0% found this document useful (0 votes)
13 views14 pages

Bs

The document is a legal plaint filed by Suresh against M Ningegowda in the Senior Civil Court at T Narasipura, seeking a declaration of ownership and permanent injunction regarding a property claimed to be fraudulently taken by the defendant. The plaintiff asserts that he has been in possession of the property since his mother's death and that the defendant has unlawfully attempted to interfere with his ownership. The plaint includes various applications for court orders and details the history of the property and the plaintiff's grievances against the defendant.
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF or read online on Scribd
0% found this document useful (0 votes)
13 views14 pages

Bs

The document is a legal plaint filed by Suresh against M Ningegowda in the Senior Civil Court at T Narasipura, seeking a declaration of ownership and permanent injunction regarding a property claimed to be fraudulently taken by the defendant. The plaintiff asserts that he has been in possession of the property since his mother's death and that the defendant has unlawfully attempted to interfere with his ownership. The plaint includes various applications for court orders and details the history of the property and the plaintiff's grievances against the defendant.
Copyright
© All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF or read online on Scribd
ise TITLE SHEET IN THE COURT OF THE SENIOR CIVIL JUDGE AND JMFC AT T NARASIPURA O.8.No___/ 2025 Plaintiff —: Suresh -v/s- Defendant : M Ningegowda INDEX SLNo. Description Pages Plaint under Order.7 Rule.1 of CPC Verifying Amfidavit Valuation slip APPLICATION UNDER ORDER VI RULE 14-A OF THE CPC APPLICATION UNDER ORDER 39 RULE 1 AND 2 OF C.P.c Vakalath List with Documents. ‘One set copy of Plaint, Verifying Affidavit, and Application in Green sheet to Court. List with Xerox copies of Documents Process memo 6 set copy of Plaint, Verifying Affidavit, Valuation slip, IA’s to the Defendant. Advocate for Plaintiff Vinayakumar P, advocate Arya’s Law Associate’s, No 105/1, Krishna Complex, Bangalore -560044, MOB- 9986857597, Mail- vinayarya1884@[Link] 12" main Road,6"BlockRajajinagar, IN THE COURT OF THE SENIOR CIVIL JUDGE AND JMFC AT T NARASIPURA ©.8.No___/ 2025 Between Suresh S/o Late Eshwarachari, Aged about 58 years, R/at No.37, Nuggahalli Koppalu Village, Bannur Hobli, T Narasipura Taluk-571101 Plaintiff AND M Ningegowda S/o Late Manchegowda Aged about 62 years, Nuggahalli Koppalu Village, Bannur Hobli, T Narasipura Taluk-571101 Defendant PLAINT UNDER ORDER VII RULE 1 OF C. The Plaintiff beg to state as follows:- 1. The address of the Plaintiff for the purpose of service of notices, Processes etc, from this Hon'ble court is as shot the cause title and the Plaintiff may also be served her counsel Sri Vinaya Kumar P, Renuka H A advocat at no 105/1, Krishna Complex, 12% Main Road, Rajajinagara,Bangalore- 560044, Mob-9986857; Vinayarya1884@[Link] 2. It is submitted that the Plaint schedule pri Plaintiff mother by name Late K Eshwarachari has acquired allotment(Grant) on 30.10.1978 and ee “Sie by Hegguru Grama Panchayath in assessment No.37, Janjar No.836, measuring east by west 40 feet north by south 60 feet situated at Nuggahalli Koppallu Village, Bannur Hobli, T Narasipura Taluk and plaintiff is belongs to Hindhu Vishwakarma Cast and after issuing grant certificate the Khata has changed in the name of the plaintiff Mother and till date khata is stand in the name of the plaintiff mother and plaintiff mother has died on 16,08.2012 And after the death of plaintiff mother plaintiff only possession and enjoyment of the suit schedule property till today. 3. Itis submitted that, the defendant was member of the Heggur Panchayath in that time the defendant as fraudulently created Janjar No.461, assessment No.37 in to his name after obtaining the khata the defendant has started harassment to the plaintiff mother as during the life time of the plaintiff mother he has given the several applications to cancel the Janjar No.461, assessment No.37 from 17.07.2009 to till death of the plaintiff mother. 4. After the death of the plaintiff mother plaintiff has given a several applications to concerned authorities but they are not taken the any auction against the to defendant. And on 23.05.2002 the defendant have illegally trespass the plaintiff schedule property and he has man handling the plaintiff as such he has given the police complaint against to the defendant and also again the defendant illegally trespass the Suit schedule property and cut the trees in the plaintiff schedule property as such complainant has given the complaint to the Bannur police station on 05.06.2023 but they have not take any auction against to the defendant. 5. Further plaintiff submits that, on 10/07/2028 the plaintiff and Nagarika Hakku Rakshna Samithi member are made a = ai the au Panchayath, Mysore and after that vyath has issued a direction to Nudel office to Given Mahazer report and after that Villa Panchayath has > j ie ff to approach EO office to after that directed to the plaintil T Narasipura plaintiff has fled a Appeal before the / Panchayath court against to the defendant in Appeal No.12/2024-2025 after hearing the ‘both the parties the Hon'ble court has rafter to Civil court: is submitted that, absolutely the defendants have no 6. It is t what’ so ever over the manner of right, title or interes! schedule property . In spite of it the defendants is trying to kmock off the schedule property and they are trying to interfere with the peaceful possession they having no right over the schedule property. Therefore they are trying to interfere with the plaintiff peaceful possession and enjoyment of plaint schedule property and also they are trying to sell the property to other persons. 7. It is submitted that the cause of action arose when defendant has fraudulently obtained the kahata and on 17.07.2009 when plaintiff mother has given the compliant and on 18.09.2025 when Hon'ble tribunal has dismiss the petition also about 7 days back i.e. on 01/11/2025 the defendants along with their henchmen have tried to interfere with the schedule property. 8. The plaintiff submits that he is helpless and having no supporters in the locality but the defendants are very powerful person and they are having both money and political influence behind their back and they are not believe in law. ‘As such his said attitude cannot be resisted without the order of this Hon’ble Court. Hence without any alternative the Plaintiff has approached this Hon'ble Court Hence itis a suit for Declaration and permanent injunction. yy -4- No.836, ent No.37, Janjar , 9. The schedule property assess™m: : | measuring east by west 40 feet north by south se es situated at No.37 Nuggahalli Koppallu Village, ee lobli, 7 Narasipura Taluk within the jurisdiction of this Hon'ble Court. 10. The suit is valued both for the purpose of court fee and jurisdiction at Rs. /- under Section 26(C) of Karnataka Court fee and suit valuation Act and hence court fee of Rs /- is deposited. A separate valuation slip is also filed. PRAYER The plaintiff therefore humbly prays that this Hon'ble Court be pleased to pass judgment and decree in his favor and against the defendants for Declaration by declaring the Plaintiff are only the owner of the scheduled property 1. By declaring the null and void of Janjar No.461, assessment No.37 situated the Nuggahalli Koppallu Village, Bannur Hobli, T Narasipura Taluk. 2. By declaring the plaintiff the absolute owner of the suit schedule property 3. By directing the Heggur Grampanchayath to change Khata in to plaintiff Name. 4 And also Permanent injunction, restraining the defendants from retraining the defendants by an order of permanent injunction And granting cost and such other relief as this Hon’ble Court deems fit to grant in the circumstances of the case 5. in the interest of justice an equity SCHEDULE PROPERTY All the piece and Parcel of the property assessment No.37, Janjar No.836, measuring east by west 40 feet north by south 60 feet situated at Nuggahalli Koppallu Village, Bannur Hobli, T oe P4 792 Nerasipura Thaluk measuring East to West: 40 feet North to South: 60 feet totally measuring 2400 Squire feet and having boundary on: East by : Vacant Site West by Road North by : House of Nanjegowda South by :Road Advocate for Plaintiff Plaintiff VERIFICATION What are all stated above are true to the best of my knowledge, belief and information and in token whereof We have signed here under. Date: Place: T Narasipura ‘THE SENIOR CIVIL JUDGE AND JMFC AT T NARASIPURA [Link] / 2025 Plaintiff : Suresh -V/s- Defendant : M Ningegowda IN THE COURT OF VERIFYING AFFIDAVIT 1 Suresh S/o Late Eshwarachari, Aged about 58 years, R/at No.37, Nuggahalli Koppalu, Bannur Hobli, T Narasipura Taluk- 571101 the Plaintiff in the above case do hereby solemnly affirm and state on oath as follows: 1. That I have filed the above suit against the defendants for declaration and injunction over the schedule properties. As such contents of plaint may kindly be read as part and parcel of this affidavit. 2. 1 State on oath that the contents of plaint from paras 1 to 11 and entire averments of the plaint are true to the best of my knowledge, belief and information and in token where of I have signed to the plaint. I do swear in the name of God that the contents of this affidavit are true and correct and I have signed here under. IDENTIFIED BY ME DEPONENT See / IN THE COURT OF THE SENIOR CIVIL JUDGE AND JMFC [ AT T NARASIPURA | 0.8.No__/ 2025 Plaintiff = Suresh v/s- Defendant : M Ningegowda [Link]. {2025 Applicant : ~~‘ Suresh vis Opponent : MNingegowda ao Defendant APPLICATION UNDER ORDER. VI RULE 14-A OF THE cPpc For the reasons stated in the accompanying affidavit applicant / Plaintiff humbly prays that the Hon’ble court be The addresses of the parties furnished in the cause title of the plaint is true and correct for the purpose of issuing notices through court as well registered post in the above case in the interest of justice and equity. Advocate for Plaintiff Plaintiff/ Applicant Date: Place: T Narasipura Eom IN THE COURT OF THE SENIOR CIVIL JUDGE AND JMFC AT T NARASIPURA O.S.No__/ 2025 Suresh -v/s- Defendant : M Ningegowda Plaint: AFFIDAVIT 1 Suresh S/o Late Eshwarachari, Aged about 58 years, R/at No.37, Nuggahalli Koppalu, Bannur Hobli, T Narasipura Taluk- 571101 the Plaintiff in the above case do hereby solemnly affirm and state on oath as follows: 1, That I have filed the above suit against the defendants for declaration and injunction over the schedule properties. As such contents of plaint may kindly be read as part and parcel of this affidavit. 2. Tam the plaintiff in the above case and I am fully conversant with the facts of the case and for the purpose of registered address, my address is the same as mentioned in the cause title. I will receive all the summons/notice on that address I do swear in the name of God that the contents of this affidavit are true and correct and I have signed here under. IDENTIFIED BY ME ADVOCATE DEPONENT PLACE: T Narasipura SlOe IN THE COURT OF THE SENIOR CIVIL JUDGE AND JMFC AT T NARASIPURA O.S.N 2025 Plaintiff : Suresh -v/S- Defendant : M Ningegowda [Link]. [2025 Applicant : Suresh v/s Opponent : MNingegowda For the reasons stated in the accompanying affidavit ‘Applicant/Plaintif? humbly prays that this Hon’ble Court be pleased to pass an ad interim order of ex-parte temporary injunction against the defendants/opponents restraining them not to alienate the application of the plaint schedule property and dealt with the same pending disposal of the suit in the interest of justice and equity. SCHEDULE PROPERTY All the piece and parcel of the property assessment No.37, Janjar No.836, measuring east by west 40 feet north by south 60 feet situated at Nuggahalli Koppallu Village, Bannur Hobli, T Narasipura Thaluk measuring East to West: 40 feet North to South: 60 feet totally measuring 2400 Squire fect and having boundary on: East by _: Vacant Site ‘West by Road North by: House of Nanjegowda South by :Road Advocate for Plaintiff Pista DATE: PLACE: T Narasipura F ate IN THE COURT OF THE SENIOR CIVIL JUDGE AND JMFC AT T NARASIPURA O.S.No___/ 2025 Plaintiff: Suresh -v/s- Defendant : M Ningegowda AFFIDAVIT 1 Suresh S/o Late Eshwarachari, Aged about 58 years, R/at No.37, Nuggahalli Koppalu, Bannur Hobli, T Narasipura Taluk- 571101. the Plaintiff in the above case do hereby solemnly affirm and state on oath as follows: 1. 1 State on oath that, the Plaint schedule property is belongs Plaintiff mother by name Late Kamalamma W/o Late Eshwarachari has acquired through Government allotment(Grant) on 30.10.1978 and grant certificate Issued by Hegguru Grama Panchayath in assessment No.37, Janjar No.836, measuring east by west 40 feet north by south 60 feet situated at Nuggahalli Koppallu Village, Bannur Hobli, T Narasipura Taluk and plaintiff is belongs to Hindhu Vishwakarma Cast and after issuing grant certificate the Khata has changed in the name of the plaintiff Mother and till date khata is stand in the name of the plaintiff mother and plaintiff mother has died on 16.08.2012 And after the death of plaintiff mother plaintiff only possession and enjoyment of the suit schedule property till today. 2. 1 State on oath that, the defendant was member of the Heggur Panchayath in that time the defendant as fraudulently created Janjar No.461, assessment No.37 in to his name Ps after obtaining the khata the defendant hes sane i harassment to the plaintiff mother as during the life time the plaintiff mother he has given the several appli to cancel the Janjar No.461, assessment No.97 from, 2009 to till death of the plaintiff mother. -12- ‘After the death of the plaintiff mother 3.1 State on oath that, te iceceraca authorities but they are not t ee ave the to defendant. And on 23.05.2002 illegally trespass the plaintiff schedule property and he has man handling the plaintiff as such he has given the police complaint against to the defendant and also again the defendant illegally trespass the suit schedule property and cut the trees in the plaintiff schedule property as such complainant has given the complaint to the Bannur police Station on 05.06.2023 but they have not take any auction against to the defendant. 4-1 State on oath that, on 10/07/2023 the plaintiff and Nagarika Hakiuu Rakshna Samithi member are made a strike {In front of the Jilla Panchayath, Mysore and after that the Jillapanchayath has issued a direction to Nudel office to given Mahazer report and after that Jilla Panchayath has directed ‘o the plaintiff to approach EO office to after that plaintiff has filed a Appeal before the T Narasipura Panchayath court Sgainst to the defendant in Appeal No.12/2024-2025 after hearing the both the Parties the Hon'ble court has rafter to Civil court, 5.1 State on oath that, absolutely the defendants have no manner of right, title or interest what’ SO ever over the Property to other persons, 13: .1 State o1 6. oath that, the cause of action arose when a has fraudulently obtained the kahata and on c 009 when plaintiff mother has given the compliant ! a 18.09.2025 when Hon'ble tribunal has dismiss the petition also about 7 days back ie. on 01/11/2025 the defendants along with their henchmen have tried to interfere with the schedule property. 7.1 State on oath that, he is helpless and having no supporters in the locality but the defendants are very powerful person and they are having both money and political influence behind their back and they are not believe in law. As such his said attitude cannot be resisted without the order of this Hon'ble Court. Hence without any alternative the Plaintiff has approached this Hon’ble Court Hence it is a suit for Declaration and permanent injunction. 8.1 State on oath that, The schedule property assessment No.37, Janjar No.836, measuring cast by west 40 feet north by south 60 feet situated at No.37 Nuggahalli Koppalhy Village, Bannur Hobli, T Narasipura Taluk within the jurisdiction of this Hon’ble Court 9.1 state on oath that I have made out a prima facie case and balance of conveyance tilts heavily in my favour if order of ex: parte temporary injunction is not granted, the very purpose of filing of this suit will be defeated and defendants shall definitely dispossess me from the suit schedule property by force and they will sell the schedule property, and they will interfering with my peace full possession and enjoyment of suit schedule property that event greater hardship and injury will be caused to me and it cannot be compensated in any manner. If the application is allowed no hardship or injustice will be caused to other side. -14- t In this circumstance | humbly submit that granting the reliefas prayed for is necessary in the interest of justice and equity Ido swear in the name of God that the contents of this affidavit are true and correct and I have signed this at T Narasipura. Identified by me Deponent Advocate Date: Place: T Narasipura

You might also like