IN THE COURT OF CIVIL JUDGE, JUNIOR DIVISION,
KUCHINDA
Civil Suit No. _____ / 2025
Sabita Agrawal…………………. Plaintiff
-Vrs-
Jagdish Kumar Behera and others……………………..….Defendants
ADDRESS SHEET OF PLAINTIFF
1. Name: Sabita Agrawal
2. Age: 56 years
3. Father’s Name : Late Ratan Lal Agrawal
4. Occupation: Cultivation
5. Village: Ward No. 2, Kuchinda
6. PS: Kuchinda
7. Tah: Kuchinda
7. Munsifi: Kuchinda
8. Dist.: Sambalpur
Advocate for the plaintiff Plaintiff.
Continued……to page No. 2
IN THE COURT OF CIVIL JUDGE, JUNIOR DIVISION,
KUCHINDA
CIVIL SUIT No. _____ / 2025
1. Sabita Agrawal, aged about 56 years, D/o- Late Ratan Lal Agrawal,
of village- Ward No. 2, Kuchinda, PS- Kuchinda, Munsifi/Tahasil-
Kuchinda, Dist- Sambalpur at present residing at – Telitileimal,
P.S.- Kuchinda, Munsifi/Tahasil- Kuchinda, Dist- Sambalpur;
................................Plaintiff.
Versus.
1. Jagdish Kumar Behera, aged about 59 years, S/o- Late Nath Behera,
resident of village- Telitileimal, PS/Tah/Mun- Kuchinda, Dist-
Sambalpur;
.......................... Defendant.
In the above suit the Plaintiff begs to state as follows :-
1) That, the plaintiff and all the defendant are “Hindu” and governed by
Mitakshyar System of Hindu Law under Benaras School and plaintiff is
Basya Bania by caste and defendant is Siyala by caste.
2) That, Late Nath Behera who was the father of defendant had got his
landed property at Mouza- Telitileimal, Tahasil- Kuchinda, P.S.-
Kuchinda, Dist- Sambalpur, under Major Settlement Khata No. 34.
3) That, Late Nath Behera died in the year 2010 leaving behind his son
Jagdish Behera.
4) That, during the lifetime of Late Nath Behera on dated. 27.12.2991 the
plaintiff entered over the Plot No. 363 having an Area of A. 0.23 Dec
(Twenty Three Decimals), Plot No. 361 having an Area of A. 0.18 Dec
(Eighteen Decimals) , Plot No. 371 having an Area of A. 0.10 Dec (Ten
Continued……to page No. 3
Decimals), Plot No. 323 having an Area of A. 0.23 Dec (Twenty Three
Decimals), Plot No. 362 having an Area of A. 0.08 Dec (Eight
Decimals), Plot No. 370 having an Area of A. 0.13 Dec (Thirteen
Decimals) forcibly with hostile animous against Late Nath Behera and
possess the same openly, continuously without interruption which is
fully described in Schedule ‘A’ of this plaint and herein after called as
suit land.
5) That, Nath Behera died on dt. 03.12.2012 and after his death on dt.
23.08.2013 all the defendants came to the plaintiff and threatened to
vacant the suit but the plaintiff forcibly openly possessing the suit land
against the wish of defendants with a hostile animous till today and
prescribed her title by way of adverse possession.
6) That, on dated. 03.04.2025 all the defendants again came to the
plaintiff and threatened to vacate the suit land. Hence, plaintiff files this
suit.
7) That, the cause of action arose on dt. 27.12.1991 and on dt. 23.08.2013
and lastly on dt. 03.04.2025 as such the suit is within time.
8) That the suit is with in territorial jurisdiction of this court.
9) That, for the purpose of court fees and jurisdiction of court the suit is
valued at Rs. 40,000/- (Rupees Forty Thousand only) and Rs. 1000/-
(Rupees One Thousand only) for permanent injunction. Total Rs.
41,000/- (Rupees Forty One Thousand Only) as such an advolerum
court fees of Rs. is required but the plaintiff is an woman,
so she is exempted from payment of court fees vide Govt. Notification
bearing SRO No. 575/94.
Plaintiff
Continued……to page No. 4
PRAYER
That, the plaintiff prays for the following reliefs:-
i) that, the Right, title, interest and possession of plaintiff over the suit
land be declared by way of adverse possession;
ii) that, the defendants are permanently injuncted from disturbing the
peaceful possession of the plaintiff.
iii) Any other relief which the
ii) Any other relief/ reliefs which the Hon’ble court may think fit and
proper;
for this act of kindness the plaintiff shall ever pray.
Plaintiff
Documents relied upon:-
1. Certified Copy of M.S. Khata No. 83/80 (Eighty Three/ Eighty) of
Mouza – Telitileimal , PS- Kuchinda, Tahasil – Kuchinda, Dist.-
Sambalpur;
2. Certified Copy of M.S. Khata No. 34 (Thirty Four) of Mouza –
Telitileimal, PS- Kuchinda, Tahasil – Kuchinda, Dist.-Sambalpur;
3. Any other document found relevant at the time of hearing.
Continued……to page No. 5
Plaintiff
Continued……to page No. 6
SCHEDULE ‘A’ LAND
M.S. Khata No. 83/80 (Eighty Three/ Eighty) of Mouza
– Telitileimal , PS- Kuchinda, Tahasil – Kuchinda, Dist.-
Sambalpur, Plot No. 363 (Three Hundred Sixty Three) Area of A.
0.23 Dec (Twenty Three Decimals), Plot No. 361 (Three Hundred Sixty
One) Area of A. 0.18 Dec (Eighteen Decimals) , Plot No. 371 (Three
Hundred Seventy One) Area of A. 0.10 Dec (Ten Decimals), Plot No.
323 (Three Hundred Twenty Three) Area of A. 0.23 Dec (Twenty Three
Decimals), Plot No. 362 (Three Hundred Sixty Two) Area of A. 0.08
Dec (Eight Decimals), Plot No. 370 (Three Hundred Seventy) Area of A.
0.13 Dec (Thirteen Decimals). Total 06 (Six) Plots, Total Area
Ac. 0.95 Dec (Ninety Five Decimals).
Plaintiff
VERIFICATION
I, Sabita Agrawal, aged about 56 years, D/o- Late Ratan Lal Agrawal,
of village- Ward No. 2, Kuchinda, PS- Kuchinda, Munsifi/Tahasil-
Kuchinda, Dist- Sambalpur at present residing at – Telitileimal, P.S.-
Kuchinda, Munsifi/Tahasil- Kuchinda, Dist- Sambalpur do hereby verify
the contents of the above plaint to which I found all true and correct, so I
Continued……to page No. 7
signed this verification today the Day of April, 2025 before my
advocate Sri K. Behera in his office at 9.30 AM.
Plaintiff
Continued……to page No. 8
AFFIDAVIT
I, Sabita Agrawal, aged about 56 years, D/o- Late Ratan Lal Agrawal,
of village- Ward No. 2, Kuchinda, PS- Kuchinda, Munsifi/Tahasil-
Kuchinda, Dist- Sambalpur at present residing at – Telitileimal, P.S.-
Kuchinda, Munsifi/Tahasil- Kuchinda, Dist- Sambalpur do hereby
solemnly affirm and declare on oath as follows:-
1) That, I am the deponent in this affidavit and filing this suit as Plaintiff.
2) That, the contents of the above plaints from para 1 to para 09 are true to
the best of my information and belief.
The facts stated above are all true and correct to the best of my
knowledge and belief.
I identify the deponent.
Advocate, Kuchinda D e p o n e n t.
Continued……to page No. 9
