IN THE COURT OF HON’BLE SENIOR CIVIL JUDEGE,
SAKET COURT DELHI
CIVIL SUIT NO.____OF 2025
IN THE MATTER OF:
1. Nitin
2. Ankit
…Plaintiff
VERSUS
1. Som Devi
2. Dharam Chandra
3. Sachin
4. Neha
…Defendant
INDEX
S.NO. PARTICULARS PAGES
C.FEE
1. Memo of Parties
2. Suit for Declaration and Permanent
Injunction along with affidavit
3. List of Documents along with
Documents.
4. Vakalatnama
FILED BY:-
S Firoz and Associates
Advocate for Plaintiff
352, Lawyers Chember
Saket Court Complex, Delhi -110017
M-9873004623
DELHI
DATED …/…/2025
IN THE COURT OF HON’BLE SENIOR CIVIL JUDEGE,
SAKET COURT DELHI
CIVIL SUIT NO.____OF 2025
IN THE MATTER OF:
1. Nitin
2. Ankit
…Plaintiff
VERSUS
1. Som Devi
2. Dharam Chandra
3. Sachin
4. Neha
…Defendant
MEMO OF PARTIES
IN THE MATTER OF:
1. Nitin (Grand Son)
S/O Sh Jai Bhagwan
R/O H.NO. 388,
1st Floor, Chirag Delhi,
Delhi – 110017
2. Ankit (Grand Son)
S/O Sh Jai Bhagwan
R/O H.NO. 388,
1st Floor, Chirag Delhi,
Delhi – 110017
…Plaintiff
VERSUS
1. Som Devi
W/O Late Kalu Ram
R/O H.NO. 388,
Ground Floor, Chirag Delhi,
Delhi – 110017
2. Dharam Chandra
S/O Late Kalu Ram
R/O H.NO. 388,
2nd Floor, Chirag Delhi,
Delhi – 110017
3. Sachin (Grand Son)
S/O Late Shri Gopal
R/O H.No. 388,
Ground Floor, Chirag Delhi,
Delhi – 110017
4. Neha (Grand Daughter)
D/O Late Shri Gopal
R/O H.No. 388,
Ground Floor, Chirag Delhi,
Delhi- 110017
…Defendant
Filed By:-
S Firoz and Associates
Advocate for Plaintiff
352, Lawyers Chamber
Saket Court Complex, Delhi- 1100017
M- 9873004623
IN THE COURT OF HON’BLE SENIOR CIVIL JUDEGE,
SAKET COURT DELHI
CIVIL SUIT NO.____OF 2025
IN THE MATTER OF:
1. Nitin (Grand Son)
S/O Sh Jai Bhagwan
R/O H.NO. 388,
1st Floor, Chirag Delhi,
Delhi – 110017
2. Ankit (Grand Son)
S/O Sh Jai Bhagwan
R/O H.NO. 388,
1st Floor, Chirag Delhi,
Delhi – 110017
…Plaintiff
VERSUS
1. Som Devi
W/O Late Kalu Ram
R/O H.NO. 388,
Ground Floor, Chirag Delhi,
Delhi – 110017
2. Dharam Chandra
S/O Late Kalu Ram
R/O H.NO. 388,
2nd Floor, Chirag Delhi,
Delhi – 110017
3. Sachin (Grand Son)
S/O Late Shri Gopal
R/O H.No. 388,
Ground Floor, Chirag Delhi,
Delhi – 110017
4. Neha (Grand Daughter)
D/O Late Shri Gopal
R/O H.No. 388,
Ground Floor, Chirag Delhi,
Delhi- 110017
…Defendant
SUIT FOR PERMANENT INJUNCTION AND DECLARTION FOR
EQUAL DISTRIBUTION OF PROPERTY
MOST RESPECTFULLY SHOWTH:
1. Description of the Parties:
a. The Plaintiff, Nitin and Ankit, are the sons of Jai Bhagwan and
grandsons of Defendant NO. 1, Som Devi, and Late Kalu Ram.
They are in possession of and reside at 388, 1 st Floor, Chirag
Delhi, Delhi – 110017.
b. Defendant No. 1, Som Devi, is the widow of Late Kalu Ram and
resides at 388, Ground Floor, Chirag Delhi – 110017.
c. Defendant No. 2, Dharam Chandra , is the son of Late Kalu
Ram and Som Devi and resides at 388, 2nd Floor, Chirag Delhi,
Delhi – 110017.
d. Defendant Nos. 3 and 4, Sachin and Neha, are the son and
daughter, respectively, of Late Shri Gopal (Son of Late Kalu
Ram and Som Devi), and reside at 388, Ground Floor, Chirag
Delhi, Delhi - 110017.
2. Family Background:
a. Late Kalu Ram and Defendant No.1, Som Devi had three
sons: a. Jai Bhagwan (Father of the Plaintiff, currently
missing), b. Dharam Chandra (Defendant No. 2),and c. Late
Shri Gopal (Father of the Defendant Nos. 3 and 4).
b. The Plaintiffs are the legal heirs of Jai Bhagwan, who is the
eldest son of Som Devi and Late Kalu Ram.
3. Description of the Property:
a. The subject matter of the this suit is an ancestral property
measuring 300 square yards, situated at 388, Chirag Delhi,
Delhi – 110017 ( hereinafter referred to as “the suit
property’’). The said property has been in the joint
possession of the family since the time of Late Kalu Ram
and is currently occupied follows:
Ground Floor : Defendant No. 1 (Som Devi), Defendant
No. 3, (Sachin), and Defendant No. 4(Neha).
1st Floor : Plaintiffs (Nitin and Ankit)
2nd Floor : Defendant No. 2( Dharam Chandra).
b. The Suit Property is an ancestral property inherited by Late
Kalu Ram and has devolved upon his legal heirs, including
the Plaintiffs and Defendants.
4. Cause of Action:
a. The Plaintiffs submit that the suit property, being ancestral
in nature, is jointly owned by all legal heirs of Late Kalu
Ram, i.e., the Plaintiffs (representing Jai Bhagwan’s Share),
Defendant No.2 (Dharam Chandra), and Defendant Nos. 3
and 4 (representing Late Shri Gopal’s Share),with Defendant
No.1 (Som Devi ) also having rights as the widow of Late
widow of Late Kalu Ram.
b. The Plaintiffs, being in possession of the 1 st Floor of the suit
property, are entitled to an equal share in the entire 300
square yards along with the 1 Defendants, as per the
principles of the Hindu Succession Act, 1956.
c. However, the Defendants, particularly Defendant No. 1 have
some threatened to sell, transfer, or alienate the suit
property without the consent of the Plaintiffs and without
ensuring its equal partition among all legal heirs. The
Plaintiffs apprehend that such action will prejudice their
lawful rights and possession in the suit property.
d. Despite repeated request by the Plaintiffs for an amicable
partition of the suit property, the Defendant have refused to
cooperate, necessitating the filing of this suit.
5. Relief Sought:
a. The Plaintiffs pray for a decree of Permanent Injunction
restraining the Defendants, their agents, assigns, or any
person acting on their behalf from selling, transferring,
alienating, or creating any third party in the suit property
measuring 300 square yards situated at 388, Chirag Delhi,
Delhi – 110017, without the consent of the Plaintiffs and
without equal partition.
b. The Plaintiffs further pray for a Declaration that the suit
property be a partitioned equally among the legal heirs of
the Late Kalu Ram, i.e., the Plaintiffs (representing Jai
Bhagwan’s share). Defendant No. 2 (Dharam Chandra) and
Defendant Nos. 3 and 4( representing Late Shri Gopal’s
Share), along with Defendant No. 1(Som Devi) as per her
entitlement under law.
6. Jurisdiction
a. The Hon’ble Court has jurisdiction to entertain and
adjudicate this suit as the suit property is situated at 388,
Chirag Delhi, Delhi – 110017, within the territorial
jurisdiction of this Court, and the cause of action has arisen
within its limits.
PRAYER:
In the view of above facts and circumstances, the Plaintiffs most
humbly pray that this Hon’ble Court may be pleased to:
a. Pass a decree of Permanent Injunction restraining the
Defendants, their, agents on their behalf from selling,
transferring, alienating, or creating any third – party interest
in the suit property measuring 300 square yards situated at
388, Chirag Delhi, Delhi – 110017, without the consent of
the Plaintiffs and without equal partition among all legal
heirs.
b. Pass a decree declaring that the Plaintiffs and Defendants
are entitled to an equal share in the suit property, and
direct the partition of the property according among the
legal heirs of Late Kalu Ram, i.e., the Plaintiffs (representing
Jai Bhagwan’s share), Defendant No.2 (Dharam Chandra),
Defendant No. 3 and 4 (representing Late Shri Gopal share),
and Defendant No.1 (Som Devi) as per her legal
entitlement.
c. Award costs of the suit in favor of Plaintiffs.
d. Grant any other relief as this Hon’ble Court may deem fit
and proper in the facts and circumstances of the case.
AND FOR THIS ACT OF KINDNESS, THE PLAINTIFFS SHALL EVER
PRAY.
FILED BY:-
S Firoz and Associates
Advocate for Plaintiff
352, Lawyers Chamber
Saket Court Complex, Delhi- 1100017
M- 9873004623
VERIFICATION:
We,Nitin S/O Jai Bhagwan and Ankit S/O Jai Bhagwan, the Plaintiffs, the
Plaintiffs herein, do hereby verify that the Contents of paras 1 to … of
the Plaint are true to our personal knowledge and belief, and no part of
it is false and nothing material has been concealed therefrom.
DELHI
DATED…/…/2025
Plaintiffs:
1. Nitin
2. Ankit
IN THE COURT OF HON’BLE SENIOR CIVIL JUDEGE,
SAKET COURT DELHI
CIVIL SUIT NO.____OF 2025
IN THE MATTER OF:
1. Nitin
2. Ankit
…Plaintiff
VERSUS
1. Som Devi
2. Dharam Chandra
3. Sachin
4. Neha
…Defendant
AFFIDAVIT
I, Nitin S/O Sh Jai Bhagwan aged about … years, R/O H.No. 388, Chirag
Delhi, Delhi- 110017, do hereby solemnly affirm and declare as under:
1. That the deponent is plaintiff in the abovementioned suit is fully
conversant with the facts and circumstances of the case and is
component to swear the present affidavit.
2. That the accompany suit has been drafted by my counsel under
my instruction contents of which are read over and explained to
me in vernacular and the deponent declares and confirms that
the same true and correct to his knowledge.
3. That the contents of the accompanying suit have have not been
repeated herein for the sake of brevity and the same may be
read as part and parcel of the affidavit.
DEPONENT
VERIFICATION
Verified at Delhi on this …day of Apr,2025 that the contains of my
above affidavit are true and correct and nothing material has
been concealed there from and no part pf it is false.
DEPONENT
IN THE COURT OF HON’BLE SENIOR CIVIL JUDEGE,
SAKET COURT DELHI
CIVIL SUIT NO.____OF 2025
IN THE MATTER OF:
1. Nitin
2. Ankit
…Plaintiff
VERSUS
1. Som Devi
2. Dharam Chandra
3. Sachin
4. Neha
…Defendant
AFFIDAVIT
I, Ankit S/O Sh Jai Bhagwan aged about … years, R/O H.No. 388, Chirag
Delhi, Delhi- 110017, do hereby solemnly affirm and declare as under:
5. That the deponent is plaintiff in the abovementioned suit is fully
conversant with the facts and circumstances of the case and is
component to swear the present affidavit.
6. That the accompany suit has been drafted by my counsel under
my instruction contents of which are read over and explained to
me in vernacular and the deponent declares and confirms that
the same true and correct to his knowledge.
7. That the contents of the accompanying suit have have not been
repeated herein for the sake of brevity and the same may be
read as part and parcel of the affidavit.
DEPONENT
VERIFICATION
Verified at Delhi on this …day of Apr,2025 that the contains of my
above affidavit are true and correct and nothing material has
been concealed there from and no part pf it is false.
DEPONENT
IN THE COURT OF HON’BLE SENIOR CIVIL JUDEGE,
SAKET COURT DELHI
CIVIL SUIT NO.____OF 2025
IN THE MATTER OF:
1. Nitin
2. Ankit
…Plaintiff
VERSUS
1. Som Devi
2. Dharam Chandra
3. Sachin
4. Neha
…Defendant
LIST OF DOCUMENTS
1. Site Plan
2. Copy of Aadhar Card of Plaintiffs
3. Copy of GPA
4. Any other documents will be filed with prior permission of this
Hon’ble Court.
FILLED BY:-
S Firoz and Associates
Advocates for Plaintiffs
352, Lawyers Chamber
Saket Court Complex, Delhi – 110017
M- 9873004623
Delhi
Dated …/…./2025
