A SUIT FOR PARTITION & PERMANENT INJUNCTION
IN THE COURT OF THE CIVIL JUDGE, SENIOR DIVISION, PUNE
AT PUNE
Shri RAN	(Full Name)	
age 43 years, occupation – 
service, resident of  Rajgurunagar, 
Taluka Khed, District Pune.
                                                                                                       Plaintiff
         Versus

1. Shri AJN _(Full Name)	
age 73 years, occupation - agriculture,
2. Shri DAN	(Full Name)	
age 40 years, occupation - service, both
 residents of Rajgurunagar, Taluka Khed,
 District Pune.
                                                                                                        Defendants
A SUIT FOR PARTITION & PERMANENT INJUNCTION
The plaintiff above named submits this plaint, praying to state as follows :
1.The Pedigree : That the pedigree is as follows :
AJN   (Defendant No. 1)
RAN	DAN
(Plaintiff)	(Defendant No. 2)
That the defendant No. 1 is the father of the plaintiff and the defendant No. 2, while the defendant No. 2 and the plaintiff are full/real brothers.
2. Description of Properties :   All that that piece and parcel of lands situate within  the  Registration  Division  &  District  Pune,   Sub-Division & Taluka Khed within the local limits of the Pune Zilla Parishad, revenue village Rajgurunagar, as detailed below:
3. That all the above mentioned were ancestral, and therein, the plaintiff had undivided l/3rd share.
4. That the plaintiff is working as a Deputy Engineer, and because of his employment, he is required to run from place to place, and hence, the properties are managed and looked after by the defendants only.
5. That taking the benefit of this position, the defendants started acting in such a manner that the plaintiff be put to the maximum loss, and, accordingly, for no need or legal necessity, the defendant No. 1, at the instigation of the defendant No. 2, sold out, on the land properties mentioned at Sr. No. 1 above, and again sold out the land property mentioned at Sr. No. 4 above, on	
6. That in fact, the defendant No. 1 does not have any need for money, and the income from the ancestral properties is much more than his needs.
7. That the defendant No. 2 is also employed as a teacher, and his salary itself is sufficient to meet his expenses, and, as such, there was neither any legal necessity, nor was there any benefit of the estate, and hence, the defendant No. 1 did not have any right, title or interest to transfer the said properties without the plaintiffs consent, and hence, those sale-deeds are not valid and binding on the share of the plaintiff in the said properties.
8. That the properties at Sr. Nos.   1  and 4 have been sold by the defendant No. 1 in favour of Shri VAG, who happens to be the son-in-law of the defendant No. 1.
9. That the plaintiff submits that the properties are the lands quite rich in quality and fertile.  However, they have been shown to have been sold at a paltry amount of Rs. 20,000/-, which is much below the said transaction is sham and fraudulent.  It has been effected with the sold intention of defeating the rights of the present plaintiff, and, hence,  on this count also,  the said sale-deeds are invalid and inoperative. However, the plaintiff is filing a separate suit for declaration and cancellation of the said sale-deeds, and he deserves his right to do so in the present suit.
10.  That after knowing about the said transactions, on or about	, and then, on	_, the plaintiff had been to his village and then he  called  upon  the  defendants  to  explain  as  to  why the  said properties were transferred without his knowledge.   However, the defendants refused to reply the queries, and thereupon, the plaintiff demanded partition of his share in the family properties.  However, the defendants specifically denied to do so asserting that they would not give any property to this plaintiff, and hence, this suit.
11. That the cause of action for the present suit first arose on	, when the partition was demanded and denied and the same has since then been arising every day thereafter, and hence, the suit filed today is well within limitation.
12. That the properties are situate within the local limits of the jurisdiction of this Court, and hence, this Hon'ble Court has jurisdiction to try and decide this suit.
13. That the properties described in para 2 above being agricultural lands are valued at 20 times the revenue assessment, and proper court fee stamp is paid herewith. In addition to this, for declaration and injunction, the suit is valued at Rs.	, and the additional court fee stamp is paid thereon.
14. That the plaintiff, therefore, prays that -
(a)It be declared that the plaintiff is entitled to one-third share
in the suit properties;
(b)The plaintiffs one-third share be divided by metes and bounds
and given in his possession;
(c)While asserting the plaintiffs one-third share, the properties sold, as described in Sr. No. 1 and 4 of para 2 above be taken into  account and included in the  shares,   those  may be assigned to the defendants, and, thus, the plaintiff be given his one-third share of all the properties.
(d) The defendants be permanently restrained from obstructing or interfering with the possession of the  plaintiff of his properties;
(e) The plaintiff be paid his costs from the defendants, and
(f) Any other orders in the interest of justice be kindly passed.
Pune,
Sd/- RAN
Dated :		PLAINTIFF
Sd/- xXx 
ADVOCATE FOR PLAINTIFF
VERIFICATION
I, Shri RAN the present plaintiff, do hereby state on solemn affirmation
that the contents of this plaint in paras 1 to 14 are true and correct to the
best of my knowledge and belief, and I have signed hereunder at Pune this
__ day of	200_
Sd/- RAN PLAINTIFF