LEGAL NOTICE
On Behalf Of:
1) Mrs. Priya, Mrs. Geetha and Mrs. Shanthi,
Daughters of Mr. Raguram
Address: ________________
_______________________
To,
1) Mr. R. Rajavel
S/o Mr. Ragu Ram
Address: __________________
____________________
2) Mr. R. Sakthivel
S/o Mr. Ragu Ram
Address: _____________
______________________
REGISTERED LEGAL NOTICE
Dear Sir,
Under instructions from and on behalf of my clients Mrs. Priya, Mrs.
Geetha, Mrs. Shanthi daughters of Mr. Ragu Ram resident of
_______, the following legal notice is being served on you: –
1. That Mr. Raguram, father of my clients, who was residing at
________died on 01.05.2016.
2. That at the time of his death he was the absolute/ sole owner
of the property bearing Door No.
___________________________.
3. That Mr. Ragu Ram died intestate, that is, without making
any ‘Will’ in the favour of any person(s) before or at the
time of his death.
4. That Mr. Ragu Ram died leaving behind the following legal
heirs at the time of her death: –
Name Relation with deceased
Mrs. Keerthana Raguram Wife
Mr. R. Rajavel Son
Mr. R. Shakthivel Son
Mrs. Priya Daughter
Mrs. Geetha Daughter
Mrs. Shanthi Daughter
5. That according to law, any of the legal heirs of Mr. Ragu
Ram may call upon the rest of the legal heirs to partition the
aforesaid property by meets and bound and delivers the
vacant possession of their respective share, at any time.
6. That it has came to the knowledge of my clients that you are
now trying to divide the property among yourselves and sell
the aforesaid property by manipulating and forging some
false documents illegally, dishonestly, fraudulently and in
gross violation of the laws of the land.
7. That as the aforesaid property has to be partitioned among all
legal hiers, you were further forbidden to deal with it in
anyway. Further you have no right to deal in any way with
the share of my clients and before partition of the aforesaid
property.
I, therefore, by means of this notice, call upon you to restrain from
any activity which may hinder the undisturbed enjoyment of my
clients of their shares over the above said property and to partition the
property bearing no. _____by meets and bound, and deliver the vacant
possession of the shares of my aforesaid clients within fifteen days of
the receipt of this notice failing which I have clear instructions to
institute the necessary Civil as well as Criminal Proceedings against
you both and in these events you shall be held liable for all the costs
of and incident to such proceedings.
Copy retained for record and further necessary action.
________________________
(ADVOCATE)
PLAINT
IN THE COURT OF THE DISTRICT MUNSIFF,
………………………………..
Civil Suit No…………………………………………………………..
/2016
1) Mrs. Priya
D/o Mr. Ragu Ram
age … years, occupation – ……………..,
resident of …………………………………..
2) Mrs. Geetha
D/o Mr. Ragu Ram
age … years, occupation – ……………..,
resident of …………………………………..
3) Mrs. Shanthi
D/o Mr. Ragu Ram
age … years, occupation – ………………,
resident of ………………………………….. Plaintiffs
Versus
1) Mr. R. Rajavel
S/o Mr. Ragu Ram
age……..years, occupation -…………………..,
2) Mr. R. Sakthivel
S/o Mr. Ragu Ram
age……..years, occupation -…………………..,
Resident of………………………………….. Defendant
A SUIT FOR PARTITION
The plaintiffs above named begs to submit as follows :
1. That the plaintiffs are the daughters and the defendants
are the sons of the deceased Mr. Ragu Ram.
2. That Mr. Raguram, who was residing at ________died on
01.05.2016.
3. That at the time of his death he was the absolute/ sole
owner of the property bearing Door No.
___________________________.
4. That Mr. Ragu Ram died intestate, that is, without making
any ‘Will’ in the favour of any person(s) before or at the
time of his death.
5. That Mr. Ragu Ram died leaving behind the following legal
heirs at the time of her death: –
Name Relation with deceased
Mrs. Keerthana Raguram Wife
Mr. R. Rajavel Son
Mr. R. Shakthivel Son
Mrs. Priya Daughter
Mrs. Geetha Daughter
Mrs. Shanthi Daughter
6. Description of Property : All that piece and parcel of land
situate within the Registration Division & District Madurai,
Madurai South Taluk, within the local limits of the Madurai
Corporation, revenue village Solanguruni, bearing
R.Survey No. 204/5A, admeasuring 20 Cents or
thereabouts, and bounded
by as follows:
On or towards the East _ …………………….
On or towards the South _ ………………..
On or towards the West _ Public Road,
and On or towards the North _ ………………..
7. That the property described in para 6 above is a self
acquired property of Mr. Ragu Ram and he purchased it
from his own funds out of his employment.
8. That the plaintiffs came to know that the Defendants are
are now trying to divide the property among themselves
and sell the aforesaid property by manipulating and
forging some false documents illegally, dishonestly,
fraudulently and in gross violation of the laws of the land.
9. That the plaintiff accordingly called upon the defendants,
on , to effect partition, but they refused to do so.
10. That the plaintiff submits that the defendants have
been obstructing these plaintiffs in their enjoyment of the
suit property along with them, and these plaintiffs have no
other source of income except and save the suit property.
11. That the plaintiffs, therefore, served upon the
defendants a notice, dated ____calling upon them to effect
partition, but the defendants, once again, refused to do so,
and hence, this suit.
12. The plaintiffs are entitled to shares in the suit property.
13. 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.
14. 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 share of such amount, proper court-fee is
paid herewith.
12. That the plaintiff, therefore, prays that –
(A) That the defendants be restrained by an injunction from
alienation.
(B) It be declared that the plaintifs are entitled to share in the suit
property;
(C) The plaintiffs share be divided and given in their possession;
(D)The defendants be permanently restrained from obstructing this
plaintiff in his enjoyment of the suit property;
(E)The plaintiff be paid the costs of this suit from the defendants,
and
(F) Any other orders in the interest of justice be kindly passed.
Dated:
Sd/- 1. PLAINTIFF
Sd/- 2. PLAINTIFF
Sd/- 3. PLAINTIFF
ADVOCATE FOR PLAINTIFF
VERIFICATION
I, Mrs Priya, the present plaintiff no 1, verify that the facts stated in
paras 1 to 7 of the above plaint are true to my personal knowledge
and the contents of Paras 8 to 12 are believed by me on
information received, to be correct. I append my signature to this
verification at …………on ……………..2016.
Sd/- SI PLAINTIFF 1
I, Mrs Geetha, the present plaintiff no 2, verify that the facts stated
in paras 1 to 7 of the above plaint are true to my personal
knowledge and the contents of Paras 8 to 12 are believed by me on
information received, to be correct. I append my signature to this
verification at …………on ……………..2016.
Sd/- SI PLAINTIFF 2
I, Mrs Shanthi, the present plaintiff no 3, verify that the facts stated
in paras 1 to 7 of the above plaint are true to my personal
knowledge and the contents of Paras 8 to 12 are believed by me on
information received, to be correct. I append my signature to this
verification at …………on ……………..2016.
Sd/- SI PLAINTIFF 3
