1

BEFORE THE HON’BLE PRINCIPAL DISTRICT AND SESSIONS JUDGE AT

THIRUVALLUR

Tr.O.P.NO. of 2024

MRS.P.SHEEBA,
wife of S.Premkumar,
No.11/27, Perumal Kovil Street,
Rajanguppam, Chennai - 600 095. …Petitioner/Plaintiff
-Vs-

1. MRS.SASIKALA UDHAYAKUMAR,
wife of Late. Udhaya Kumar,
No.1, Ambattur Flats, Redhills Road,
Ambattur, Chennai - 600 053.
2. MRS.KALAISELVI,
wife of Late. Jegath Kumar,
No.2, First Floor, Rajalakshmi Apartments,
5th Street, 1st Cross Road,
Mahalakshmi Nagar, Madipakkam,
Chennai - 600091.
3. MRS.ANITHA,
wife of Senthil Kumar,
No.2, First Floor, Rajalakshmi Apartments,
5th Street, 1st Cross Road,
Mahalakshmi Nagar, Madipakkam,
Chennai - 600091.
4. MRS.SARASWATHI,
wife of Late. A.N.Deva Kumar,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
5. MRS.LAKSHMI,
wife of Prathul,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
6. MR. SENTHIL KUMAR,
son of Late. A.N.Deva Kumar,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
7. MR.SIVAKUMAR,
son of Late. Udhaya Kumar,
No.1, Ambattur Flats, Redhills Road,
Ambattur, Chennai - 600053.

8. MR.VINOTHKUMAR LAL BAHADUR,

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Son of Lal Bahadur,

No.8/41, Vaidhiyalingapuram,
Kurinjipadi, Cuddalore District
Pincode - 607302.
9. THE SUB REGISTRAR, AMBATTUR
Sathya Street, Ram Nagar,
Vinayagapuram, Ambattur,
Chennai - 600053.
10. THE DISTRICT COLLECTOR,
First Floor, Collectorate
Tiruvallur, Tiruvallur District,
Pincode - 602001. …Respondents/Defendants

IN THE MATTER OF THE ORIGINAL SUIT NO.194 OF 2023 ON THE FILE OF THE
HON’BLE DISTRICT MUNSIF COURT AT AMBATTUR

O.S.No.194 of 2023

MRS.P.SHEEBA,
wife of S.Premkumar,
No.11/27, Perumal Kovil Street,
Rajanguppam, Chennai - 600 095. …Plaintiff
-Vs-

1. MRS.SASIKALA UDHAYAKUMAR,
wife of Late. Udhaya Kumar,
No.1, Ambattur Flats, Redhills Road,
Ambattur, Chennai - 600 053.
2. MRS.KALAISELVI,
wife of Late. Jegath Kumar,
No.2, First Floor, Rajalakshmi Apartments,
5th Street, 1st Cross Road,
Mahalakshmi Nagar, Madipakkam,
Chennai - 600091.
3. MRS.ANITHA,
wife of Senthil Kumar,
No.2, First Floor, Rajalakshmi Apartments,
5th Street, 1st Cross Road,
Mahalakshmi Nagar, Madipakkam,
Chennai - 600091.
4. MRS.SARASWATHI,
wife of Late.A.N.Deva Kumar,
 3

No.3/325, 11th Street, Govinda Samy Nagar,

Madipakkam, Chennai - 600091.
5. MRS.LAKSHMI,
wife of Prathul,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
6. MR. SENTHIL KUMAR,
son of Late. A.N.Deva Kumar,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
7. MR.SIVAKUMAR,
son of Late. Udhaya Kumar,
No.1, Ambattur Flats, Redhills Road,
Ambattur, Chennai - 600053.
8. MR.VINOTHKUMAR LAL BAHADUR,
Son of Lal Bahadur,
No.8/41, Vaidhiyalingapuram,
Kurinjipadi, Cuddalore District
Pincode - 607302.
9. THE SUB REGISTRAR, AMBATTUR
Sathya Street, Ram Nagar,
Vinayagapuram, Ambattur,
Chennai - 600053.
10. THE DISTRICT COLLECTOR,
First Floor, Collectorate
Tiruvallur, Tiruvallur District,
Pincode - 602001. …Defendants
AFFIDAVIT OF P.SHEEBA

I, P.SHEEBA, wife of Mr.S.Premkumar, Hindu, aged about 40 years residing at No.11/27,

Perumal Koil Street, Rajankuppam, Ayanambakkam Post, Chennai – 600 095, do hereby
solemnly affirm and sincerely state as follows :-
1. I am the Plaintiff in the above main suit. I am aware of the facts and circumstances of the
case and competent to swear to this Affidavit.
2. I state that I have filed the above suit in O.S.No.194 of 2023 for the following main reliefs:
-
i. to declare that the General Power of Attorney dated 09.01.2023 executed by the 2 nd to
6th Defendants in favor of the 1 st Defendant and the same was registered as Document
No.601 of 2023 at the office of the Sub-Registrar, Ambattur as null and void, illegal in
the eyes of law and the same is not binding on the Plaintiff;
ii. to declare that the Sale Deed dated 04.02.2023 executed by the 1 st to 6th Defendants in
favor of the 7th Defendant and the same was registered as Document No.1684 of 2023
at the office of the Sub-Registrar, Ambattur as null and void, illegal in the eyes of law
and the same is not binding on the Plaintiff;
iii. to declare that the Mortgage Deed dated 09.02.2023 executed by the 7 th Defendant in
favor of the 8th Defendant and the same was registered as Document No.1837 of 2023
 4

at the office of the Sub-Registrar, Ambattur as null and void, illegal in the eyes of law
and the same is not binding on the Plaintiff;
iv. to grant permanent injunction restraining the 1st to 8th Defendants, their men, servants,
agents, or any person acting under them, from alienating or creating any kind of
encumbrances in any manner whatsoever in the suit schedule property;
3. I state that earlier I had filed the suit in O.S.No.400 of 2022 pending before the Hon’ble II
Additional District and Sessions Judge at Poonamallee for the following main reliefs: -
i. to declare that the Plaintiff is the absolute owner of the suit schedule property;
ii. to grant permanent injunction restraining the Defendant, her men, servants, agents
or any person acting under her, from interfering in the Plaintiff peaceful
possession and enjoyment of the suit property;
4. I state that the second suit in O.S.No.194 of 2023 pending on the file of Hon’ble District
Munsif Court at Ambattur is filed for cause of action that took place after filing of the suit
in O.S.No.400 of 2022. But the issue involved in the both the cases are one and the same.
The averments and the allegations in both the suits may read as part and parcel of this
Petition and the same is not repeated for the sake of brevity.
5. I state that the second suit in O.S.No.194 of 2023 is filed before the Hon’ble District Munsif
Court at Ambattur, since the case falls under its pecuniary jurisdiction. Both the courts are
subordinate to this Hon’ble Court. The issues involved in both the suits are one and the
same.
6. I further state that the documents required to be produced and the evidence required to be
adduced are one and the same in the both suits.
7. I state that if both the suits are tried separately in two courts it would involve confusion and
doubling of work in the two courts. I further state that if the two courts render different
findings on the same common issues involved both the suits the parties will be compelled to
prefer appeals in both the suits. I state that on the other hand, if the suit in O.S No.194 of
2023 pending on the file of Hon’ble District Munsif Court at Ambattur, transferred to the
Hon’ble II Additional District and Session Court at Tiruvallur, the necessity to adduce
evidence, enquiry of the witness and conflicting findings in the two suits can be avoided.
8. I submit that if the suit in O.S.No.194 of 2023 transferred to the Hon’ble Additional District
Court at Poonamalle, a better and full adjudication relating to the same subject matter of the
suits could be achieved instead of trial in two different courts of the same districts.
Therefore, I humbly submit that in the interest of justice and to avoid multiplicity of
proceedings, I pray that this Hon’ble Court may be pleased to transfer the pending suit in
O.S.No.194 of 2023 on the file of Hon’ble District Munsif Court at Ambattur to the file of
Hon’ble II Additional District Judge and Sessions Judge at Poonamallee.
9. I submit that the Respondents will not be prejudiced in any manner by transferring the suit
in O.S.No.194 of 2023 on the file of Hon’ble District Munsif Court at Ambattur to the
Hon’ble II Additional District and Sessions Judge at Poonamallee and tried with suit in
O.S.No.400 of 2022.

I therefore pray that this Hon’ble Court may be pleased to order withdrawal of the suit in
O.S.No.194 of 2023 from the file of the Hon’ble District Munsif Court at Ambattur and
transfer the same to the court of Hon’ble II Additional District Judge and Sessions Judge at
Poonamallee with the direction to try the same along with the suit in O.S.No.400 of 2022 in
the same court of law at II Additional District and sessions Judge at Poonamallee.
 5

Solemnly affirmed at Chennai BEFORE ME

on this the day of January 2024 and

Signed her name in my presence ADVOCATE, THIRUVALLUR

BEFORE THE HON’BLE PRINCIPAL

DISTRICT AND SESSIONS JUDGE AT
THIRUVALLUR

Tr.O.P.NO. of 2024

MRS.SHEEBA

…Petitioner

-Vs-

MRS.SASIKALA UDHAYAKUMAR

and Others

…Respondents
 6

AFFIDAVIT OF P.SHEEBA

M/S.ARULSELVAM ASSOCIATES
R.O.C.No.7553 of 2015/F2
A.Aravindan
Counsel for the Petitioner/Plaintiff
aravindanadvocate@gmail.com
(98418-09777)
BEFORE THE HON’BLE PRINCIPAL DISTRICT AND SESSIONS JUDGE AT
THIRUVALLUR

Tr.O.P.NO. of 2024

MRS.P.SHEEBA,
wife of S.Premkumar,
No.11/27, Perumal Kovil Street,
Rajanguppam, Chennai - 600 095. …Petitioner/Plaintiff
-Vs-

1. MRS.SASIKALA UDHAYAKUMAR,
wife of Late. Udhaya Kumar,
No.1, Ambattur Flats, Redhills Road,
Ambattur, Chennai - 600 053.
2. MRS.KALAISELVI,
wife of Late. Jegath Kumar,
No.2, First Floor, Rajalakshmi Apartments,
5th Street, 1st Cross Road,
Mahalakshmi Nagar, Madipakkam,
Chennai - 600091.
3. MRS.ANITHA,
wife of Senthil Kumar,
No.2, First Floor, Rajalakshmi Apartments,
5th Street, 1st Cross Road,
Mahalakshmi Nagar, Madipakkam,
 7

Chennai - 600091.
4. MRS.SARASWATHI,
wife of Late. A.N.Deva Kumar,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
5. MRS.LAKSHMI,
wife of Prathul,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
6. MR. SENTHIL KUMAR,
son of Late. A.N.Deva Kumar,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
7. MR.SIVAKUMAR,
son of Late. Udhaya Kumar,
No.1, Ambattur Flats, Redhills Road,
Ambattur, Chennai - 600053.

8. MR.VINOTHKUMAR LAL BAHADUR,

Son of Lal Bahadur,
No.8/41, Vaidhiyalingapuram,
Kurinjipadi, Cuddalore District
Pincode - 607302.
9. THE SUB REGISTRAR, AMBATTUR
Sathya Street, Ram Nagar,
Vinayagapuram, Ambattur,
Chennai - 600053.
10. THE DISTRICT COLLECTOR,
First Floor, Collectorate
Tiruvallur, Tiruvallur District,
Pincode - 602001. …Respondents/Defendants

IN THE MATTER OF THE ORIGINAL SUIT NO.194 OF 2023 ON THE FILE OF THE
HON’BLE DISTRICT MUNSIF COURT AT AMBATTUR

O.S.No.194 of 2023

MRS.P.SHEEBA,
wife of S.Premkumar,
No.11/27, Perumal Kovil Street,
Rajanguppam, Chennai - 600 095. …Plaintiff
-Vs-
 8

1. MRS.SASIKALA UDHAYAKUMAR,
wife of Late. Udhaya Kumar,
No.1, Ambattur Flats, Redhills Road,
Ambattur, Chennai - 600 053.
2. MRS.KALAISELVI,
wife of Late. Jegath Kumar,
No.2, First Floor, Rajalakshmi Apartments,
5th Street, 1st Cross Road,
Mahalakshmi Nagar, Madipakkam,
Chennai - 600091.
3. MRS.ANITHA,
wife of Senthil Kumar,
No.2, First Floor, Rajalakshmi Apartments,
5th Street, 1st Cross Road,
Mahalakshmi Nagar, Madipakkam,
Chennai - 600091.
4. MRS.SARASWATHI,
wife of Late. A.N.Deva Kumar,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
5. MRS.LAKSHMI,
wife of Prathul,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
6. MR. SENTHIL KUMAR,
son of Late. A.N.Deva Kumar,
No.3/325, 11th Street, Govinda Samy Nagar,
Madipakkam, Chennai - 600091.
7. MR.SIVAKUMAR,
son of Late. Udhaya Kumar,
No.1, Ambattur Flats, Redhills Road,
Ambattur, Chennai - 600053.
8. MR.VINOTHKUMAR LAL BAHADUR,
Son of Lal Bahadur,
No.8/41, Vaidhiyalingapuram,
Kurinjipadi, Cuddalore District
Pincode - 607302.
9. THE SUB REGISTRAR, AMBATTUR
Sathya Street, Ram Nagar,
Vinayagapuram, Ambattur,
Chennai - 600053.
10. THE DISTRICT COLLECTOR,
First Floor, Collectorate
Tiruvallur, Tiruvallur District,
Pincode - 602001. …Defendants
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PETITION FILED UNDER SECTION 22 AND 24 OF C.P.C FOR TRANSFER OF

SUIT

The Petitioner most respectfully state as follows:

I. NAME AND ADDRESS OF THE PETITIONER:

1. The Petitioner is P.SHEEBA, wife of S.Premkumar, Hindu, aged about 40 years, residing at
No.11/27, Perumal Kovil Street, Rajanguppam, Chennai - 600095. (within the jurisdiction
of the Hon’ble District Munsif Court at Ambattur).
The address for service of all notices and processes on the Petitioner that of her Counsel
M/S.ARULSELVAM ASSOCIATES, represented by A.Aravindan, T.Rajasekaran, S.Elumalai,
R.Honest, J.Nandhini, J.Suryaprakash and S.Kalpika Advocates, having office at New No.4,
Ramaiah Street, Shenoy Nagar, Chennai-600 030. Email: aravindanadvocate@gmail.com,
Phone No.044 - 26641187, Mobile: 9841809777 and P.Dinesh Kumar, Thiruvallur Bar
Association.
II. NAME AND ADDRESS OF THE RESPONDENTS:

2. The First Respondent is MRS.SASIKALA UDHAYAKUMAR, wife of Late.

Udhayakumar, Hindu, aged about 77 years, residing at No.1, Ambattur Flats, Redhills
Road, Ambattur, Chennai - 600 053. (within the jurisdiction of the Hon’ble District Munsif
Court at Ambattur).
3. The Second Respondent is MRS.KALAISELVI, wife of Late. Jegath Kumar, No.2, First
Floor, Rajalakshmi Apartments, 5th Street, 1st Cross Road, Mahalakshmi Nagar,
Madipakkam, Chennai - 600091. 600091. (within the jurisdiction of the Hon’ble Principal
District Munsif Court at Alandur).
4. The Third Respondent is MRS.ANITHA, wife of Senthil Kumar, No.2, First Floor,
Rajalakshmi Apartments, 5th Street, 1st Cross Road, Mahalakshmi Nagar, Madipakkam,
Chennai - 600091. - 600091. (within the jurisdiction of the Hon’ble Principal District
Munsif Court at Alandur).
5. The Fourth Respondent is MRS.SARASWATHI, wife of Late. A.N.Deva Kumar,
No.3/325, 11th Street, Govinda Samy Nagar, Madipakkam, Chennai - 600091. (within the
jurisdiction of the Hon’ble Principal District Munsif Court at Alandur).
6. The Fifth Respondent is MRS.LAKSHMI, wife of Prathul, No.3/325, 11th Street, Govinda
Samy Nagar, Madipakkam, Chennai - 600091. (within the jurisdiction of the Hon’ble
Principal District Munsif Court at Alandur).
 10

7. The Sixth Respondent is MR.SENTHIL KUMAR, son of Late. A.N.Deva Kumar,

No.3/325, 11th Street, Govinda Samy Nagar, Madipakkam, Chennai - 600091. (within the
jurisdiction of the Hon’ble Principal District Munsif Court at Alandur).
8. The Seventh Respondent is MR.SIVAKUMAR, son of Late. Udhaya Kumar, No.1,
Ambattur Flats, Redhills Road, Ambattur, Chennai - 600053. (within the jurisdiction of the
Hon’ble District Munsif Court at Ambattur).

9. The Eight Respondent is MR.VINOTHKUMAR LAL BAHADUR, son of Lal Bahadur,

No.8/41, Vaidhiyalingapuram, Kurinjipadi, Cuddalore District, Pincode - 607302. (within
the jurisdiction of the Hon’ble Principal District Munsif Court at Cuddalore).
10. The Ninth Respondent is THE SUB REGISTRAR, AMBATTUR, Sathya Street, Ram
Nagar, Vinayagapuram, Ambattur, Chennai, Tamil Nadu, 600053. (within the jurisdiction
of the Hon’ble District Munsif Court at Ambattur).
11. The Tenth Defendant is THE DISTRICT COLLECTOR, having office at First Floor,
Collectorate, Tiruvallur, Tiruvallur District, Pincode - 6020001. (Within the jurisdiction of
the Hon’ble District Munsif Court at Thiruvallur.)
The addresses for service of notices and summons on the Defendants are as stated above.

For the reasons stated in the accompanying affidavit, it is prayed that this Hon’ble Court may be
pleased to order withdrawal of the suit in O.S No.194 of 2023 from the file of the Hon’ble
District Munsif Court at Ambattur, and transfer the same to the Hon’ble II Additional District
Judge and Session Judge at Poonamallee with the direction to try the same along with the suit in
O.S.No.400 of 2022 in the same court of law at II Additional District and sessions Judge at
Poonamallee and pass any such orders suitable to the circumstance and thus render justice.

Dated at Thiruvallur this the day of January, 2024.

Counsel for Petitioner/Plaintiff

11

BEFORE THE HON’BLE PRINCIPAL

DISTRICT AND SESSIONS JUDGE AT
THIRUVALLUR

Tr.O.P.NO. of 2024

MRS.SHEEBA

…Petitioner

-Vs-

MRS.SASIKALA UDHAYAKUMAR

and others

…Respondents

PETITION FILED UNDER SECTION 22 AND 24

OF C.P.C FOR TRANSFER

OF SUIT

M/S.ARULSELVAM ASSOCIATES,
R.O.C.No.7553 of 2015/F2
A.Aravindan
Counsel for the Petitioner/Plaintiff
aravindanadvocate@gmail.com
(98418-09777)