IN THE COURT OF DISTRICT MUNSIF AT ALANDUR

O.S.NO. of 2021

U.Dhanalakshmi
W/o. P.Umashankar @ Sadhasivam
No.957, 12th Cross Street,
Dr.Ambedkar Nagar, Adambakkam
Chennai- 600 088 ... Plaintiff

-Vs-

1. R.Selvanayagi
W/o. Late Ramanathan
2. P.Bhuvaneshwari
W/o. Paneerselvam
3. P.Sathya
D/o. Paneerselvam
4. S.Nandakumar
S/o. Selvaganapathy
All are residing at
No.957, 12th Cross Street
Dr.Ambedkar Nagar, Adambakkam
Chennai – 600 088.
…. Defendants

MEMO OF VALUATION

1.Nature of the suit : Suit for ejectment

2.Suit valued at : NIL
3.Section& sub Section : Under section 42(e) of T.N.C.F&S.V.Act
4.Court Fee paid is : Rs.100/-

Dated at Alandur on this the day of September, 2021

Counsel for plaintiff Plaintiff

 IN THE COURT OF DISTRICT MUNSIF AT ALANDUR

O.S.NO. of 2021

U.Dhanalakshmi
W/o. P.Umashankar @ Sadhasivam
No.957, 12th Cross Street,
Dr.Ambedkar Nagar, Adambakkam
Chennai- 600 088 ... Plaintiff

-Vs-

1. R.Selvanayagi
W/o. Late Ramanathan
2. P.Bhuvaneshwari
W/o. Paneerselvam
3. P.Sathya
D/o. Paneerselvam
4. S.Nandakumar
S/o. Selvaganapathy
All are residing at
No.957, 12th Cross Street
Dr.Ambedkar Nagar, Adambakkam
Chennai – 600 088.
…. Defendants

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

The above-named Plaintiff respectfully begs to state as follows:

1. The Plaintiff is U.Dhanalakshmi, W/o. P.Umashankar @ P.Sadhasivam,

Hindu, aged about 41 years, residing at No.957, 12 th Cross Street,
Dr.Ambedkar Nagar, Adambakkam, Chennai – 600 088, Adambakkam
Village, Alandur Firka, Alandur Taluk, which falls within the jurisdiction of
this Hon’ble Court.
The Address for service of all process and notices on the petitioner is that of
his counsel M/s. V.Karnan, S.Krishnamoorthy, Thenraj, K.Ramesh &
M.Sushma having office at Old No.127, New No.261, Rohith Tower, 2 nd
Floor, Angappa Naicken Street, George Town, Chennai – 600 001.

2. The Defendants are 1.R.Selvanayagi, W/o. Late Ramanathan, aged about

80 years, 2. P.Bhuvaneshwari, W/o. Paneerselvam, aged about 50 years,
3. P.Sathya, D/o. Paneerselvam, aged about 21 years, 4. S.Nandakumar,
 -2-
S/o. Selvaganapathy, aged about 22 years, all are residing at No.957, 12 th
Cross Street, Dr.Ambedkar Nagar, Adambakkam, Chennai – 600 088,
Adambakkam Village, Alandur Firka, Alandur Taluk, which falls within the
jurisdiction of this Hon’ble Court.
The address of the Defendant for services of process and notices is
the same as stated above.
3. The Plaintiff submits that she is the absolute owner of the suit premises
bearing No.957, 12th Cross Street, Dr.Ambedkar Nagar, Adambakkam,
Chennai – 600 088. The suit premises consist of 2 floors, namely ground
floor and first floor hereafter said to be the A Schedule portion in the suit
premises and Terrace portion in the 2nd Floor hereafter said to be the B
Schedule portion in the suit premises. The said suit property was purchased
by the plaintiff from one Mr.Thirunavukarasu, S/o. Late Kuppusamy in the
year 2005 for a valid sale consideration of Rs.25,000/- (Rupees Twenty Five
Thousand Only) and ever since the date of purchase the plaintiff is in
continuous possession and enjoyment of the schedule property.
4. The Plaintiff states that the 1st Defendant is the mother of the plaintiff, 2 nd
Defendant is the sister of the plaintiff, 3 rd Defendant is the daughter of the
2nd defendant and 4th Defendant is the son of another sister
Mrs.Vijayalakshmi of the plaintiff. The plaintiff states that her father
Ramanathan died in the year 1998 and he owned a property in Adyar,
Chennai at the time of his death. The Plaintiff further state that in the year
2001 my client was married to one Sadhasivam and stayed with her husband
in Salem and she has a male child born out of their wedlock, Whereas in the
year 2003, the 1st Defendant decided to sell the property in Adyar belonged
to Late Ramanthan and out of the total sale consideration an amount of
Rs.1,75,000/- (Rupees One Lakh Seventy Five Thousand Only) was given
to the plaintiff as her share in the property.
5. The plaintiff states that 1st Defendant was residing in Adyar for rent after the
disposal of the property belonging to Late Ramanathan in the year 2003 and
after the purchase of the suit schedule property in the year 2005 by the
 -3-

plaintiff, the 1st defendant requested the plaintiff to allow her to stay in the
schedule property, as she is unable to pay rent and out of pity the plaintiff
also let her to stay in the schedule property at a roof house in the terrace. It
is also stated by the plaintiff that since the plaintiff was staying with her
husband Sadhasivam and her son in Salem, she gave all the documents
related to the below schedule property to the 1 st defendant only out of belief
and trust she had on her. It is further stated by the plaintiff that
Mrs.Vijayalakshmi the mother of 4th defendant, who is also the sister of the
plaintiff came to Plaintiff in the year 2016 and requested the plaintiff to
permit the 4th defendant to stay in the B schedule portion of the suit
property for few months with the 1st defendant stating the reason for the
education purpose of the 4th defendant, on seeing the pathetic situation, the
plaintiff has permitted him to stay for few months and further in the year
2017, the 2nd Defendant entered into the schedule property along with her
daughter the 3rd Defendant and requested the plaintiff to permit them to stay
along with the 1st defendant in B schedule portion of the suit property
the plaintiff has permitted all of them to stay for few months and they
assured to vacate the portion immediately if they found a suitable
accommodation.

6. The Plaintiff states that in the year 2018, the plaintiff decided to sell the
below scheduled property due to her financial difficulties faced by her and
in the month of October 2018 the plaintiff orally demanded the Defendants
to vacate and hand over the vacant portion, for which the Defendants agreed
to vacate the portion, later started to create problems and further they started
to demand illegal money in order to evict the premises under permissible
occupation. It is further stated by the plaintiff that the defendants 2,3 and 4
by using the 1st Defendant had given number of false police complaints as
against the plaintiff demanding illegal money to vacate the B schedule
portion of the suit property, the Plaintiff had repeatedly requested them to
 -4-

vacate and hand over the vacant portion of B Schedule property. It is

stated by the plaintiff that to her shock and surprise she received a summons
in O.S. No.214 of 2021 from The Hon’ble District Munsif Court at Alandur
and came to know that the defendants 1,2 & 4 filed the above suit with false
allegations and the above suit is not maintainable either in fact and law.

7. The plaintiff states that it is false to state that that the defendants 1,2 & 4
residing in the B schedule portion in the below scheduled property for past
more than 15 years without giving any disturbance and trouble to the
plaintiff and the defendants are put to strict proof for the same. The plaintiff
states that as already stated above the defendants 1 to 4 are permitted to stay
in the portion of the below scheduled property on good faith, when the
plaintiff wanted to sell the suit premises due to financial crisis faced by the
plaintiff she demanded all the defendants 1 to 4 to vacate the portion of the
below scheduled property permitted the plaintiff for defendant 1 and 4 to
occupy the suit premises for a short period and the same was extended
periodically, instead of vacating the B schedule portion of below scheduled
property the defendants 1 to 4 filed the above suit with false and frivolous
allegations against the plaintiff.

8. The plaintiff states that it is false to state that 1 st defendant purchased the
below scheduled property for a valuable consideration of Rs. 25,000/-
(Rupees Twenty-Five Thousand) from the amount of Rs. 2,00,000/-(Rupees
Two Lakhs) which was given by 1 st defendant to the plaintiff and 1 st
defendant have to put strict proof for the same. It is also stated by the
plaintiff that the below scheduled property was purchased by the plaintiff
from one Mr.Thirunavukarasu, S/o. Late Kuppusamy in the year 2005 for a
valid sale consideration of Rs.25,000/- (Rupees Twenty Five Thousand) out
of her share money as stated above.

9. The plaintiff states that it is false to state that all of a sudden in the year of
2005, the plaintiff came to the 1st Defendant’s residence along with her 6
year old son and she told to the 1st Defendant that she will not live with her
 -5-

husband Sadhasivam at Salem due to some family dispute among them,

therefore 1st Defendant felt pity on the plaintiff and her 6 year old son on
the humanitarian ground, then 1 st Defendant decided to construct a house in
the below mentioned property from the amount of Rs. 12,00,000/-(Rupees
Twelve Lakhs) which was already in her hand through her own sale
consideration and 1st defendant started to construct a house in the year 2005
and 2006 for which she spent more than 10 lakhs consisting ground floor,
first floor and a roof house in the terrace and 1 st Defendant is put to strict
proof for the same. Further the allegation of 1 st Defendant started spending
her money and construct a house in the year 2005 and 2006 for which she
spent more than 10 lakhs consisting ground floor, first and second floor are
absolutely false. Further all the defendants 1 to 4 had created forged, bogus
construction material receipts for the purpose of the above suit and the same
is illegal and unlawful and against the established provisions of law.

10. The plaintiff also states that it is false to state that plaintiff and her husband
colluded each other, tried to evict defendants 1,2 & 4 from the portion of the
below mentioned property from the year 2018 onwards with view to defraud
and defeat the defendants and it is their right to receive amount of Rs.
10,00,000/- (Rupees Ten Lakhs) from the plaintiff and her husband which
was spent for constructing a house in the below mentioned schedule
property by 1st Defendant. As already stated above 1st Defendant had never
spent any money towards the construction of house in the below scheduled
property and therefore the allegation of defraud and defeat all of their right
to receive amount of Rs. 10,00,000/- (Rupees Ten Lakhs) from the plaintiff
and her husband which was spent for construct a house in the below
mentioned schedule property by 1st defendant was absolutely false. It is
stated that after the plaintiff asked and demanded the defendants 1 to 4 to
vacate from the permissible occupation of the portion of the below
scheduled premises, the defendants 1 to 4 colluded together by suppressing
true facts filed the above suit for illegal gain and the defendants 1 to 4 had
not approached the court with clean hands and the above suit is vexatious.
 -6-

11. The plaintiff states that it is false to state that on 11.10.2018 the defendants
had given a police complaint as against the plaintiff to return the amount
which was spent by 1st Defendant to construct a house in the below A and B
schedule portion of the suit property and Police officers namely Inspector
Mr. Murali and Sub Inspector Mrs. Devika had conducted an enquiry in
which the plaintiff accepted to pay Rs. 6,00,000/-(Rupees Six Lakhs) and
for the same she had given a letter to 1 st Defendant but till today the plaintiff
has not paid the said amount and hence the defendants has given several
complaints dated 05.02.2019, 25.08.2019. 9.06.2020 and finally on 36.-
05.2021 and the plaintiff and her husband are trying to evict all of you
instead of paying the amount of Rs. 6,00,000/- (Rupees Six Lakhs). It is
already stated above that the 1 st Defendant had never spent any money
towards the construction of house in the below scheduled property, therefore
the demand of return of money spent for construct house was not
maintainable under principles of established provisions of law. It is stated
by the plaintiff that only after she asked and demanded all the defendants 1
to 4 to vacate from the permissible occupation of the portion of the below
scheduled premises, the defendants 1 to 4 colluded together by suppressing
true facts had given a false complaint before the police and influenced them,
under the guise of enquiry the police act against procedural law and
conducted Kangaroo court and forced the plaintiff to give a letter under
threat, force and coercion and the same has not binding on the plaintiff,
since the letter was obtained by force, threat and coercion in police station
therefore the letter was void document and the same was illegal, unlawful
and against the principles of established provisions of law. Further the
allegation of Defendants has given several complaints dated 05.02.2019,
25.08.2019. 9.06.2020 and finally on 36.05.2021 and the plaintiff and her
husband are trying to evict the defendants 1 to 4 instead of paying the
amount of Rs. 6,00,000/- (Rupees Six Lakhs) was false, frivolous and
vexatious.
 -7-

12. The plaintiff states that it is false to state that in the month of February
2021, the plaintiff requested 4th Defendant to prepare a documents for the
reasons that now she is ready to pay of Rs. 3,00,000/- (Rupees Three Lakhs)
to 1st defendant and rest of amount of Rs. 3,00,000/- (Rupees Three Lakhs)
will be paid within 90 days and as per instructions 4 th Defendant prepared
and requested her signature in the said document but she refused to sign the
same. It is already stated above in the year 2018, that the plaintiff decided to
sell the below scheduled property due to her financial difficulties and in the
month of October 2018 the plaintiff orally demanded the defendants 1 and 4
to vacate and hand over the vacant portion in B Schedule portion of the suit
property, and the defendants 1 and 4agreed to vacate the portion but started
created problems and also started to demand illegal money to evict the
permitted portion of occupation. Further all the defendants 1 to 4 on
knowing the plaintiff’s financial situation and she is trying to sell the below
scheduled property to come out from the financial crisis for illegal money
all of you colluded and towards their illegal gain threatened the plaintiff to
sign in certain papers and when the plaintiff rightly refused to sign the
documents which was created by all the defendants 1 to 4 for illegal money
and the said act of all defendants 1 to 4 are unlawful and illegal. Further all
defendants 1 to 4 threatened the plaintiff that they will not vacate and hand
over the vacant possession of the permitted portion under the defendants
occupation if the plaintiff will not pay the illegal money as demanded by the
defendants and their act of not vacating the permitted portion of occupation
is illegal, unlawful and against the established principles of law.

13. The plaintiff states that it is false to state that in the meantime the plaintiff is
ready to sell away the below mentioned scheduled property to one
Manoharan and she has also received advance amount of Rs. 7,50,000/-
(Rupees Seven Lakhs and Fifty Thousand) from him and on 05.06.2021
onwards the plaintiff and her husband and the above said Manoharan are
threatening the defendants to vacate the permitted portion under their
occupation, further they will take forceful illegal methods to evict the
 -8-

defendants through rowdy elements, the defendants having entitle to reside

in the permitted portion under their occupation, hence the defendants cannot
be evicted from the permitted portion under their occupation except
following due process of law. Further it is false to state that if the defendants
are evicted from the permitted portion under their occupation, it is very
difficult for them to reside anywhere else because 1 st Defendant has spent
money for purchasing and to construct a house in the below A and B
schedule portion in the scheduled property, all the above persons are making
lot of trouble to defendants and from 05.06.2021 onwards with a view to
evict all of the defendants from the permitted portion under their
occupation, the above said Manoharan represented before the defendants
that he has purchased the below scheduled property and further threatening
the defendants to vacate the permitted portion under their occupation
without delay, further the above said persons interfered with the possession
and enjoyment of permitted portion under the defendants occupation. The
true fact was that the above said Manoharan was no way connected with the
below mentioned scheduled property and the plaintiff and her husband and
the above Manoharan were not threatened to evict the defendants illegally to
vacate the permitted portion under their occupation at any point of time and
also they were not taken any illegal and unlawful steps to evict the
defendants illegally to vacate the permitted portion under their occupation at
any point of time. The above false and frivolous allegations are tactically
drafted by the defendants to deceive the court for illegal gain. As already
stated above the plaintiff is the absolute owner of the below scheduled
property and the same was purchased by the plaintiff from one
Mr.Thirunavukarasu, S/o. Late Kuppusamy in the year 2005 for a valid sale
consideration of Rs.25,000/- (Rupees Twenty Five Thousand) out of her
own income and from her savings and thereby she is having every right to
sell the property and the defendants doesn’t have any title, share or interest
in the below B schedule portion of the schedule mentioned property and
the defendants 1 and 4 were permitted by my client to stay in the above
 -9-

portion under good faith and the defendants are taking advantage of my
client’s good faith and failed to vacate the premises under their occupation
even after repeated demands, therefore their permissive occupation was
terminated in the month of October 2018 itself, the defendants occupation in
the above B schedule portion in the below mentioned scheduled property is
unlawful and illegal.

14. The plaintiff states that as already stated above the plaintiff is the absolute
owner of the below scheduled property and the defendants 1 and 4 were
permitted by the plaintiff to stay in the above portion under good faith but
later defendants 2 and 3 entered the suit premises and accompanied the
other defendants, but they misused her good faith and failed to vacate the B
schedule portion in the schedule premises under their occupation even after
repeated demands, therefore the defendants permissive occupation was
terminated in the month of October 2018 itself and instead of vacating the
above portion permitted by the plaintiff to stay defendants 1 and 4 along
with defendants 2 and 3 filed a false, vexatious and malicious suit to deprive
the plaintiff’s right in the below scheduled property, the above suit is not
maintainable under the eye of law.

15. The cause of action for the suit arose in the year 2005 at No.957, 12 th Cross
Street, Dr.Ambedkar Nagar, Adambakkam, Chennai – 600 088,
Adambakkam Village, Alandur Firka, Alandur Taluk, which falls within the
jurisdiction of this Hon’ble Court, when the plaintiff purchased the said suit
property from Mr.Thirunavukarasu and later permitted the defendant 1 and
4 to stay in the B schedule portion of the suit premises and due to financial
difficulties the plaintiff requested the defendant 1 and 4 to vacate the suit
premises in order to sell the suit property, later the defendants 2 and 3
entered the B schedule portion in the suit premises and joining hand in
gloves with the other defendants and threatened the plaintiff by claiming
illegal money for vacating the suit premises by giving false complaints and
 -10-
also by filing a civil suit in the Hon’ble Court of District Munsif at Alandur
as O.S.No.214 of 2021 and when the plaintiff availed legal advice, she was
advised to approach the Court and Hence this suit filed before this Hon’ble
Court for justice.
16. The Plaintiff valued the suit for the purpose of court fee and pecuniary
jurisdiction and notionally valued the suit at NIL and pays a court fee of
Rs.100/- under section 42 ( e ) of Tamil Nadu Court Fee and Suits Valuation
Act, 1955 (Amended Act 2003).

17. The Plaintiff therefore hereby prayed that this Hon’ble Court may be
pleased to pass a decree and judgment in favour of the plaintiff and as
against the defendants 1 to 4that;

a. Directing the Defendants 1 to 4 to vacate and hand over vacant possession

of the B Schedule portion of the suit premises to the Plaintiff;
b. For the costs of this suit and;

c. for such other relief or reliefs as this Hon’ble Court may deem fit and proper
in the circumstances of this case and thus render justice.

Dated at Alandur on this the day of September, 2021

COUNSEL FOR PLAINTIFF PLAINTIFF

VERIFICATION

I, U.Dhanalakshmi, W/o. P.Umashankar @ P.Sadhasivam, the plaintiff, do

hereby solemnly and sincerely affirm and state that the above contents are true and
correct to the best of my knowledge, belief and information.

Verified at Alandur on this the day of September, 2021

 -11-

COUNSEL FOR PLAINTIFF PLAINTIFF

SCHEDULE OF PROPERTY

‘A’ SCHEDULE PROPERTY

All that piece and parcel of land situated at Ground Floor and First floor at
No.957, 12th Cross Street, Dr.Ambedkar Nagar, Adambakkam, Chennai – 600 088,
Adambakkam Village, Alandur Firka, Alandur Taluk, which falls within the
jurisdiction of this Hon’ble Court.
‘B’ SCHEDULE PROPERTY

All that piece and parcel of land situated at Second floor Terrace portion at
No.957, 12th Cross Street, Dr.Ambedkar Nagar, Adambakkam, Chennai – 600 088,
Adambakkam Village, Alandur Firka, Alandur Taluk, which falls within the
jurisdiction of this Hon’ble Court.

COUNSEL FOR PLAINTIFF PLAINTIFF

VERIFICATION

I, U.Dhanalakshmi, W/o. P.Umashankar @ P.Sadhasivam, the plaintiff, do

hereby solemnly and sincerely affirm and state that the above address are true and
correct to the best of knowledge, belief and information.
Verified at Alandur on this the day of September, 2021

COUNSEL FOR PLAINTIFF PLAINTIFF

 -12-

LIST OF DOCUMENTS FILED BY THE PLAINTIFF UNDER ORDER VII

RULE 14(1) OF C.P.C

-------------------------------------------------------------------------------------------
S.No. Date Description of Documents Remarks
-------------------------------------------------------------------------------------------
1. Allotment issued by TNSCB to
Mr.Thirunavukarasu Xerox

2. 07.02.2001 Sale Agreement entered between

Mr.Thirunavukarasu and Plaintiff Xerox

3. 26-10-2005 Approval of electricity connection

to the plaintiff by TNSCB Xerox

4. 08.02.2006 Receipt issued by Chennai

Metropolitan Water Supply and
Sewerage Board Xerox

5. 30.05.2007 Name change of plaintiff husband

Published in TamilNadu
Government Gazette Xerox

6. Aadhaar Card of the Plaintiff Xerox

7. Ration card of the Plaintiff Xerox

8. 30.01.2019 Receipt issued

By TNSCB Xerox

Dated at Alandur on this the day of September, 2021

Counsel for plaintiff Plaintiff

 -13-
MEMO OF VALUATION
1.Nature of the suit : Suit for ejectment
2.Suit valued at : NIL
3.Section& sub Section : Under section 42(e) of T.N.C.F&S.V.Act
4.Court Fee paid is : Rs.100/-

Counsel for plaintiff Plaintiff

 IN THE COURT OF THE DISTRICT
MUNSIF AT ALANDUR

O.S.No. of 2021

U.Dhanalakshmi
...Plaintiff

-Vs-

R.Selvanayagi & Others

...Defendants

PLAINT FILED UNDER ORDER

VII RULE 1 OF C.P.C.

M/s. V.Karnan
S.Krishnamoorthy
Thenraj
K.Ramesh (1801/2016)
Counsels for Plaintiff
Ph: 9003308644
 IN THE COURT OF DISTRICT MUNSIF AT ALANDUR

O.S.No of 2021

U.Dhanalakshmi
.... Plaintiff

-Vs-

1. R.Selvanayagi
2. P.Bhuvaneshwari
3. P.Sathya
4. S.Nandakumar
…. Defendants

PROOF AFFIDAVIT OF U.DHANALAKSHMI

I, U.Dhanalakshmi, W/o. P.Umashankar @ P.Sadhasivam, Hindu, aged about

41years, residing at No.957, 12th Cross Street, Dr.Ambedkar Nagar, Adambakkam,
Chennai – 600 088, Adambakkam Village, Alandur Firka, Alandur Taluk, which
falls within the jurisdiction of this Hon’ble Court, do hereby solemly affirm and
state as follows:
1. I am the petitioner herein, and the Plaintiff in the above suit and as such I
am well acquainted with the facts of the case.
2. I state that I have filed the above suit to direct the Defendants 1 to 4 to
vacate and hand over vacant possession of the B Schedule portion of the
suit premises to the Plaintiff in No.957, 12 th Cross Street, Dr.Ambedkar
Nagar, Adambakkam, Chennai – 600 088;
3. This Hon’ble Court may be pleased to pass a Decree and Judgment in
favour of the Plaintiff and there are no controversies and no prejudice will
be caused to anyone in the above mentioned suit.
I, therefore hereby declare that the facts stated in pleadings are correct
and I pray this Hon’ble court may number the suit and pass further orders in
the interest of justice.

Solemnly affirm and signed at Before Me

Alandur on this day of
September, 2021
 Advocate, Alandur

IN THE COURT OF THE DISTRICT

MUNSIF AT ALANDUR

O.S.No. of 2021

U.Dhanalakshmi
...Plaintiff

-Vs-

R.Selvanayagi & Others

...Defendants

PROOF AFFIDAVIT OF
U.DHANALAKSHMI

M/s. V.Karnan
S.Krishnamoorthy
Thenraj
K.Ramesh (1801/2016)
Counsels for Plaintiff
 Ph: 9003308644

IN THE COURT OF DISTRICT MUNSIF AT ALANDUR

O.S.No of 2021

U.Dhanalakshmi ... Plaintiff

-Vs-
1. R.Selvanayagi
2. P.Bhuvaneshwari
3. P.Sathya
4. S.Nandakumar …. Defendants

VERIFIED AFFIDAVIT OF U.DHANALAKSHMI

I, U.Dhanalakshmi, W/o. P.Umashankar @ P.Sadhasivam, Hindu, aged
about 41years, residing at No.957, 12th Cross Street, Dr.Ambedkar Nagar,
Adambakkam, Chennai – 600 088, Adambakkam Village, Alandur Firka, Alandur
Taluk, which falls within the jurisdiction of this Hon’ble Court. The address for
service of the Plaintiff is the same as mentioned above.

I am the deponent herein and I am well acquainted with the facts of this case
and I am filing this affidavit. I crave leave of this Hon’ble court may read the
plaint averments as part and parcel of this affidavit.

I Submit that I have filed the above suit to direct the Defendants 1 to 4 to
vacate and hand over vacant possession of the B Schedule portion of the suit
premises to the Plaintiff in No.957, 12th Cross Street, Dr.Ambedkar Nagar,
Adambakkam, Chennai – 600 088. This Hon’ble Court may be pleased to pass a
Decree and Judgment in favour of the Plaintiffs and there are no controversies
and no prejudice will be caused to anyone in the above mentioned suit. Hence file
the present suit and I read the pleadings carefully which is according to my
instructions.
I, therefore hereby declare that the document filed along with plaint only
available documents and I pray this Hon’ble court may be number this suit and
pass further orders in the interest of justice.

Solemnly affirm and signed at Before Me

Alandur on this the day of
September, 2021

Advocate, Alandur
 IN THE COURT OF THE DISTRICT
MUNSIF AT ALANDUR

O.S.No. of 2021

U.Dhanalakshmi
...Plaintiff

-Vs-

R.Selvanayagi & Others

...Defendants

VERIFIED AFFIDAVIT OF
U.DHANALAKSHMI

M/s. V.Karnan
S.Krishnamoorthy
Thenraj
K.Ramesh (1801/2016)
Counsels for Plaintiff
Ph: 9003308644
 IN THE COURT OF DISTRICT MUNSIF AT ALANDUR

O.S.NO. of 2021

U.Dhanalakshmi
W/o. P.Umashankar @ Sadhasivam
No.957, 12th Cross Street,
Dr.Ambedkar Nagar, Adambakkam
Chennai- 600 088 ... Plaintiff

-Vs-

1. R.Selvanayagi
W/o. Late Ramanathan
2. P.Bhuvaneshwari
W/o. Paneerselvam
3. P.Sathay
D/o. Paneerselvam
4. S.Nandakumar
S/o. Selvaganapathy
All are residing at
No.957, 12th Cross Street,
Dr.Ambedkar Nagar, Adambakkam
Chennai- 600 088 …. Defendants

AFFIDAVIT OF U.DHANALAKSHMI

I, U.Dhanalakshmi, W/o. P.Umashankar @ P.Sadhasivam, Hindu, aged

about 41years, residing at No.957, 12th Cross Street, Dr.Ambedkar Nagar,
Adambakkam, Chennai – 600 088, do hereby solemnly affirm and sincerely state
as follows :-
1. I am the petitioner here in, and the Plaintiff in the above suit and as such I
am well acquainted with the facts of the case.
2. I state that I have filed the above suit to direct the Defendants 1 to 4 to
vacate and hand over vacant possession of the B Schedule portion to the
Plaintiff in No.957, 12th Cross Street, Dr.Ambedkar Nagar, Adambakkam,
Chennai – 600 088 and direct the defendants to pay the cost of the suit.
3. I humbly submit that the plaint may be numbered on urgent basis due to
financial difficulties faced by the plaintiff and the plaintiff is depending
solely on the suit premises to set out the debts incurred by her by selling the
suit premises, hence, filing this suit on urgent basis, so that injunction order
may be granted by this Hon’ble Court in order to evict the defendants.
4. I, therefore hereby pray that this Hon’ble court maybe pleased to treat the
suit as urgent and number the suit and pass further orders in the interest of
justice.

Solemnly affirm and signed at Before Me

Alandur on this the day of
September, 2021

Advocate, Alandur
 IN THE COURT OF DISTRICT MUNSIF AT ALANDUR

O.S.NO. of 2021

U.Dhanalakshmi
W/o. P.Umashankar @ Sadhasivam
No.957, 12th Cross Street,
Dr.Ambedkar Nagar, Adambakkam
Chennai- 600 088 ... Plaintiff

-Vs-

1. R.Selvanayagi
W/o. Late Ramanathan
2. P.Bhuvaneshwari
W/o. Paneerselvam
3. P.Sathya
D/o. Paneerselvam
4. S.Nandakumar
S/o. Selvaganapathy
All are residing at
No.957, 12th Cross Street,
Dr.Ambedkar Nagar, Adambakkam
Chennai- 600 088 …. Defendants

URGENTPETITION FILED UNDER SECTION 151 OF CIVIL

PROCEDURE CODE

For the reasons stated in the accompanying affidavit it is prayed that this

Hon’ble court may be pleased to treat the plaint as urgent and pass such other

suitable order or orders in the interest of justice.

Dated at Alandur on this the day of September, 2021

Counsel for Petitioner/Plaintiff

 IN THE COURT OF THE DISTRICT
MUNSIF AT ALANDUR

O.S.No. of 2021

U.Dhanalakshmi
...Plaintiff

-Vs-

R.Selvanayagi & Others

...Defendants

PETITION FILED U/S 151 OF

C.P.C

M/s. V.Karnan
S.Krishnamoorthy
Thenraj
K.Ramesh (1801/2016)
Counsels for Plaintiff
Ph: 9003308644
 IN THE COURT OF THE DISTRICT MUNSIF AT ALANDUR

O.S. No. / 2021

U.Dhanalakshmi
…….Petitioner/Plaintiff
-Vs-
R.Selvanayagi & Others
.…….Respondents/Defendants

Batta memo for payment of stamps cash with Court.

Nature Name and description of person Village Taluk and District Proce
of on which or on whose property Munsif where process is to ss
Process the process is to be executed. be executed. fee.

Notice. 1. R.Selvanayagi All are residing at

W/o. Late Ramanathan No.957, 12th Cross Street,
2. P.Bhuvaneshwari Dr.Ambedkar Nagar,
W/o. Paneerselvam Adambakkam
3. P.Sathya Chennai- 600 088
D/o. Paneerselvam
4. S.Nandakumar
S/o. Selvaganapathy

It is requested that process memo with stamps for Rs. May be received.

Counsel for Petitioner/Plaintiff

 IN THE COURT OF THE DISTRICT
MUNSIF AT ALANDUR

O.S.No. of 2021

U.Dhanalakshmi
...Plaintiff

-Vs-

R.Selvanayagi & Others

...Defendants

PROCESS APPLICATION

M/s. V.Karnan
S.Krishnamoorthy
Thenraj
K.Ramesh (1801/2016)
Counsels for Plaintiff
Ph: 9003308644
 IN THE COURT OF THE DISTRICT MUNSIF AT ALANDUR

O.S. No. / 2021

U.Dhanalakshmi
…….Petitioner/Plaintiff
-Vs-
R.Selvanayagi & Others
. …….Respondent/Defendants

To.
R. 1. R.Selvanayagi
W/o. Late Ramanathan
No.957, 12th Cross Street,Dr.Ambedkar Nagar,
Adambakkam, Chennai- 600 088

Petition presented on
Petition filed on
Notice issued on

Whereas on the day of 2021, the above named petitioner filed a petition against the
respondent for

You are hereby required to appear in this Court on the Day of , 2021 at
10.30 a.m. in the forenoon in person or by pleader duly instructed and able to answer all material
questions relating to the above proceeding.

Also take notice that in default of appearance on the aforesaid day the issues will be settled and
the petition heard and determined in your absence. You shall also bring with you or send by
your pleader any documents which the petitioner desires to inspect and any documents on which
you intend to rely in support of your defence.

You are required file a written statement/Counter in Court on before the Day of
, 2021.

Given under my hand and the seal of this Court day of September, 2021
/By Order/

Advocate for Petitioner

Deputy Nazir,
District Munsif, Alandur

Note.:.
1. A copy of petition accompanies this notice.
2. This notice should be served not less than 21 days before the day fixed above for
settlement of issues.
3. Should you apprehend that your witness will not attend of their own accord. You can
have summons issued from this court to compel the attendance of any witness and the
production of any document that you have a right to call on the witness to produce on
applying to the court and on depositing the necessary expenses.
This notice has been taken by Sri. K.Ramesh

Advocate for the Petitioner.

 IN THE COURT OF THE DISTRICT MUNSIF AT ALANDUR

O.S. No. / 2021

U.Dhanalakshmi
…….Petitioner/Plaintiff
-Vs-
R.Selvanayagi & Others
. …….Respondent/Defendants

To.
R. 2. P.Bhuvaneshwari
W/o. Paneerselvam
No.957, 12th Cross Street,Dr.Ambedkar Nagar,
Adambakkam, Chennai- 600 088

Petition presented on
Petition filed on
Notice issued on

Whereas on the day of 2021, the above named petitioner filed a petition against the
respondent for

You are hereby required to appear in this Court on the Day of , 2021 at
10.30 a.m. in the forenoon in person or by pleader duly instructed and able to answer all material
questions relating to the above proceeding.

Also take notice that in default of appearance on the aforesaid day the issues will be settled and
the petition heard and determined in your absence. You shall also bring with you or send by
your pleader any documents which the petitioner desires to inspect and any documents on which
you intend to rely in support of your defence.

You are required file a written statement/Counter in Court on before the Day of
, 2021.

Given under my hand and the seal of this Court day of September, 2021
/By Order/

Advocate for Petitioner Deputy Nazir,

District Munsif, Alandur

Note.:.
1. A copy of petition accompanies this notice.
2. This notice should be served not less than 21 days before the day fixed above for
settlement of issues.
3. Should you apprehend that your witness will not attend of their own accord. You can
have summons issued from this court to compel the attendance of any witness and the
production of any document that you have a right to call on the witness to produce on
applying to the court and on depositing the necessary expenses.
This notice has been taken by Sri. K.Ramesh

Advocate for the Petitioner.

 IN THE COURT OF THE DISTRICT MUNSIF AT ALANDUR

O.S. No. / 2021

U.Dhanalakshmi
…….Petitioner/Plaintiff
-Vs-
R.Selvanayagi & Others
. …….Respondent/Defendants

To.
R. 3. P.Sathya
D/o. Paneerselvam
No.957, 12th Cross Street,Dr.Ambedkar Nagar,
Adambakkam, Chennai- 600 088

Petition presented on
Petition filed on
Notice issued on

Whereas on the day of 2021, the above named petitioner filed a petition against the
respondent for

You are hereby required to appear in this Court on the Day of , 2021 at
10.30 a.m. in the forenoon in person or by pleader duly instructed and able to answer all material
questions relating to the above proceeding.

Also take notice that in default of appearance on the aforesaid day the issues will be settled and
the petition heard and determined in your absence. You shall also bring with you or send by
your pleader any documents which the petitioner desires to inspect and any documents on which
you intend to rely in support of your defence.

You are required file a written statement/Counter in Court on before the Day of
, 2021.

Given under my hand and the seal of this Court day of September, 2021
/By Order/

Advocate for Petitioner Deputy Nazir,

District Munsif, Alandur

Note.:.
1. A copy of petition accompanies this notice.
2. This notice should be served not less than 21 days before the day fixed above for
settlement of issues.
3. Should you apprehend that your witness will not attend of their own accord. You can
have summons issued from this court to compel the attendance of any witness and the
production of any document that you have a right to call on the witness to produce on
applying to the court and on depositing the necessary expenses.
This notice has been taken by Sri. K.Ramesh

Advocate for the Petitioner.

 IN THE COURT OF THE DISTRICT MUNSIF AT ALANDUR

O.S. No. / 2021

U.Dhanalakshmi
…….Petitioner/Plaintiff
-Vs-
R.Selvanayagi & Others
. …….Respondent/Defendants

To.
R. 4. S.Nandakumar
S/o. Selvaganapathy
No.957, 12th Cross Street,Dr.Ambedkar Nagar,
Adambakkam, Chennai- 600 088

Petition presented on
Petition filed on
Notice issued on

Whereas on the day of 2021, the above named petitioner filed a petition against the
respondent for

You are hereby required to appear in this Court on the Day of , 2021 at
10.30 a.m. in the forenoon in person or by pleader duly instructed and able to answer all material
questions relating to the above proceeding.

Also take notice that in default of appearance on the aforesaid day the issues will be settled and
the petition heard and determined in your absence. You shall also bring with you or send by
your pleader any documents which the petitioner desires to inspect and any documents on which
you intend to rely in support of your defence.

You are required file a written statement/Counter in Court on before the Day of
, 2021.

Given under my hand and the seal of this Court day of September, 2021
/By Order/

Advocate for Petitioner Deputy Nazir,

District Munsif, Alandur

Note.:.
1. A copy of petition accompanies this notice.
2. This notice should be served not less than 21 days before the day fixed above for
settlement of issues.
3. Should you apprehend that your witness will not attend of their own accord. You can
have summons issued from this court to compel the attendance of any witness and the
production of any document that you have a right to call on the witness to produce on
applying to the court and on depositing the necessary expenses.
This notice has been taken by Sri. K.Ramesh

Advocate for the Petitioner.

 IN THE COURT OF THE DISTRICT MUNSIF AT ALANDUR

O.S. No. / 2021

U.Dhanalakshmi
…….Petitioner/Plaintiff
-Vs-
R.Selvanayagi & Others
. …….Respondent/Defendants

I, U.Dhanalakshmi, W/o. P.Umashankar @ P.Sadhasivam, do hereby appoint and retain

M/S.V.Karnan, S.Krishnamoorthy, Thenraj and K.Ramesh Advocates to appear for me in the
above Suit / Original / Miscellaneous Petition and to conduct and prosecute or defend the
same and all proceedings that may be taken in respect of any application for execution of any
decree or order passed therein. I empower my Advocate to appear in all miscellaneous
proceedings in the above suit or matter till all decrees or orders are fully satisfied or adjusted
and to obtain the return of documents and draw moneys that might be payable to me in the
said suit or matter and I do further empower my Advocate to accept on my behalf service of
notice of all or any appeals or petitions filed in any Court of Appeal, Reference or Revision with
regard to the said suit or matter before the disposal of the same in this Hon’ble Court. They
are also authorized to dispute other Counsel to act on their behalf.

Dated at Alandur on this the day of September, 2021

I certify that the contents of this vakalat

were read out and explained
in my presence to the executants/s who
appeared perfectly to understand the
same and made his/her/their
signature/s in my presence.

Advocate

ACCEPTED : The address for service of the said Advocate is Advocate for Plaintiff
Old No.127, New No.261, Rohith Tower, 2nd floor, Angappa Naicken Street, George Town,
Chennai – 600 001.
 IN THE COURT OF THE DISTRICT
MUNSIF AT ALANDUR

O.S.No. of 2021

U.Dhanalakshmi
...Plaintiff

-Vs-

R.Selvanayagi & Others

...Defendants

VAKALAT

M/s. V.Karnan
S.Krishnamoorthy
Thenraj
K.Ramesh (1801/2016)
Counsels for Plaintiff
Ph: 9003308644
IN THE COURT OF THE DISTRICT
MUNSIF AT ALANDUR
 O.S.No. of 2021

U.Dhanalakshmi
...Plaintiff

-Vs-

R.Selvanayagi & Others

...Defendants

DOCUMENT NO.

M/s. V.Karnan
S.Krishnamoorthy
Thenraj
K.Ramesh (1801/2016)
Counsels for Plaintiff
Ph: 9003308644