Suit of Declaration of Land

IN THE COURT OF HON’BLE _____
IN THE MATTER OF
_____ S/o, W/o _____
…..PLAINTIFFS
VERSUS
_____ S/o, W/o _____
…..DEFENDANTS
SUIT FOR DECLARATION
AFFIDAVIT
We, _____ S/o, W/o _____ and  _____ S/o, W/o _____ residents of _____, do hereby solemnly affirm and declare as under :-
1(a) That the plaintiff No.1 is owner in possession of portion of plot measuring _____ Sq. Yards forming part of _____, which is situated in _____.
1(b) That the plaintiff No.2 is owner in possession of portion of plot measuring _____ Sq. Yards forming part of _____, which is situated in _____.
2- That the plaintiff No.1 is the _____ of the defendant NO.1 and the plaintiff NO.2 is the _____ of the defendant NO.2 and the parties to the suit constitute a _____ and co-related and blood related to each other with the principle of _____.
3- That as a matter of record the defendant No.1 to 2 are the joint co-owners and in possession to the extent of _____ share out of the total land measuring _____ Sq. Yards which was jointly purchased by the defendants vide sale Deed bearing its document No. _____ dated _____ registered in the office of _____. The photocopy of the sale deed is enclosed herewith the plaint.
4- That on _____ a family settlement arrived at between the plaintiffs and the defendants in which the defendant NO.1 relinquished the land measuring _____ Sq. Yards out of the land measuring _____ Sq. Yards in favour of the plaintiff No.1, the defendant No.2 also relinquished the land measuring _____ Sq. Yards out of the land measuring _____ Sq. Yards in favour of the plaintiff No.2 and since then the plaintiffs are owners in possession of the suit properties which are mentioned in Para No.1 (a) to 1(b) of the plaint.
5- That now the defendants are not admitting the claim of the plaintiffs in respect of the suit properties and they are not admitting the family settlement for which the defendants have got no right, title and interest to do so.
6- That the plaintiffs requested the defendants several times to admit the claim of the plaintiffs in respect of the suit properties and to get the _____ records corrected in the name of the plaintiffs. First of all the defendants were avoiding to the legitimate requests of the plaintiffs on one pretext or the other and finally on _____ they refused to accept to the legitimate requests of the plaintiffs.
7- That the cause of action to file the present suit firstly arose on _____ when the family settlement took place and it further arose on each and every dates when the plaintiffs requested the defendants to admit the claim of the plaintiffs in respect of the suit properties and the cause of action finally arose on _____ when the defendants finally refused to accept to the legitimate request of the plaintiffs. Hence this suit.
DEPONENTS
VERIFICATION
Verified that the contents of our above affidavit are true and correct to best of our knowledge and belief and nothing has been concealed therein. Verified at _____ on _____
DEPONENTS