agricultural Nanja land
comprised in Paimash
No.33 measuring Hectare-0.8.0 Ares
No.88 measuring Hectare-0.14.14 Ares in all measuring Hectare-3.8.12 Ares (New
S.Nos.163/2, 164/7B, 171/3,172/4 in all measuring Ac.4.37 Cents), situated in
sithukkadu village, Poonamallee Taluk, Thiruvallur District was settled by Palani
Achari to and in favour of his Nagammal(2 nd wife of Palani Achari) and Pakkiri
Ammal @ Thanjammal W/o. Chellappa Achari(Daughter of Palani Achari and his
1st wife); vide Settlement Deed, dated 29-04-1951, Doc No.1011/1951, SRO
Poonamallee. As per the covenants of the Settlement Deed, the beneficiary
Nagammal & Pakkiri Ammal @ Thanjammal have got only life interest and
thereafter, the sons and daughters born to Pakkiri Ammal @ Thanjammal shall
obtain absolute interest. Plaintiffs are the daughter born to Chellappa Achari and
Pakkiri Ammal @ Thanjammal, who alone have got absolute right over above said
properties.
(4) The Plaintiffs respectfully submits that contrary to the covenants of the
Settlement Deed; Dhanammal, the 1st Defendant, knowing fully well about the
covenants of the Settlement Deed, Doc.No.1011/1951, illegally Purchased part of
property from Nagammal and others vide Sale Deed, dated 15-07-1959, Doc
No.2019/1959, S.R.O.Poonamallee; in respect of Paimash
No.34,46,88,33,47(extent mention are all wrong). Hence 1st defendant is the
malafide purchaser of bad cause. Hence the above sale deed is “void ab initio” and
does not have any binding effect over Plaintiffs.
(5) The Plaintiffs respectfully submits that Ettiappan the 2 nd Defendant knowing
fully well about the covenants of the Setlement Dedd, Doc No.1011/1951, illegally
purchased part of the Property from Nagammal & Others vide Sale Deed, dated
13-12-1962, Doc No.489/1963, S.R.O.Poonamallee; in respect of Paimash
No.33,47. Hence 2nd Defendant is the malafide purchaser of bad cause. Hence the
Sale Deed is “void ab initio” and does not have any binding effect over the
Plaintiffs.
(6) The Plaintiffs respectfully submits that Egavalli Ammal, the 3 rd Defendant
knowing fully well about the covenants of the Settlement Deed, Doc
No.1011/1951, illegally purchased part of the Property from Dhanammal vide Sale
Deed, dated 17-06-1969, Doc No.1650/1969, S.R.O.Poonamallee; in respect of
S.No.171/3 & 163/2. Hence 3rd defendant is the malafide purchaser of bad cause.
Hence the above sale deed is “void ab initio” and does not have any binding effect
over the Plaintiffs.
(7) The Plaintiffs respectfully submits that Krishnaveni Ammal, the 4 th
Defendant, Knowing fully well about the covenants of the Settlement Deed, Doc
No.1011/1951, illegally got mortgaged/purchased part of the property from
Ettiappan & Dhanammal vide
 Mortgage Deed, dated 25-09-1969, Doc No.2716/1696, S.R.O. Poonamalle
in respect of S.No.163/2
 Sale Deed, dated 02-03-1970, Doc No.506/1970, S.R.O.Poonamallee, in
respect of S.No.163/2, 171/3
 Sale Deed, dated 11-03-1970, Doc No.1443/1970, S.R.O.Poonamallee, in
respect of S.No.171/3, 163/2
 Sale Deed, dated 30.03.1973, Doc No.764/1973, S.R.O.Poonamalee, in
respect of S.No.163/2, 171/3,164/7. Hence 4th defendant is the malafide purchaser
of bad cause. Hence the above mortgage deed, sale deed are “void ab initio” and
does not have any binding effect over the plaintiffs.
(8) The Plaintiffs respectfully submits that Krishnaveni Ammal the 4 th
Defendant, Chellappan the 5th Defendant, Jayaraman the 6th Defendant,
Swaminathan the 7th Defendant knowing fully well about the covenants of the
Settlement Deed, Doc No.1011/1951, have illegally entered into Partition Deed,
dated 27-01-1986, Doc No.2935/1986, SRO Poonamallee, in respect of
S.Nos.163/2, 171/3, 164/7, 172/4. Hence D4 to 7 are the malafide beneficiary of
bad cause. Hence the above partition deed is “void ab initio” and does not have any
binding effect over the plaintiffs.
(9) The plaintiffs respectfully submits that Krishnaveni Ammal the 4 th
Defendant, Mohan the 8th Defendant, Devi the 9th Defendant, Kumar the 10th
Defendant, Sugumar the 11th Defendant, Vijayakumar the 12th Defendant,
Rajkumar the 13th Defendant, Krishnamoorty the 14th Defendant, knowing fully
well about the covenants of Settlement Deed, Doc No.1011/1951, illegally entered
into Settlement Deed, dated 28-08-1990, Doc No. 4932, SRO Poonamallee, in
respect of S.No.163/2,171/6, 172/4 & Settlement Deed, dated 07-09-1990, Doc
No. 5131/1990, SRO Poonamallee, in respect of S.No.164/7B. Hence D8 to 14 are
the malafide beneficiary of bad cause. Hence the above two Settlement Deed are
“void ab initio” and does not have any biding effect over the Plaintiffs.
(10) The Plaintiffs respectfully submits that Govindasamy the 15 th Defedant,
knowing fully well about the covenants of the Settlement Deed, Doc
No.1011/1951, purchased part of the subjective property from Egavalli the 3 rd
Defendant, vide Sale Deed, dated 24-06-1999, Doc No.855/1999, SRO
Poonamallee, in respect of S.No.171/3. Hence 15 th defendant is the malafide
purchaser of bad cause. Hence the above sale deed is “ void ab initio” and does not
have any binding effect over the Plaintiffs.
(11) The Plaintiffs respectfully submits that Gopinath and Dhayalan the 16 th and
17th Defendants, knowing fully well about the covenants of the Settlement Deed,
Doc.No.1011/1951, purchased part of the subjective property from Govindasamy
the 15th defendant, vide sale deed, dated 12-03-2007, Doc No.708/2007, SRO
Poonamallee, in respect of S.No.171/3B. Hence D16,17 are the malafide purchaser
of bad cause. Hence the sale deed is “void ab initio” and does not have any binding
effect over the plaintiffs.
(12) The plaintiffs are in peaceful possession and enjoyment of the subjective
vacant land properties i.e. Agriculture Nanja land comprised in paimash No.33
measuring Hectare-0.8.0 Ares, No.34 measuring Hectare-0.7.6 Ares, No.46
measuring Hectare-0.9.8 Ares, No.47 measuring Hectare-1.1.0 Ares, No.88
measuring Hectare-0.14.14 Ares in all measuring Hectare-3.8.12 Ares (New
S.Nos.163/2, 171/6,172/4). But all of sudden in and after October 2015, defendants
have visited the property in piece meal and illegally tried to trespass into Plaintiffs
property. The Plaintiffs queried about trespass and at that time defendant claimed
right over the property. So the plaintiffs immediately verified encumbrance
certificate and was shocked to find about illegal aforesaid transactions. Then the
plaintiffs gradually gathered all the certified copies of illegal transactions. The
Plaintiffs obtained knowledge about the above illegal transaction only in the month
of October, 2015.
(13) The Plaintiffs further submits that the above illegal deeds, are sham, and
nominal and does not have any binding effect over the plaintiffs.
(14) The plaintiffs further submits that now the defendants 1 to 17 have created
fabricated Deeds, with the malafide intention to deceive the plaintiffs and make out
un just enrichment. If the defendant 1 to 17, succeed in their evil attempts, then the
plaintiffs will be put to irrevocable loss and hardship. The sub registrar,
Poonamalle is added as 18th Defendant for proper adjudication of the proceedings,
to comply with provision laid out under Section 31(2) of Specific Relief Act. The
Plaintiffs 1 to 3 mother’s Pakkiri Ammal @ Thanjammal is no more now.
(15) The cause of action for the suit arouse at Sithukkadu Village, Poonamaalee
Taluk & Firka, Thiruvallur District, October, 2015, when defendants have visited
the property in piece meal and illegally tired to trespass into Plaintiffs Property,
subsequently when the plaintiff verified encumbrance certificate and obtained
certified copies of illegal transactions and subsequently within the jurisdiction of
this Hon’ble Court.
(16) The Plaintiffs values the suit for the purpose of court fee and Jurisdiction as
fololows:
National Value Permanent Injunction Prayer(a) Rs.1000
Court Fee Paid Under Section 27(c) of C.F Act Rs.75.50
National Value Declaration Prayer(b) Rs.1000
Court Fee Paid Under Section 25(d) of TNCFAct Rs.75.50
National Value Declaration Prayer(c) Rs.1000
Court Fee Paid Under Section 25(d) of TNCF.Act Rs.75.50
National Value Declaration Prayer(d) Rs.1000
Court Fee Paid Under Section 25(d) of TNCF Act Rs.75.50
National Value Declaration Prayer(e) Rs.1000
National Value Declaration Prayer(f) Rs.1000
Court Fee Paid Under Section 25(d) of TNFC Act Rs.75.50
National Value Declaration Prayer(g) Rs.1000
National Value Declaration Prayer(h) Rs.1000
National Value Declaration Prayer(i) Rs.1000
National Value Declaration Prayer(j) Rs.1000
National Value Declaration Prayer(k) Rs.1000
National Value Declaration Prayer(l) Rs.1000
National Value Declaration Prayer(m) Rs.1000
National Value of Mandatory Injunction Prayer(n) Rs.1000
Court Fee Paid Under Section 27(c) of C.F Act Rs.75.50
Total Rs.14,000 Rs.1057.00
(17) The Plaintiffs therefore prays for judgment and Decree against the
defendants
(a) For a permanent injunction restraining the defendants 1 to 24 and their agent
any other persons claiming through them from interfering with Plaintiffs rights,
title, interest and possession over the suit property.
(b) Declaring that the sale deed, dated 15-07-1959, Doc No.2019/1959, SRO
Poonamallee as Null and Void ab initio.
(c) Declaring that the sale deed, dated 13-12-1962, Doc No.489/1963, SRO
(d) Declaring that the sale deed, dated 17-06-1969, Doc No.1650/1969, SRO
(e) Declaring the Mortgage deed, dated 25-09-1969, Doc No.2716/1969, SRO
(f) Declaring that the sale deed, dated 02-03-1970, Doc No.506/1970, SRO
Poonamallee as Null and Void ab inito.
(g) Declaring that the sale deed, dated 11.06.1970, Doc No.1443/1970, SRO
(h) Declaring that the sale deed, dated 30-03-1973, Doc No.764/1973, SRO
(i) Declaring the Partition deed, dated 27-01-1986, Doc No.2935/1986, SRO
(j) Declaring that the Settlement deed, dated 28-08-1990, Doc No.4932/1990,
SRO Poonamallee as Null and Void ab initio.
(k) Declaring that the Settlement deed, dated 07-09-1990, Doc No.5131/1990,
SRO Poonamallee as Null and Void ab initio.
(l) Declaring that the sale deed, dated 24-06-1999, Doc No.855/1999, SRO
(m) Declaring that the sale deed, dated 12-03-2007, Doc No.708/2007, SRO
Poonamallee as Null and Void ab initio. Consequently the court shall send a copy
of decree to 18th defendant, as per section 31(2) of Specific Relief Act.
(n) For Mandatory Injunction, directing the 18th Defendant, the Sub Registrar,
Poonamallee to incorporate the above cancellations in the respective book/register.
(o) Impose this suit cost on the defendant
(p) To pass such further relief as this Hon’ble Court deem fit and proper.
Dated: 20th October, 2020
Counsel for Plaintiffs Plaintiffs

VERIFICATION
We, the Plaintiffs above named do hereby declare and state that what are all
stated in the above paragraphs are all rue to the best of our knowledge, information
and belief.

LIST OF DOCUMENTS FILED UNDER ORDER VII RULE 14(1) CPC
S.No. Date Documents
1. 29-04-1951 Certified copy of Settlement Deed, Doc No.1011/1951
2 15-07-1959 Certified copy of Sale Deed, Doc No.2019/1959
5 25-09-1969 Certified copy of Mortgage Deed, Doc No.2716/1969
9 27-01-1986 Certified copy of Partition Deed, Doc No.2935/1986
10 28-08-1990 Certified copy of Settlement Deed, Doc No.4932/1990
11 07-09-1990 Certified copy of Settlement Deed, Doc No.5131/1990
14 Manual Encumbrance Certificated
15 Online Encumbrance Certificates
16 12-11-2016 Legal Notice to Defendants 1 to 17 with Postal
Receipts
17 Returned Covers
18 Online Postal Tracking for served notices
SCHEDULE OF PROPERTY
All that part and parcel of Agricultural Nanja land comprised in Paimash
No.88 measuring Hectare-0.14.14 Ares in all measuring Hectare-3.8.12 Ares (New
S.Nos.163/2, 164/7B, 171/3,172/4 in all measuring Ac.4.37 Cents), situated in
Sithukkadu Village, Poonamallee Taluk, Thiruvallur District.
VERIFICATION
We, the Plaintiffs above named do hereby declare and state that what are all
stated in the above are all rue to the best of our knowledge, information and belief.
MEMO OF VALUATION
National Value Permanent Injunction Prayer(a) Rs.1000
Court Fee Paid Under Section 27(c) of C.F.Act Rs.75.50
National Value Declaration Prayer(b) Rs.1000
Court Fee Paid Under Section 25(d) of TNCFAct Rs.75.50
National Value Declaration Prayer(c) Rs.1000
National Value Declaration Prayer(d) Rs.1000
National Value Declaration Prayer(f) Rs.1000

National Value Declaration Prayer(g) Rs.1000
National Value Declaration Prayer(h) Rs.1000
National Value Declaration Prayer(i) Rs.1000
National Value Declaration Prayer(j) Rs.1000
National Value Declaration Prayer(k) Rs.1000
National Value Declaration Prayer(l) Rs.1000
National Value Declaration Prayer(m) Rs.1000
National Value Mandatory Injunction Prayer(n) Rs.1000
Court Fee Paid Under Section 27(c) of C.FAct Rs.75.50
Total Rs.14,000 Rs.1057.00

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IN THE COURT OF DISTRICT MUNSIF AT POONAMALLE

1. SAROJA,D/o. Chellapa Achari & W/o. Vairakkannu,

25. Dicana Heman Kumar,

1. Dhanammal W/o Ettiappan

19. K.Ashok Kumar,

AMENDED PLAINT FILED UNDER SECTION

The Plaintiff above named states as follows:-

The 4th Defendant KRISHNAVENI AMMAL, W/o.Late Munuswami,

Counsel for Plaintiffs Plaintiffs

Counsel for Plaintiffs Plaintiffs

Court Fee Paid Under Section 25(d) of TNCF Act Rs.75.50

Counsel for Plaintiffs Plaintiffs

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