IN THE COURT OF THE………………..
Suit No………………… of 19………………………………….
C. D…………………………………………………………. Plaintiff
versus
C. F………………………………………………………. Defendant
The abovenamed plaintiff most respectfully submits as under: —
1. That the plaintiff has filed the present suit for declaration of his rights claiming himself to be a Bhumidhar of the land in dispute on the basis of a sale deed alleged to have been executed by……………….. who is a co-bhumidhar of the defendants……………….. and……………….. and he has sought a declaration as co-bhumidhar with the defendants in place of……………………….
2. That the alleged sale deed is a forged and fabricated document and has never been executed by……………….. who is the widow of their deceased brother.
3. That it is expedient that the statement of the plaintiff may be taken on oath under O. 10 R. 1 of the Code of Civil Procedure as to the fact whether the defendant is the same lady by whom the alleged sale deed is said to have been executed and if the plaintiffs state in the affirmative exercising inherent powers of this Court under section 151 of the Code, the signature of the defendant……………….. may be obtained and got compared through an expert with the signature made on the sale deed and may thereafter proceed to decide the suit according to the procedure laid down in the Code of Civil Procedure along with that provided in the Revenue Court manual.
PRAYER
It is, therefore, most respectfully prayed that applying the procedure provided by the Code of Civil Procedure, the Court may be pleased to take statements of the plaintiffs as well as of the defendant…………… under order X, R, 1 C. P. C.
It is accordingly prayed.
Plaintiff
Through Advocate
VERIFICATION
I, abovenamed plaintiff, do hereby verify that the contents of paras ……………….. to……………….. of the plaint are true to my personal knowledge and those of paras……………….. and……………….. thereof are based on legal advice which I believe to be true.
Verified on this…………….. day of…………….. 19……………….. at………………..
Plaintiff