O.S.NO.

/2025

IN THE COURT OF PRL CIVIL JUDGE VIJAYAPURA

1. Indravva W/o Shasappa Hirekurubar

Age: 45 Years, Occ: HHW and Agrl.
R/o: Agasanahalli, Tq: Babaleshwar,
Dist: Vijayapura
…………Plaintiff.
V/s
1. Shivananda @ Shivanappa S/o Laxman Hirekurubar
Age: 55 Years, Occ: Agrl.
R/o: Agasanahalli Tq: Babaleshwar,
Dist: Vijayapura
…………Defendant.

PLAINT UNDER ORDER VII RULE 1 AND 2 OF C.P.C.-1908

SUIT FOR PARMANENT INJUNCTION

Herein the plaintiff named above begs to submit as

under,
1. The address of the plaintiff and defendant is as shown in cause
title of the plaint for the purpose of service of suit summons and
I.A. notice.
2. The plaintiff is the owner of Sy No. 1075 of Kakhandaki village
measuring 11As 00Gs along with his sons Ramesh and Bhimappa.
In this 11As there are 2 parts, western portion 5As belongs to
plaintiff and her sons. Eastern portion 6As belongs to husband’s
brother of plaintiff by name Birappa S/o Neelappa Hirekurubar.
The plaintiff has field this suit on behalf of herself and her sons.
3. Defendant is the distant relative of the plaintiff. The defendant’s
father is the owner of 10As 30Gs of land in Sy No. 1075 of
Kakhandaki village. Earlier the property of plaintiff and her
husband’s brother by name Bhimappa was numbered as Sy No.
1075/2 measuring 11As 0.5Gs and defendant’s property
measuring 10As 35Gs was numbered as Sy No. 1075/1. The
genealogy of plaintiff and defendant is shown in “Shcedule A”, the
same be treated as part and parcel of the plaint. The land
belonging to the father of the defendant is situated towards
western side of plaintiff’s property. To show the exact situation of
lands of plaintiff and defendant’s father a rough hand sketch is
produced, the same is mentioned as “Schedule B” and the same
be treated as part and parcel of the plaint. Herein after 5As 00Gs
excluding port kharab 5Gs is shown by letters A,B,C,D in the hand
sketch. Herein after 5As of land in Sy no. 1075 out if 11As shown
by letters A,B,C,D is called as suit property.
4. Property measuring 6As which belongs to plaintiff’s husband’s
brother by name Birappa is shown by letters B,C,D,E in the hand
sketch. In the same way the property belonging to defendant’s
father by name Laxman S/o Ramappa Hirekurubar measuring 10As
30Gs is shown by letters A,D,X,Y in the pliant hand sketch.
Defendant’s father Laxman and father in-law of plaintiff by name
Neelappa were brothers. Neelappa died long back his property
measuring 11As, in Sy No. 1075 was succeeded by 2 sons of
Neelappa by Shasappa and Birappa. The plaintiff is the wife of
Shasappa. The plaintiff has field this suit on behalf of herself and
on behalf of her sons Ramesh and Bheemappa.
5. The plaintiff, her husband’s brother and defendant’s father are
enjoying their respective land independently. Since more than 30
years back there was partition between Neelappa and Laxman.
The sons of plaintiff by name Ramesh and Bhimappa reside at
Bengaluru to do coolie work.Only plaintiff resides in Kakhandaki
village.
 Except the suit property the plaintiff has no other source of
income to survive. The defendant cultivate his father‘s land
measuring 10As 30Gs in Sy No. 1075. Taking the disadvantage of
fact that plaintiff is a helpless lady and her husband is no more,
her sons reside far away from the plaintiff, the defendant is trying
to encroach upon the suit property with an intention to dispossess
the plaintiff from the suit property.
6. Since last 6 months, the defendant is obstructing the possession of
plaintiff over the suit property. The plaintiff got the defendant
advised by the elders, but the defendant did not heard, so the
plaintiff approached Babaleshwar Police Station. The PSI
Baleshwar did not register the complaint but called the defendant
and his followers and advised them. The defendant agreed before
the police station and again behaved in the same manner in the
village. The defendant gave life threat to the plaintiff when all
these was intolerable plaintiff again approached the Babaleshwar
Police Station this time, the PSI of Babaleshwar Police Station, said
that he cannot register the complaint as the dispute is that of civil
nature. The plaintiff had ploughed the land and had put seeds as it
was a sowing season on 24/6/2025, when the plaintiff was out of
station, the defendant has ploughed the entire suit property
causing damage to the land and loss to the plaintiff to the extent
of Rs.25,000/-. Hence left with no other go. The plaintive is
compelled to file this suit. The plaintiff is in peaceful possession,
enjoyment and wahiwat of the suit property. This defendant who
has no right, title or interest of whatsoever kind is trying to
obstruct the peaceful possession, of the plaintiff and dispossess
her from the suit property.

7. CAUSE OF ACTION : Cause of action arose to the plaintiff to file the

suit on 24/6/2025, when the defendant damaged the cultivated
portion of the suit property, the same is continued till today
 8. JURIDICTION: Parties to the suit reside, suit property situate and
cause of action arose within the jurisdiction of this hon’ble court.
Hence this hon’ble court has the jurisdiction to try this suit
For the purpose of pecuniary jurisdiction and
advocate fee, the suit is valued at Rs.1000/-.

9. COURT FEES: The suit is one for permanent injunction. The same is
valued under section 26(c) of KCF and SV Act. The claim is valued
Rs.1000/- and court fee of Rs.25/- is paid.

10.PRAYER: Hence your honour be pleased to

A. Issue permanent injunction restraining the defendant, his
relatives, agents, servants, and henchman from obstructing the
peaceful possession, enjoyment, and wahiwat of plaintiff over
the suit property.
B. Order any other relief deemed fit.

Place: Vijayaprura
Date: Plaintiff
 VERIFICATION

I, Indravva W/o Shasappa Hirekurubar Age: 45 Years,

Occ: HHW and Agrl. R/o: Agasanahalli, Tq: Babaleshwar, Dist:
Vijayapura, the above named plaintiff, do solemnly declare that what
is stated in the plaint are true to the best of my knowledge and belief.

Place: Vijayaprura
Date: Plaintiff