6) That the Defendants No.

1 to 6 have huge political clout and muscle power and

have lot of influence on local police. The Plaintiff being busily engaged practice

and was taking treatment for her health. The Defendants are taking the

advantages of the same has trying to grab and dispossess the Plaintiff from

the open plot i.e., Suit A Schedule Property. The Plaintiff even approached the

local police to lodge the complaint against the Defendants, but the police refused

to take any complaint as the matter is of civil in nature and advice to approach the

Civil Court.

7) That originally above said street road located to backside of BDO Office,

Pernambut, now Public road over a stretch of 100 feet or thereabouts being a main

road branching off from Gudiyattam Road (Pernambut to Gudiyattam main road)

and also access road inter-alia for the residents of the area which goes by the

name Lalapet. Street road/Public Road referred to supra is comprised in

S.Nos.684, 683 and 685 in Pernambut Village, Vellore District. It is an admitted

factual position as between the parties that the above said road was 20 feet wide

and 100 feet long. It is also a further admitted position as between the parties that

there are encroachments by Defendants on either side of the said road that have

reduced/shrunk the width of the 20 feet wide road to barely 10 feet. In this regard,

the Plaintiff affected lot and met huge loss by these encroachments by

Defendants.
8) The property purchased by the plaintiff through sale deed has been described

hereunder as suit A schedule property and the encroached portion of the suit A

schedule property has been described hereunder as suit B schedule property and

the said Street encroached and put up construction by the defendants has been

described hereunder as suit C schedule property. The defendants 1 and 6 are liable

to deliver the encroached portion of the suit A schedule property namely the suit

B schedule property. The plaintiff has demanded the defendants 1 and 6 to remove

the encroachment over the suit B schedule property and deliver the same to her,

but they have failed to do the same.

9) That, the Plaintiff is true lawful owner and absolute owner of suit A schedule

property and the Defendants does not have any sort of right or title over the suit A

schedule property but illegally grabbed the suit B schedule property by the

defendants 1 and 6. The encroached portion of the suit B schedule property having

no other option the Plaintiff constrained to approach this Hon’ble Court for

declaration of Title and Recovery of Possession of the suit B schedule property

and also for mandatory injunction against 7 to 9 to remove the encroachment over

the suit C schedule property and directing the defendants 1 to 5 to remove the

encroachment over the suit C schedule mentioned property.

CAUSE OF ACTION

It is humbly submitted that the cause of action firstly accrued when the

Defendants committed, without there being any sort of right or title over the suit B

schedule property grabbed illegally and started the construction and On

16/01/2025 the Plaintiff approached the first and sixth Defendants and questioned

about their illegal activities over the suit B schedule property, upon which the

Defendants blenderly refused to show any piece of evidence in regard to the title

or claim over the suit B schedule property, and Defendants 2 to 5

grabbed/encroached the street road and pathway, apart from that the Defendants

along with their henchmen’s necked out the Plaintiff and threatened with dire

consequences by refusing to remove the structure.

JURISDICTION

That the property is situated within the territorial limits of this Hon’ble Court,

cause of action also accrued here, the Registering Authority fall under the

jurisdiction of this Hon’ble Court, Hence this Hon’ble Court has the jurisdiction

to entertain and adjudicate upon the matter.

The Plaintiff values this suit for the purpose of payment of court fees and

jurisdiction at Rs.5000/- + Rs.1,000/- + Rs.1,000/- and pays court fee of Rs.150/-

+ Rs.30/- + Rs.30/- U/S 25(a) and 27(c) and 27(c) of the Tamil Nadu Court Fees

and Suit Valuation Act of 1955.

PRAYER

Therefore the Plaintiff most humbly prayed that this Hon’ble Court may be

pleased to pass judgment and decree against the Defendants,

(a) To declare the Plaintiff’s right and title over the suit B schedule

mentioned property and directing the defendants 1 and 6 to deliver the

possession of the suit B schedule mentioned property after removal of

encroachment over the same failing which to effect delivery through court

of law with help of court ameen, VAO and Surveyor

(b) To direct the defendants 1 to 6 to remove the encroachment over the suit

C schedule mentioned Street property failing which to remove the same

through court of law with help of court ameen, VAO and Surveyor

(c) To direct the Defendants 7 to 9 to take appropriate action to remove the

encroachments of street road/ pathway and secure the possession of the suit

C schedule property.

(d) To grant costs of the suit, and

(e) Pass such other order or orders as Hon‘ble Court deems fit and proper

in the ends of justice.

 SCHEDULE OF PROPERTY

‘A’ schedule property:

BtY]h; khtl;lk;, Bgh;zhk;gl; tl;lk;, Bgh;zhk;gl; rhh;gjpt[ mYtyfj;ijr;
Brh;e;j, rhj;fh; fpuhk Cuhl;rp, Bgh;zhk;gl; g[d;bra; rh;Bt vz;.684,
1.07.0 b#f;Blh; Vf;fh; 2.64 brd;;l; njpy; utp vd;gthpd; epyj;jpw;F
fpHf;F, yhyhBgl;il fpuhkj;jpw;F Bkw;F, Nj;fhtpw;F tlf;F, mg;Jy;yh
gh&h epyj;jpw;F bjw;F njd; kj;jpapy; Vf;fh; 1.32 brd;l; epyk;.
‘B’ schedule property:
BtY]h; khtl;lk;, Bgh;zhk;gl; tl;lk;, Bgh;zhk;gl; rhh;gjpt[ mYtyfj;ijr;
Brh;e;j, rhj;fh; fpuhk Cuhl;rp Bgh;zhk;gl; g[d;bra; rh;Bt vz;.684,
1.07.0 b#f;Blh; Vf;fh; 2.64 brd;;l; njpy; 1k; gpujpthjp bra;Js;s
Mf;fpukpg;g[ gFjp khjphp tiuglj;jpy; EFGH vd rptg;g[ epwj;jpy;
fhl;oa[s;s gFjpapd; mst[ fpHf;F Bkw;F 6 mo, tlf;F bjw;F 1 mo Mf 6
rJuo kw;Wk; 6k; gpujpthjp bra;Js;s Mf;fpukpg;g[ gFjp khjphp
tiuglj;jpy; ABCD vd gr;ir epwj;jpy; fhl;oa[s;s gFjpapd; mst[ fpHf;F
Bkw;F 8 mo, tlf;F bjw;F 2 mo Mf 16 rJuo Mf bkhj;jk; 22 rJuo gFjp.
kjpg;g[ U}.176/- (1 brd;l; U}.3500/436 = U}.8/- (1 rJuo), 8 X 22 =
U}.176/-)

‘C’ schedule property:

BtY]h; khtl;lk;, Bgh;zhk;gl; tl;lk;, Bgh;zhk;gl; rhh;gjpt[ mYtyfj;ijr;
Brh;e;j, rhj;fh; fpuhk Cuhl;rp Bgh;zhk;gl; rh;Bt vz;.677-y; fpHf;F
Bkw;fhf bry;Yk; Bgh;zhk;gl;oypUe;J Foahj;jk; bry;Yk; gpujhd
rhiyapypUe;J tlf;F bjw;fhf bry;Yk; bjUtpd; mfyk; 20 mo ePsk; 100
mo njpy; gpujpthjpfs; 1 Kjy; 5 Mf;fpukpg;g[ bra;Js;s gFjpahdJ
khjphp tiuglj;jpy; IJEH vd ePy epwj;jpy; fhl;oa[s;s gFjpapd;
mst[ fpHf;F Bkw;F 6 mo, tlf;F bjw;F 100 mo Mf 600 rJuo bjUgFjp.

Advocate for Plaintiff Plaintiff

I, the Plaintiff do hereby declare that what is stated above is true to the best
of my knowledge, belief, information, verified and signed this at
Vaniyambadi on .01.2025.

Plaintiff

PARTICULARS OF VALUATION
Suit for declaration and possession and injunction against the respondents
Relief of declaration and possession
Value of the suit B schedule property is Rs.176/-
Minimum valued adopted for payment of
Court fee and valued at Rs.5,000/-
Court fees paid thereon U/s 25(a) of T.N.C.F. Act Rs. 150/-

Relief of Mandatory injunction against defendants 1 to 6

Incapable of Valuation and valued at Rs.1,000/-
Court fees paid thereon U/s 27(c) of T.N.C.F. Act Rs. 30/-
Relief of Mandatory injunction against defendants 7 to 9
Incapable of Valuation and valued at Rs.1,000/-
Court fees paid thereon U/s 27(c) of T.N.C.F. Act Rs. 30/-
LIST OF DOCUMENTS FILED U/O 7 R 14(1) CPC
1) Certified copy of the deed Doc.No.129/2001 dated 22-
 02-2001 standing in the name of Plaintiff
2) Computerized patta No.867 standing in the name of
plaintiff
3) Computerized FMB in S.NO.684

4) Computerized copy of A register extract S.NO.684

5) Photos with CD

6) Online EC

7) Guideline value

(Xerox copies of plaint documents are annexed herewith)

LIST OF DOCUMENTS TO BE FILED U/O 7 R 14(3) CPC

At present nil

Advocate for Plaintiff