A SUIT FOR PARTITION IN THE COURT OF THE CIVIL JUDGE, SENIOR DIVISION, PUNE
AT PUNE
Civil Suit No	 /200.
Shri SI __.(Full Name)	                                                           Plaintiff
age 32 years, occupation - agriculture,
 resident of House No. 302 Kothrud, 
Taluka Haveli, District Pune.
Versus
Shri _F__ (Full Name)	
age 63 years, occupation - agriculture, 
Smt. _M_ (Full Name) _
age 55 years, occupation - agriculture,
Shri _S2_. (Full Name)	
age 26 years, occupation - agriculture, 
all residents of House No. 302, Kothrud, 
Taluka Haveli, District Pune.                                                      Defendant
A SUIT FOR PARTITION
The plaintiff abovenamed submits this plaint, praying to state as follows :
1.      The Pedigree : That the pedigree is as follows :
F   (Defendant No. 1)
M   (Defendant No. 2)
SI (Plaintiff)                                                                          S2 (Defendant No. 3)

That the defendant No. 1 is the father of the plaintiff and the defendant No. 3 and husband of the defendant No. 2, while the defendant No. 2 is the mother of the plaintiff and the defendant No. 3, and the plaintiff and the defendant No. 3 are full/real brothers.
2. Description of Property : All that piece and parcel of land situate within the Registration Division & District Pune, Sub-Division & Taluka Haveli, within the local limits of the Pune Municipal Corporation, revenue village Kothrud, bearing Gat No. 302, admeasuring 8 hectares or thereabouts,and bounded
by as follows:
On or towards the East    _      CTS No. 300, 
On or towards the South _     CTS No. 299, 
On or towards the West   _      Public Road, and On or towards the North _      Nullah.
3. That the property described in para 2 above originally belonged to GF, who died in June 200_, and on his death, the suit property came to be devolved upon the family of the plaintiff and the defendants, and since then, the defendant No. 1 has been managing the suit property as a Karta of the joint family. 
4. That since last one and a half years, the relationship between the plaintiffs wife and the defendant No. 2 is so strained that there have been frequent quarrels, and it has finally become necessary for the plaintiff to live apart.
5. That the plaintiff accordingly called upon the defendant No. 1, on	, to effect partition, but he refused to do so.
6. That the plaintiff submits that the defendants have been obstructing this plaintiff in his enjoyment of the suit property along with them, and this plaintiff has no other source of income except and save the suit property.
7. That the plaintiff, therefore, served upon the defendants a notice, dated ____calling upon them to effect partition, but the defendant No. 1, once again, refused to do so, and hence, this suit. 
8. That the plaintiff and the defendants are governed by the Mitakshara School of Hindu Law, and accordingly, the plaintiff is entitled to one-fourth share in the suit property.
9. That the cause of action for this suit first arose on	., when the plaintiffs demand for partition was turned down by the defendants and has since then been arising every day thereafter,  and hence,  the suit filed today is well within limitation.
10. That the property is 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.
11.That the suit is valued for the purpose of jurisdiction at Rs.__that being the amount equal to 20 times the revenue assessment, and on the one-fourth of such amount, proper court-fee is paid herewith.
12. That the plaintiff, therefore, prays that – 
(A)It be declared that the plaintiff is entitled to one-fourth share in the suit property;
(B) The plaintiffs one-fourth share be divided and given in his possession;
(C)The defendants be permanently restrained from obstructing this plaintiff in his enjoyment of the suit property;
(D)The plaintiff be paid the costs of this suit from the defendants,
and
(E) Any other orders in the interest of justice be kindly passed.
Pune,
Dated:
Sd/- S1 PLAINTIFF
Sd/- xXx 
ADVOCATE FOR PLAINTIFF

VERIFICATION
I, Shri S1, the present plaintiff, do hereby state on solemn affirmation that the contents of this plaint in paras 1 to 12 are true and correct to the best of my knowledge and belief, and I have signed hereunder.
Sd/- SI PLAINTIFF