___________ Versus _________
SUIT FOR DECLARATION.
Affidavit
I __________ son of Shri ________ R/o ___________ do hereby solemnly affirm and declare as under :-
1- That the defendant is recorded as owner of the following agricultural lands:-
(a) to extent of _____ share of the agricultural land bearing _____________, total measuring ______.
(b) to the extent of __________ share of the agricultural land bearing _____________, total measuring ____,
(c) to the extent of ____ share of agricultural land bearing ______, total measuring ____
(d) to the extent of ____ share of agricultural land bearing _______, total measuring ______, all the lands are situated within the revenue estate of ___________. The certified copy of the _____ for the year ____ is enclosed herewith the palint.
2- That the defendant is the ____ of the deponent and the parties to the suit constitute a ____.
3- That on ____ a family settlement took place between the deponent and the defendant vide which the defendant gave her respective shares of the suit property, mentioned in Paras No.1 (a) to 1(d) of the plaint, in favour of the deponent and since then the deponent is in actual and physical possession of the suit property mentioned in Para No.1(a) to (d) of the plaint. However, the name of the defendant still exists in the revenue records which is wrong and is not binding upon the rights, title and interest of the plaintiff.
4- That now the defendant with a malafide intention is not admitting the family settlement and she is also not admitting the claim of the deponent in respect of suit property and by getting recorded her name in the revenue records she is still declaring herself as owner of the suit property for which the defendant has got no right, title and interest to do so.
5- That the deponent asked the defendant several times to admit the claim of the deponent and to get the revenue entries corrected/incorporated in the name of the plaintiff. First of all the defendant was avoiding the requests of the plaintiffs on one pretext or the other and finally on _____ refused to accept the legitimate requests of the plaintiff.
6- That the cause of action to file the present suit firstly accrued on _______ when the family settlement took place between the deponent and the defendant. It further arose on each and every date when the deponent asked the defendant to admit the claim of the plaintiff. The cause of action finally ____ when the defendant finally refused to accept the claim of the plaintiff. This is the date when the final cause of action has arisen in favour of the deponent and against the defendant, which necessitated the institution of the present suit.
DEPONENT
VERIFICATION:
Verified that the contents of my above affidavit are true and correct to best of my knowledge and belief and nothing has been concealed therein.
Verified at ______ on _________
DEPONENT
______________
……Plaintiffs
VERSUS
_________________
….Defendant
SUIT FOR DECLARATION
Affidavit
I, ____________ son of Shri ____________, resident of _________________, do hereby solemnly affirm and declare as under :-
1- That the defendant are recorded owner in possession of the agricultural land comprising ___________________, total measuring _____________, which is situated with in the revenue estate of village ___________________. A copy of the Jamabandi for the year of _________________ is enclosed herewith the plaint.
2- That the plaintiffs are the real ___________ of the defendant and the parties to the suit constitute joint _____ Family.
3- That on ____________ a family settlement took place between the plaintiffs and the defendant vide which the defendant gave the suit property to the plaintiffs in equal share each (1/2 share each) and put the plaintiffs into the actual and physical possession of the suit property, mentioned in Paras No.1 of the plaint, and since then the plaintiffs are owners in possession to the extent of ½ share each of the suit property as mentioned in Para No.1 of the plaint. However, the name of the defendant still exists in the revenue records which is wrong and is not binding upon the rights, title and interest of the plaintiffs.
4- That now the defendant with a malafide intention are not admitting the family settlement and by getting the benefit of revenue entries in his name he is still declaring himself as owner in possession of the suit property for which the defendant have got no right, title and interest to do so.
5- That the plaintiffs asked the defendant several times to admit the claim of the plaintiffs and to get name of the plaintiffs recorded in the revenue records in place of his name. First of all the defendant was avoiding the requests of the plaintiffs on one pretext or the other and finally on ____________ the defendant refused to accept the legitimate requests of the plaintiffs.
6- That the cause of action to file the present suit firstly accrued on _____________ when the family settlement took place between the plaintiffs and the defendant. It further arose on each and every date when the plaintiffs asked the defendant to admit the claim of the plaintiffs and the cause of action finally ___________ when the defendant finally refused to accept the claim of the plaintiffs. Hence this is the date when the final cause of action has arisen in favour of the plaintiffs and against the defendant, which necessitated the institution of the present suit.
DEPONENT
VERIFICATION:
Verified that the contents of my above affidavit are true and correct to best of my knowledge and belief and nothing has been concealed therein.
Verified at _________ on _________
DEPONENT