IN THE COURT OF THE CIVIL JUDGE, SENIOR DIVISION, KANPUR
AT KANPUR
Civil Suit No. 225/2024
Mr. Ram Prasad,
Age- 32 years, Occupation- Business,
residing at House No. 10, Awas Vikas,
Laxminagar, Kanpur - 411018. …………………Plaintiff
VERSUS
Mr. Rajendra Prasad,
Age- 52 years, Occupation- Business,
residing at House No.10, Awas Vikas,
Laxminagar, Kanpur– 411018. …………………Defendant
A SUIT FOR PARTITION
The Plaintiff above named submits this plaint, praying to state as follows:
1. The Family linage is as follows:
F (Defendant No.1)
S1 (Plaintiff) S2 (Defendant No.2)
That the defendant No.1 is the father of the plaintiff and the defendant No.2, and the defendant
No.2 and the Plaintiff are full/real brothers.
2. Description of Property:
All that piece and parcel of land situate within the Registration Division & District Kanpur, Sub-
Division & Laxminagar, within the local limits of the Kanpur Municipal Corporation, Awas
Vikas, bearing Gat No. 302 admeasuring 2500 sqft. or thereabouts, and bounded by as follows:
- On or towards the East - House No. 300,
- On or towards the South - Public Road,
- On or towards the West - House No. 299,
- On or towards the North - Public Park.
3. The plaintiff, Mr. Ram, and his brother, Mr. Lakhan, are the two sons of Mr. Rajendra Prasad,
belonging to a Hindu Mitakshara family and they reside in a 3-story building located at House
No. 10, Awas Vikas, Laxminagar, Kanpur and own 3 shops in Laxminagar, Kanpur.
4. Additionally, Mr. Ram is the sole owner of another shop situated in Krantinagar, Kanpur,
which he acquired from his personal savings.
5. The joint family property includes the aforementioned building and shops.
6. The plaintiff desires to seek partition of the joint family property due to irreconcilable
differences and wishes to separate from the joint family.
7. Despite repeated attempts at amicable settlement, the defendant has refused to agree to a
partition of the joint family property.
8. The plaintiff asserts his rights to a fair share of the joint family property, including his
separate ownership of the shop in Krantinagar, Kanpur.
9. The plaintiff and the defendant are governed by the Mitakshara system of Hindu Law,
entitling the plaintiff to a rightful share in the joint family property.
10. The cause of action for this suit arose when the plaintiff's demand for partition was denied
by the defendant.
11. The property falls within the jurisdiction of this honorable court, and hence, this court has
jurisdiction to adjudicate upon the matter.
12. The suit is valued for the purpose of jurisdiction at Rs.xx, and the proper court fee has been
paid herewith.
13. Plaintiff most humbly submits prays as under:
- That it be declared that the plaintiff is entitled to a rightful share in the joint family property.
- The plaintiff's share be partitioned and given into his possession.
- The defendant be permanently restrained from obstructing the plaintiff's enjoyment of the
joint family property.
- The plaintiff be awarded the costs of the suit from the defendant.
- Any other orders deemed fit and just by this honorable court.
KANPUR, Sd/- Mr. Ram Prasad
Dated: 10.02.2024 (Plaintiff)
Sd/- *****
ADVOCATE FOR PLAINTIFF
VERIFICATION
I, Ram Prasad, the present Plaintiff, do hereby state on solemn affirmation that the contents of
this plaint in paras 1 to 12 are true and correct to the best of my knowledge and belief, and I have
signed hereunder.
Sd/****
PLAINTIFF
