IN THE COURT OF SUB COURT, JUDGE AT TINDIVANAM

O.S.NO. OF 2024
1. Poongothai, F/63yrs
wife of Mr.Subramaniyan,
daughter of Late.Mr.Selvam,
residing at No.255, 8th Block,
Udhayasuriyan Nagar,
Vyasarpadi, Chennai-600 039.
2. Mrs.Maha, F/56 yrs,
wife of Mr.Mahalingam,
daughter of Late.Mr.Selvam,
residing at No.220,
Arunthathiyar Street,
Kadavambakkam,
Villupuram-604101.
3. Mr.Kudiyarasu, M/49 yrs,
son of Late.Mr.Selvam,
residing at No.413,
C- Kalyanapuram 2nd Street,
Vyasarpadi, Chennai-600 039

4. Mr.Rajesh, M/38 yrs,

son of Late.Mr.Raja,
residing at No.347,
C- Kalyanapuram 5th Street,
Vyasarpadi, Chennai-600039.
5. Mrs.Ramani, F/36 years,
wife of Mr.Chinnadurai,
daughter of Late.Mr.Raja,
residing at No.58,
C-Kalyanapuram 1st Main Road,
Vyasarpadi, Chennai-600 039.
6. Mrs.Uma, F/54 yrs,
wife of Late.Mr.Raja,
residing at 347, C-Kalyanapuram,
5th Street, Vyasarpadi, Chennai-600 039.
7. Mrs.Divya, F/33 yrs,
wife of Mr.Dillibabu,
daughter of Late.Mr.Paramashivam,
residing at No.243, C- Kalyanapuram Main Street,
Vayasarpadi, Chennai-600 039.
 8. Mrs.Dhivina, F/32 yrs,
wife of Mr.Sudhakar,
daughter of Late.Mr.Paramashivam,
residing at No.127, D’Block,
Malligapoo Colony, Vayasarpadi,
Chennai-600 039.
9. Mrs.Renuga @ Renugadevi, F/47 yrs,
wife of Mr.Sundaramoorthy,
daughter of Late.Mr.Pushpalingam,
No.48, Manamman Koil Street,
Boomiapet, Pondicherry- 605 005.
10. Mr.Thirunavukarasu, M/45 yrs,
son of Late.Mr.Pushpalingam,
residing at No.7, 2nd Cross Street,
Rajayar Thottam, Kuyavarpalayam, Saram,
Puducherry- 605013.
11. Mrs.Thenmozhi, F/69 yrs,
wife of Late.Mr.Pushpalingam,
residing at No.48, Mariamman Koil Street,
Boomianpet, Pondicherry-605005.
12. Mrs.Eswari, F/49 yrs,
wife of Mr.Santhosh Kumar,
daughter of Late.Mrs.Jothi,
residing at No.14, Iyyanar Koil Street,
Vishnu Nagar. Karuvadikuppam,
Lawspet, Puducherry- 605008,
13. Mrs.S.Mageswari, F/47 yrs,
wife of Mr.Saravanan,
daughter of Late.Mrs.Jothi,
residing at No.16, Ezhal Mariamman Koil Street,
Kuyavarpalayam, Saram,
Pondicherry-605013
14. Mr.A.S.Shanmugam, M/41 yrs,
son of Subrayan,
residing at No.14, Iyyanar Koil Street,
Vishnu Nagar. Karuvadikuppam,
Lawspet, Puducherry- 605008
15. Mrs.Thulasi, F/58 yrs,
Wife of Mr.Mani,
No.4, Aruthathiyar Street, Kadavampakkam,
Aavalippur Post, Tindivanam,
Villupuram- 604101
 All the above 1 to 14 were represented
by their Power Agent,
Mrs.Thulasi, F/58 yrs,
Wife of Mr.Mani,
No.4, Aruthathiyar Street, Kadavampakkam,
Aavalippur Post, Tindivanam,
Villupuram- 604101. …Plaintiff
Verses
1. Mrs.Megala,
W/o. Mr.Sekar,
Residing at Aruthathiyar Street,
Kadavampakkam,
Aavalippur Post, Tindivanam,
Villupuram- 604101.
2. S.Krishnasamy, M/72yrs
son of Late.Mr.Selvam,
residing at No.2/5, 2nd Floor,
Eswar Enclave, Pillaiyar Koil Street,
Kalaignar Karunanidhi Nagar,
Chennai-600 078.
3. Mrs.Rajeswari, F/47 yrs,
wife of Mr.Ezhumalai,
D/o Late.Mr.Shankar @ Sankaralingam,
residing at No.124, 4th Street,
J.J.Nagar, Vyasarpadi,
Chennai-600 039.
4. Mr.Vijayakumar, M/41 yrs,
son of Late.Mr.Shankar @ Sankaralingam,
residing at No.7,
Jeevanantham Street,
Soozhpunal Karai, Erukkancheri,
Koduingayur, Chennai-600 118
5. The Sub-Registrar,
Avarapakkam,
Tindivanam. …Defendants

PLAINT FILED UNDER ORDER VII RULE 1 OF C.P.C.

The Plaintiff above named humbly submits as follows:
1. The Plaintiffs are 1. Poongothai, wife of Mr.Subramaniyan,
daughter of Late.Mr.Selvam, aged about 63 years, residing at
No.255, 8th Block, Udhayasuriyan Nagar, Vyasarpadi, Chennai-600
039, 2. Mrs.Maha, wife of Mr.Mahalingam, daughter of
Late.Mr.Selvam, aged about 56 years, residing at No.220,
Arunthathiyar Street, Kadavambakkam, Villupuram-604101,
3.Mr.Kudiyarasu, son of Late.Mr.Selvam, aged about 49 years,
residing at No.413, C- Kalyanapuram 2 nd Street, Vyasarpadi,
Chennai-600 039, 4. Mr.Rajesh, son of Late.Mr.Raja, aged about 38
years, residing at No.347, C- Kalyanapuram 5 th Street, Vyasarpadi,
Chennai-600 039, 5. Mrs.Ramani, wife of Mr.Chinnadurai, daughter
of Late.Mr.Raja, aged about 36 years, residing at No.58, C-
Kalyanapuram 1st Main Road, Vyasarpadi, Chennai-600 039, 6.
Mrs.Uma wife of Late.Mr.Raja, aged about 54 years, residing at 347,
C-Kalyanapuram, 5th Street, Vyasarpadi, Chennai-600 039, 7.
Mrs.Divya, wife of Mr.Dillibabu, daughter of Late.Mr.Paramashivam,
aged about 33 years, residing at No.243, C- Kalyanapuram Main
Street, Vayasarpadi, Chennai-600 039, 8. Mrs.Dhivina, wife of
Mr.Sudhakar, daughter of Late.Mr.Paramashivam, aged about 32
years, residing at No.127, D’Block, Malligapoo Colony, Vayasarpadi,
Chennai-600 039, 9. Mrs.Renuga @ Renugadevi, wife of
Mr.Sundaramoorthy, daughter of Late.Mr.Pushpalingam, aged about
47 years, residing at No.48, Manamman Koil Street, Boomiapet,
Pondicherry- 605 005, 10. Mr.Thirunavukarasu, son of
Late.Mr.Pushpalingam, aged about 45 year, residing at No.7, 2 nd
Cross Street, Rajayar Thottam, Kuyavarpalayam, Saram, Puducherry-
605013, 11. Mrs.Thenmozhi wife of Late.Mr.Pushpalingam, aged
about 69 years, residing atNo.48, Mariamman Koil Street,
Boomianpet, Pondicherry-605005 12. Mrs.Eswari, wife of
Mr.Santhosh Kumar, daughter of Late.Mrs.Jothi, aged about 49 years,
residing at No.14, Iyyanar Koil Street, Vishnu Nagar.
Karuvadikuppam, Lawspet, Puducherry- 605008, 13.
Mrs.S.Mageswari, wife of Mr.Saravanan, daughter of
Late.Mrs.Jothi, aged about 47 years, residing at No.16, Ezhal
Mariamman Koil Street, Kuyavarpalayam, Saram, Pondicherry-
605013 and 14. Mr.A.S.Shanmugam, son of Subrayan, aged about
41 years, residing at No.14, Iyyanar Koil Street, Vishnu Nagar.
Karuvadikuppam, Lawspet, Puducherry- 605008 , 15. Mrs.Thulasi,
Wife of Mr.Mani, Hindu, Female, aged about 58 years, residing at
No.4, Aruthathiyar Street, Kadavampakkam, Aavalippur Post,
Tindivanam, Villupuram- 604101,represented by their Authorized
power agent Mrs.Thulasi, Wife of Mr.Mani, Hindu, Female, aged
about 59 years, residing at No.4, Aruthathiyar Street,
Kadavampakkam, Aavalippur Post, Tindivanam, Villupuram-
604101, Within the jurisdiction of this Hon’ble Court.

Address for service of the plaintiff to her counsel M/s. C.RUBAN

D SILVA, M.BENAZIR BEGUM, GOPINATH AND C.IMMANVEL,
having their office at No

2. The 1st Defendant is Mrs.Megala, wife of Mr.Sekar, Hindu,

female, age not known, residing at Aruthathiyar Street,
Kadavampakkam, Aavalippur Post, Tindivanam, Villupuram-
604101,

The 2nd Defendant is Mr.S.Krishnasamy, son of

Late.Mr.Selvam, Hindu, Male aged about 73 years, residing at
No.2/5, 2nd Floor, Eswar Enclave, Pillaiyar Koil Street, Kalaignar
Karunanidhi Nagar, Chennai-600 078.

The 3rd Defendant is Mrs.Rajeswari, wife of Mr.Ezhumalai,

Daughter of Late.Mr.Shankar @ Sankaralingam, Hindu, Female,
aged about 48 years, residing at No.124, 4 th Street, J.J.Nagar,
Vyasarpadi, Chennai-600 039, and

The 4th Defendant is Mr.Vijayakumar, son of Late.Mr.Shankar

@ Sankaralingam, Hindu, Male, aged about 42 years, residing at
No.7, Jeevanantham Street, Soozhpunal Karai, Erukkancheri,
Koduingayur, Chennai-600 118.

The 5th Defendant is the Sub-Registrar, Avarapakkam,

Tindivanam

and the Address for Service of the Defendants is as mentioned

above and 1st Defendant and 4th Defendant are within the
jurisdiction of this Hon’ble Court and the service of summons
and process to the Defendants 2 to 4 through City Civil Court,
Chennai.

3. The 15th Plaintiff (herein after called Plaintiff) states that she is
the Authorized Power of Attorney of the Plaintiffs 1 to 14 herein
(herein after called PRINCIPALS), whereas, she was been
appointed as a Power Agent by the above said plaintiffs vide an
unregistered power deed dated 11.09.2023 to file this present
case and adduce all evidence and to file necessary petitions and
documents, ect., and the plaintiff further states that she, along
with the principals herein and Defendants 2 to 4 are the only
surviving legal heirs of one Late.Mr.Selvam son of Late.Nagan
(herein after called PRINCIPALS). The Family Tree of
Late.Mr.Selvam is shown below for better appreciation.
 Legal Heirs of Late Mr.Selvam (FAMILY TREE)

Late.Mr.Selvam
Pachaiyammal (Wife) Deceased

Deceased Deceased Deceased Deceased Deceased

Deceased
(Son) (Daughter) (Daughter) (Son) (Son) (Son) (Son) (Son) (Daughter) (Daughter)
(Son)

1.Krishnasamy 2.Poongothai 3.Maha 4.Kudiyarasu 5.Shakar 6.Raja 7.Paramasivam 8.Pushpalingam 9.Jothi 10. Thulasi 11.Nagaraj

(Unmarried )
Rajeswari Vijayakumar
(Wife) (Son)

Renuadevi Thenmozhi
Uma Ramani Rajesh (Daughter) (Wife)
(Wife) (Daughter) (Son) Thirunavukarasu
(Son)

Divya Dhivina
(Daughter) (Daughter)

S.Maeswari S.Eswari S.Shanmugam

(Daughter) (Daughter) (Son)
4. The plaintiff states that, the above said Late.Mr.Selvam,
purchased the schedule mentioned property herein ought of
his hard earned money from Mr.Pachaiappan vide Sale Deed
Document No.913/1993 dated 14.07.1993 before SRO
Aravambakkam, the 5th defendant herein, and since from the
date of the abovesaid purchase, he was in the peaceful
possession and enjoyment over the Scheduled mentioned
property herein till the date of his demises.
5. The plaintiff further states that, the said Mr.Selvam died
intestate on 08.06.2001 leaving behind his legal heir as
shown in abovesaid Family tree, to succussed the scheduled
mentioned property without subjecting the scheduled
mentioned property herein to any mortgage, Lien or
encumbrance.
6. The plaintiff further submit that, after the demise of the
Mr.Selvam on 08.06.2001, the surviving legal heirs of the
deceased neither made any deed of Partition with respect to
their respective shares in scheduled mentioned property, nor
executed any settlement deeds in any others favour and
enjoyed their respective shares in the said property without
subjecting the same into any encumbrance. Since, the value
of the property is very low during that time and they waited
patiently to share the said property after its value increase in
the furture.
7. The Plaintiff further states that, soon after the demies of
the said Selvam, the 2nd defendant along with one Mr.Sankar
@ Sankaralingam, who is the father of the 3 rd and 4th
defendant herein, jointly colluded with the 1 st defendant with
the malafide intention to cheat the plaintiff and her Principals
and the said 2nd defendant along with the Sankar @
sankaralingam unilaterally and fraudulently executed a
Registered sale Deed in Document No.203 of 2002 dated
15.02.2002 in favour of the 1st defendant herein before SRO
Avarapakkam, the 5th defendant herein with respect to the
schedule mentioned property herein without the knowledge
and consent from the other serving legal heir of the
deceased Mr.Selvam, which is fictitious, sham, incompetent,
bad, illegal, nullity and void ab initio in law.
8. The Plaintiff further submit that, the Defendants 1 & 2
and the father of the 3rd and 4th defendant played a serious
fraud against the plaintiff and her principals, since they
promiscuously supressed the execution of the sale of the
scheduled mentioned property herein to the other surviving
legal heirs of the deceased Mr.Selvam and it is pertinent to
note here that, though the 1 st defendant herein is the
resident of the same locality who very well known about the
other surviving legal heirs of the deceased Mr.Selvam (who is
owner of the Scheduled mentioned property), she too
fraudulently obtained the sale deed in her favour with a
malafide intention to cheat the plaintiff and her principals.
9. The plaintiff further submits that, after the execution of
the said sale deed, the 1 st defendant kept all her activities in
abeyance till the month of June 2023 without doing anything
in the schedule mentioned property, though she obtained a
fraudulent sale deed in her favour in the year February 2002
and she suddenly encroached into the Scheduled mentioned
property and started a construction in the scheduled
mentioned property herein in the month of July 2023.
Whereas, during that time the plaintiff herein who is residing
in the same area, she came to known about the illegal
encroachment made by the 1 st defendant herein and she
rushed to the subject property and asked the 1 st Defendant to
stop her illegal activities and demanded her to remove all
illegal encroachment in the scheduled mentioned property.
Whereas, to the utter shock and surprise of the plaintiff
herein, the 1st defendant failed to adhere any of the demand
made the plaintiff and she informed that, she already
purchased the scheduled mentioned property herein in the
year 2002 and claimed herself as a legal owner of the said
property, which put the plaintiff into the shell shock.
Whereas, the 1st defendant is doing a money lending
business and she is very influential in that area and she also
have a very powerful political background, she chased the
plaintiff herein with the help of gundas by abusing her in very
filthy language and the 1st defendant also challenged the
plaintiff that no one can do anything against her in that
locality and asked the plaintiff to do anything she want.

10. The plaintiff further submits that, immediately the

plaintiff herein called all the surviving legal heirs of the
deceased Mr.Selvam and informed about the aforesaid
happening and when the plaintiff and her principal
immediately applied an online EC with respect to the
scheduled mentioned property herein on 14.07.2023, to their
ultimate shock and surprise, they came to know about the
fraudulent sale executed by the 2 nd defendant and the father
of the 3rd and 4th defendant herein, where they sold the entire
extent of the scheduled mentioned property without having
any rights to convey the same in favour of the 1 st defendant
herein. It is also further submitted that neither the Plaintiff
herein nor her principals did not know about the execution of
the said fraudulent sale deed until the happening of the
above said event as stated supra and they came to known
about the whereabouts of the fraudulent sale only in the
month of July 2023.
11. The Plaintiff further submits that, thereafter, the plaintiff
along with her principal preferred a complaint before the G-1,
Maduranthakam Police Station against the 1 st defendant
herein with respect to the fraudulent sale and
misappropriation of the scheduled mentioned property with
all relevant documents on 21.07.2023. Since, the 1 st
defendant has very powerful political background, she
influenced the said police with her money and political power
and because of the said influence, the police officials refused
to take the said complaint on file and registered a FIR and
they simply asked the plaintiff and her principals to approach
the Civil Court to try their remedy. Though we have applied
for legal heirship certificate of late.Mr.Selvam before
preferring a police complaint, we have obtained the said
certificate only on 16.08.2023.

12. The plaintiff further submits that, since the plaintiff and
her principal were raised from the very poor family
background and some of them are only a daily wages
employee and remaining some are the house wives and all
were residing in a rental house, they were unable to mobilize
money to initiate a civil suit against the defendants
 immediately and they were facing serious struggle to run
their respective day to day life. Where on the other hand the
plaintiff’s and her principals’ only assert which is the
Scheduled mentioned property herein also been fraudulently
obstructed and encroached by the 1 st Defendant herein by
way of a fraudulent Sale Deed.

13. The Plaintiff states that the Plaintiff have no other alternate
remedy except approaching this Hon’ble Court and the above acts
of the defendants are unjust and the same has to be restrained by
legal clutches. Hence this suit.

14. The Plaintiff submits that the Defendants intention is crystal

clear that 2nd and 3rd defendants are wantonly making such an
unlawful attempt to evict the plaintiff from the Suit schedule
property with the aforesaid Settlement deed and if the
Defendants succeed in there fraudulent attempt, the Plaintiff will
be put to irreparable loss. Hence, it is also just and necessary to
restrain the 2nd and 3rd defendants from further creating
documents, thereby defrauding the Plaintiff.
15. The Plaintiff further submit that, if at all any necessity
arises, the plaintiff and his principal reserve their right to file a
suit for partition among themselves with respect to schedule
mentioned property and the Plaintiff is also entitled to file a suit
against the Defendants herein for claiming damages in respect of
the loss caused to the Plaintiff by the fraud played by the
Defendant No. 1 to 4 upon the Plaintiff. The Plaintiff therefore
crave leave of this Hon’ble Court under Order II, Rule 2 of the
Code of Civil Procedure, 1908, to omit to sue the Defendant No. 1
and 4 in respect of the Plaintiff’s claim for declaration and
damages other claims in respect of same cause of action.
16. The Plaintiff has not filed any civil suit praying similar relief
before this Court and no similar suit is pending before any other
Court of law. The Plaintiff submits that all the above said
fraudulent activities made by the defendants came to knowledge
of the plaintiff only in the month July 2023 when the 1th Defendant
herein started the construction into the plaintiff’s property and
there is no delay and latches on the part of the Plaintiff to prefer
this, Suit.

17. The Plaintiff submits that the cause of action arose well
within the jurisdiction of this Hon’ble Court as the properties
mentioned in the Suit Schedule Property is situated within
the Territorial Jurisdiction of this Hon’ble Court and when
Late.Mr.Selvam, purchased the schedule mentioned property
herein ought of his hard earned money from Mr.Pachaiappan
vide Sale Deed Document No.913/1993 dated 14.07.1993
before SRO Aravambakkam, and the said Mr.Selvam died
intestate on 08.06.2001 leaving behind his legal heir as
shown in abovesaid Family tree, to succussed the scheduled
mentioned property without subjecting the scheduled
mentioned property herein to any mortgage, Lien or
encumbrance and the 2nd defendant along with one
Mr.Sankar @ Sankaralingam, who is the father of the 3 rd and
4th defendant herein, jointly colluded with the 1 st defendant
with the malafide intention to cheat the plaintiff and her
Principals and the said 2nd defendant along with the Sankar @
sankaralingam unilaterally and fraudulently executed a
Registered sale Deed in Document No.203 of 2002 dated
15.02.2002 in favour of the 1st defendant herein before SRO
Avarapakkam with respect to the schedule mentioned
property herein without the knowledge and consent from the
other serving legal heir of the deceased Mr.Selvam, and the
1st defendant kept all her activities in abeyance till the month
of June 2023 without doing anything in the schedule
mentioned property, though she obtained a fraudulent sale
deed in her favour in the year February 2002 and she
suddenly encroached into the Scheduled mentioned property
and started a construction in the scheduled mentioned
property herein in the month of July 2023.and the plaintiff
herein who is residing in the same area, she came to known
about the illegal encroachment made by the 1 st defendant
herein and she rushed to the subject property and asked the
1st Defendant to stop her illegal activities and demanded her
to remove all illegal encroachment in the scheduled
mentioned property and the 1st defendant failed to adhere
any of the demand made the plaintiff and she informed that,
she already purchased the scheduled mentioned property
herein in the year 2002 and claimed herself as a legal owner
of the said property and she chased the plaintiff herein with
the help of gundas by abusing her in very filthy language and
the plaintiff herein called all the surviving legal heirs of the
deceased Mr.Selvam and informed about the aforesaid
happening and when the plaintiff and her principal
immediately applied an online EC with respect to the
scheduled mentioned property herein on 14.07.2023, to their
ultimate shock and surprise, they came to know about the
 fraudulent sale executed by the 2 nd defendant and the father
of the 3rd and 4th defendant herein, where they sold the entire
extent of the scheduled mentioned property without having
any rights to convey the same in favour of the 1 st defendant
herein and the plaintiff along with her principal preferred a
complaint before the G-1, Maduranthakam Police Station
against the 1st defendant herein with respect to the
fraudulent sale and misappropriation of the scheduled
mentioned property with all relevant documents on
21.07.2023. Since, the 1st defendant have very powerful
political background, she influenced the said police with her
money and political power and because of the said influence,
the police officials refused to take the said complaint on file
and registered a FIR and they simply asked the plaintiff and
her principals to approach the Civil Court to try their remedy
and Hence, it is also just and necessary to restrain the 1 st
defendant from further creating documents, thereby
defrauding the Plaintiff and all other subsequent dates and
events are well within the Jurisdiction of this Hon’ble Court
and as such this Hon’ble Court has Jurisdiction to entertain
this case.

18. The Plaintiff values the suit for the purpose of Court fee and
Jurisdiction and for the suit prayer (a) valued for the relief of
Declaration at Rs.5,000/- and pays a court fee of Rs.150/- under
Section 25 of Tamil Nadu Court Fee and Suits Valuation Act and
valued prayer (b) for the Permanent injunction at Rs. 5000/- being
notional value and has paid Rs.150/- under section 27(c) as court
fees and per the Tamil Nadu court fee and suits valuation Act 1955
and valued prayer.
19. The Plaintiffs therefore most respectfully prays that this
Hon’ble Court may be pleased to pass Decree and Judgment in
favour of the Plaintiffs and against the defendants 1 to 3;

(i) For a declaration to declare that the Sale deed dated

15.02.2002 registered as sale Deed in Document No.203
of 2002 on the file of SRO Avarapakkam, the 5th
Defendant herein which is fraudulently executed by the
2nd and father of 3rd and 4th Defendants in respect of the
Suit schedule property as null and void and cancel the
same.

(ii) for a Permanent injunction restraining the Defendant 1 and

her men, agents, servants, relatives, or their attorney/s or
any other persons acting on their behalf or instructions or
claiming right under their, from in any manner alienating or
encumbering or not to enter any deeds with respect to the
suit schedule mentioned property to any third party;
(iii) To direct the Defendants to pay the costs of the suit to the
plaintiff and
(iv) Grant such further or other relief as this Hon’ble court
may deem fit and proper in the circumstances of the case.

Dated at Chennai on this day of November 2024.

COUNSEL FOR PLAINTIFF

PLAINTIFF

VERIFICATION
 I, Mrs.Thulasi, Wife of Mr.Mani, Hindu, Female, aged about 59
years, residing at No.4, Aruthathiyar Street, Kadavampakkam,
Aavalippur Post, Tindivanam, Villupuram- 604101, I declare that
what are all stated and submitted in the above paragraphs from 1
to 19 are true and correct to the best of my knowledge and
correct information on my belief and I believe the same to be
true.

Verified at Chennai on this day of November 2024.

Plainti
ff

LIST OF DOCUMENTS

S Dat DESCRIPTION OF REMA

. e DOCUMENTS RKS
N
o
1 14.0 Sale Deed Document Certifi
. 7.19 No.913/1993 dated ed
93 14.07.1993 in favour of Late copy
Mr.Selvam
2 04.1 Death Certificate of Xerox
. 1.19 Pushpalingam
80
3 13.0 Death Certificate of Jothi Xerox
. 1.19
 86
4 26.0 Death Certificate of Nagaraj Xerox
. 4.19
96
5 03.0 Death Certificate of Xerox
. 6.19 Paramasivam
94
6 08.0 Death Certificate of Selvam Xerox
. 6.20
01
7 29.0 Death Certificate of Xerox
. 1.20 Patchaiammal
02
8 15.0 sale Deed in Document Certifi
. 2.20 No.203 of 2002 in favour of 1st ed
02 Defendant copy
9 21.0 Death Certificate of Xerox
. 6.20 Sankaralingam
08
1 21.0 Police Complaint made by the Xerox
0 7.20 plaintiff
. 23
1 02.0 Death Certificate of Raja Xerox
1 4.20
. 19
1 16.0 Legal heirship Certificate Xerox
2 8.20
. 23
1 199 Encumbrance Certificate Certifi
3 3 to ed
 . 202 copy
4
1 11.0 Power of Attorney Deed in Origin
4 9.20 favour of Plaintiff al
. 23

LIST OF DOCUMENTS FILED UNDER ORDER VII RULE 14(2)

CPC
- Nil at Present -

Dated at Chennai on this day of November 2024.

Counsel for Plaintiff

Plaintiff

VERIFICATION
I, Mrs.Thulasi, Wife of Mr.Mani, Hindu, Female, aged
about 59 years, residing at No.4, Aruthathiyar Street,
Kadavampakkam, Aavalippur Post, Tindivanam, Villupuram-
604101, the Plaintiff herein do hereby declare that whatever
submitted in the List of Documents are true to my knowledge,
belief and information.

Dated at Chennai on this day of November 2024

Plainti
ff
 SUIT SCHEDULE PROPERTY

All the piece and parcel of land to the extent of 0.04

Cents (1744 Sq.Ft) situated in Villupuram District,
Tindivanam Taluk, Kadavambakkam Village, comprised in Old
Survey No.380/10, New Survey No.100/14A, within the Sub
Registration District of Aravambakkam and there abouts
bounded as follows:

North : Kalam Purambokku

South : A. Ko. Punjai Land
East : Poongan Po Mangaiammal Punjai Land
West : A.Ko. Punjai Land

Counsel for Plaintiff

Plaintiff

STATEMENT OF ADDRESSE UNDER ORDER VI RULE 14 (A)

C.P.C.

Name and Address of the Plaintiff : 1. Poongothai,

F/63yrs
wife of Mr.Subramaniyan,
daughter of Late.Mr.Selvam,
residing at No.255, 8th Block,
Udhayasuriyan Nagar,
Vyasarpadi, Chennai-600 039.
2. Mrs.Maha, F/56 yrs,
wife of Mr.Mahalingam,
daughter of Late.Mr.Selvam,
residing at No.220,
 Arunthathiyar Street,
Kadavambakkam,
Villupuram-604101.
3. Mr.Kudiyarasu, M/49 yrs,
son of Late.Mr.Selvam,
residing at No.413,
C- Kalyanapuram 2nd Street,
Vyasarpadi, Chennai-600 039
4. Mr.Rajesh, M/38 yrs,
son of Late.Mr.Raja,
residing at No.347,
C- Kalyanapuram 5th Street,
Vyasarpadi, Chennai-600039.
5. Mrs.Ramani, F/36 years,
wife of Mr.Chinnadurai,
daughter of Late.Mr.Raja,
residing at No.58,
C-Kalyanapuram 1st Main Road,
Vyasarpadi, Chennai-600 039.
6. Mrs.Uma, F/54 yrs,
wife of Late.Mr.Raja,
residing at 347, C-Kalyanapuram,
5th Street, Vyasarpadi, Chennai-600
039.
7. Mrs.Divya, F/33 yrs,
wife of Mr.Dillibabu,
daughter of Late.Mr.Paramashivam,
residing at No.243, C- Kalyanapuram
Main Street,
Vayasarpadi, Chennai-600 039.
8. Mrs.Dhivina, F/32 yrs,
wife of Mr.Sudhakar,
daughter of Late.Mr.Paramashivam,
residing at No.127, D’Block,
Malligapoo Colony, Vayasarpadi,
Chennai-600 039.
9. Mrs.Renuga @ Renugadevi, F/47
yrs,
wife of Mr.Sundaramoorthy,
daughter of Late.Mr.Pushpalingam,
 No.48, Manamman Koil Street,
Boomiapet, Pondicherry- 605 005.
10. Mr.Thirunavukarasu, M/45 yrs,
son of Late.Mr.Pushpalingam,
residing at No.7, 2nd Cross Street,
Rajayar Thottam, Kuyavarpalayam,
Saram,
Puducherry- 605013.
11. Mrs.Thenmozhi, F/69 yrs,
wife of Late.Mr.Pushpalingam,
residing at No.48, Mariamman Koil
Street,
Boomianpet, Pondicherry-605005.
12. Mrs.Eswari, F/49 yrs,
wife of Mr.Santhosh Kumar,
daughter of Late.Mrs.Jothi,
residing at No.14, Iyyanar Koil Street,
Vishnu Nagar. Karuvadikuppam,
Lawspet, Puducherry- 605008,
13. Mrs.S.Mageswari, F/47 yrs,
wife of Mr.Saravanan,
daughter of Late.Mrs.Jothi,
residing at No.16, Ezhal Mariamman
Koil Street,
Kuyavarpalayam, Saram,
Pondicherry-605013
14. Mr.A.S.Shanmugam, M/41 yrs,
son of Subrayan,
residing at No.14, Iyyanar Koil Street,
Vishnu Nagar. Karuvadikuppam,
Lawspet, Puducherry- 605008
15. Mrs.Thulasi, F/58 yrs,
Wife of Mr.Mani,
No.4, Aruthathiyar Street,
Kadavampakkam,
Aavalippur Post, Tindivanam,
Villupuram- 604101

Plaintiff’s Counsel : M/s. C. Ruban Dsilva,

M. Benazir Begum,
P.Gopinath and
 C.Immanvel, Advocates,
having office at No. 6,
Sundaram Main Road,
Vyasarpadi, Chennai-
600039.

Name and Address of the Defendants : 1. Mrs.Megala,

W/o. Mr.Sekar,
Residing at Aruthathiyar Street,
Kadavampakkam,
Aavalippur Post, Tindivanam,
Villupuram- 604101.
2. S.Krishnasamy, M/72yrs
son of Late.Mr.Selvam,
residing at No.2/5, 2nd Floor,
Eswar Enclave, Pillaiyar Koil Street,
Kalaignar Karunanidhi Nagar,
Chennai-600 078.
3. Mrs.Rajeswari, F/47 yrs,
wife of Mr.Ezhumalai,
D/o Late.Mr.Shankar @
Sankaralingam,
residing at No.124, 4th Street,
J.J.Nagar, Vyasarpadi,
Chennai-600 039.
4. Mr.Vijayakumar, M/41 yrs,
son of Late.Mr.Shankar @
Sankaralingam,
residing at No.7,
Jeevanantham Street,
Soozhpunal Karai, Erukkancheri,
Koduingayur, Chennai-600 118
5. The Sub-Registrar,
Avarapakkam,
Tindivanam.
VERIFICATION

I do hereby declare and verify and submits that the averments

submitted in the Statement of Addresses above is true to the best
of my knowledge and belief.
 Verified at Chennai on this day of November 2024.

Plaintiff
Memo of Valuation

1. Value of the 1st prayer in the suit :

Rs.5,000/-
2. Court fee paid on the 1st prayer in the suit :
Rs.150/-
3. Value of the 2nd prayer in the suit : Rs.5,000/-
4. Court fee paid on the 2nd prayer in the suit :
Rs.150/-
5. Total court fees paid in the suit : Rs.300/-
Dated at Chennai on this day of November 2024.

Counsel for
Plaintiff

IN THE COURT OF SUB COURT, JUDGE

AT TINDIVANAM
O.S.NO. OF 2024

1. Poongothai, F/63yrs
& 14 others
represented
by their Power Agent,
Mrs.Thulasi,
 …Plaintiff
Verses
1.Mrs.Megala,
W/o. Mr.Sekar,
& 4 others
…Defendants

PLAINT FILED UNDER

ORDER VII RULE 1 OF
C.P.C.

M/s. C. Ruban Dsilva,

Ms.2000/15
M. Benazir Begum,
2192/15
P.Gopinath
C.Immanvel , Ms.3373/21
COUNSEL FOR PLAINTIFF