.
It is not out of place to mention here sir, that sale of land has been shown under Transfer of Property
Act and under the Jammu and Kashmir Transfer Property Act Under Section 38 there must be sale in
writing stamped as per the value of the property and further it must be registered under Section 17 of
the Registration Act. Neither verbally nor -3rd-
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in writing has any sale been made. The entries in the record was made fraudulent in league with the
revenue authorities. The plaintiffs reserve the right to challenge the revenue entries before the
competent court o flaw.
6. That the defendants being the men of substance and having the muscle power are trying to
dispossess the plaintiffs from the suit land and if they are not stopped at this juncture, which will cause
irreparable loss to the plaintiffs which can not be compensated by any means.
7. That the plaintiffs asked the defendant not to claim ownership over the said piece of land but for the
last one week they have refused to restrain from claiming ownership over the suit land, hence cause of
action has accrued to the plaintiff against the defendants.
8. That the plaintiffs time and again asked the defendants not to claim any right over the property
declared them as owners, but they have failed to do the same. hence the present suit.
9. That this Hon'ble court has the original and territorial jurisdiction to entertain the present suit and
adjudicate thereupon under the law of the land.
10. That the suit is valued for the purpose of court fee and jurisdiction at RS Solex and the proper Court
fee in the form of stamps is enclosed herewith.
11. That the plaintiffs have not filed any suit before any forum with regard to the suit land except the
present suit.
12. That the suit is filed in duplicate under Order VII Rule 11(e) and the necessary copies for the
defendants are enclosed alongwith affidavit duly sworn in by the plaintiff.
In the premises it is therefore prayed that the following decrees may be passed in favour of plaintiffs
and against the defendants:-
A. That a decree for Declaration may be passed in favour of
Plaintiffs and against the defendant, thereby declaring the plaintiffs as owners of land falling under
khasra no. 36, 37, 38 & 39, Khewat No. 47, Khata no. 78 situated at Jabia Salamabad Uri.
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B. Decree for permanent prohibitory injunction may be passed in favour of Plaintiffs and against
defendants, thereby permanently restraining the defendants from claiming any ownership over the suit
land and they may be permanently restrained from causing any sort of interference into the possession
of the suit land.
C. Any other relief, order or direction which this hon'ble court deems fit and proper, though not
specifically prayed for, may be passed in favour of the Plaintiffs and against the contesting defendants.
Plaintiffs through counsel
Verification:
Verified today 23rd day of December-2017 at Baramulla that the averments made in the plaint are true
and correct to the best of my knowledge and belief and as per the Information furnished by my client
and the legal aspect is believed to be true.
Plaintiff through counsel
