In,

The court of principle civil judge,

(senior District) Gaya

Title suit no.- /2018

Sri Vikram Singh, s/o late Ram Kishore Prasad Narayan Singh R/o B/4-
45 Safdarjung enclave, 2nd floor, new Delhi-110029.................. Plaintiff

Vr’s.

1. Ajay singh, s/o late Ram Kishore Prasad Narayan Singh, R/o village-
Maksudpur Raj palace maksudpur, p.s.- Kijar sarai District Gaya, at
present resident.
2. Mata Bhagwati, the deity Sri Radha jee, Krishna jee, sri Tara ji,Vidya
ji, sri Ramji, sri Balram ji, sri Bajrangwali ji, and suraj bhagwan
installed in the temple which is part of the Maksudpur kitta through
alleged shebait namely Ajay Singh, s/o- late Ram Kishore Prasad
Narayan Singh, R/o village- Maksudpur Raj palace maksudpur, p.s.-
Kijar sarai District Gaya......................................................defendants

The above named plaintiff

begs to state as:-
1. That one Raja Chardeshwar Prasad Narayan Singh had no male issue
rather he died on 28/9/1941 leaving behind his widow Rani Deo Murat
Kuar and four daughters namely:
I. Janak Kishori Devi
II. Raj Kishori Devi
III. Krishna Kishori Devi and
IV. Girija Kishori Devi

out of them Janak Kishori Devi died inoscites as a widow and the said
Deo Murat Kuar died also on 29/06/1942.

2. That the said Krishna Kishori Devi w/o- Raj Kishor Prasad Narayan
singh also died leaving behind her two sons namely Jagat kishor Prasad
 Narayan Singh and Ram Kishore Prasad Narayan Singh both of them
died one after another and as such jugat kishore Prasad Narayan Singh
had left a son Krishna kishore singh, who died too subsequently leaving
behind his widow shashi singh and a daughter Divangi singh while the
said Ram Kishore Prasad Narayan Singh died leaving behind his two
sons, the plaintiff and defendant no.-1 and a daughter namely Mirja
Guleri widow of late S.S.Guleri.
3. That in order to clearify the relationship of the above narrated facts a
relevant genelogical table is given below here-in-under:-

Raja Chandeshwar Prasad Narayan Singh

Janak Kishori Devi Raj Kishori Devi Krishna Kishori Devi Girija Kishori Devi

( Issuless Widow ) Raj Kishori Prasad Narayan Singh

Jagat Kishor Prasad Narayan Singh Ram Kishor Prasad Narayan Singh

Krishna Kishor Singh

Sashi Singh Ajay Singh Vikram singh

Birendrahari Singh Prataphari Singh Raghubendrahari Singh

Kaushalendrahari Singh Yadhuvendhari Singh

4. That the said Raja chandeshwar Prasad Narayan Singh was admittedly
absolute owner in exclusive possession of the entire properties covered
under the estate of Maksudpur raj in the district of Gaya, Patna and Saran
of Bihar State but the said raja chandeshwar Prasad Narayan Singh was
very quasi man and fully devoted himself in religious jone and as such he
was great devotee of his ‘Kul-devta’ installing “Maa Kali” deity and also
constructed ‘Maa Maha Kalison’ temple with in the maksudpur kila in the
district Gaya.
5. That it is humbly submitted that by passage of time the said Raja
Chandeshwar Prasad Narayan Singh had executed his last ‘WILL’ and
testament relating to both movable and immovable properties of the said
estate of Maksudpur on 30/06/1929, and deducting his entire properties in
the name of “Maa Bhagwati” and the said “WILL” was written in
presence of emirant lawyer as well as Doctor as that very time. In the said
“WILL” it was cantended that in case after his death if no son was
adopted by his Rani Deo Murat Kuer, the said property will be managed
through his all female heirs but they did not yet as a shebait of the said
deity “MSS BHAGWATI”.
6. That it is an admitted fact even after the death of the said Raja
Chandeshwar Prasad Narayan Singh his wife Rani Deo Murat Kaur did
not adopt any male child and she died on 29/6/42 and her legal heirs and
successors subsequently they had always acted contrary to the interestnof
the said “Maa Bhagwati”.
7. That it may be humbly submitted further it was conditomal president to
maintain and up-keep of Rag-Bhog and other puja –path and other festiva
like annual periodical etc should be maintained from the income of the
property given to the said deity but in the long run the defendant no-1
created so many forged and fabricated document declaring himself as a
alleged shebait for the said Mata Bhagwati .
171/2000
8. That in the year 2000 a title suit no- /150/2000 was instituted
by the father of plaintiff and defendant no.-1, in the court of suj-judge –
VIth Gaya inthe name of Mata Bhagwati and just to safe guard the
interest in the properties given to the deities by or on behalf of the father
of defendant no.-1 for declaring the title in favour of the plaintiff deity in
respect of all most entire properties available of the Maksudpur estate at
that very time and the said title suit is still pending which was instituted
on 10/07/2000 and during the pendency of the said Ram Kishore Prasad
Narayan Singh died on .
9. That thereafter the defendant no.-1 filed an application for substitution to
represent the said deity “MATA BHAGWATI” as a alleged shebait
himself which was allowed on 10/12/2000 and the said suit is pending
against 228 persons, for declaring the title of the plaintiff deity in respect
of the entire properties mentioned in the plaint of the said title suit no.
50/17
/150/2000.
10.That to ascertain from the entire recital of the testator of the said “WILL”
dated 30/06/29 the intention of the testator is constructed the “WILL”
only not the Arpannama or deed of endorsement which can be gathered
from itself of the proper construction of the word use and no where it is
stated that the entire property of the maksudpur estate endored to the said
deity and there is no any contrary languages showing the said deed of
WILL is out and out of deed of endorment, no doubt the said Raja
Chandeshwar Prasad Narayan Singh had expressed his desire to distribute
the income of the estate into three parts and each daughters shall get
6000/- per year besides other amountwill go to the employee of the estate
out of the total income of the estate. Thus it would be clear the testator be
quethed his property to the said deity with a condition so the same is
conditional WILL however the said WILL dated 30/06/1929 has yet not
been probated and no probative value is attached with the same, however
the plaintiff is entitled to get the declaration of the said document as a
WILL only not any other nature of the deed like deed of ‘endorment’ and
for that reason no shebait was ever appointed for controlling and
managing the property of Maksud estate till today.
11.That it be further submitted that the said testor was alive till the year 1941
and incase the said deed of ‘WILL’ declaring in the form of himself a
deed of endorment then he had to make creation of the trustee in order to
protect and safeguard the property of the Maksudpur estate devoted to the
deity but it was never done in his life time and such surrounding
circumstances is enough for declaring the said deed of WILL not as a
deed of ‘endorment’ or appointed any shebaid for the same, more over
the said testator also given some properties to his all three daughter
referred above and also given to some of employee at that very time.
12.That from the submission made above it would be clear that the
defendants have no right to say that the said regd. deed of Will dt.
30/06/1929 is deed of ‘endorment’ instead of unprobated WILL by which
the entire Maksudpur estate property was never vested to the deity at any
point of time nor, the alleged shebait of defendant no.-1 has any right to
interfere in the property held by the legal heirs of the said testator by way
of the opration of Hindu Sucession Act and plaintiff has got every right to
suit for declaring the said regd. deed of WILL is absolutely in the nature
of WILL only and the said WILL is still unprobated and no probative
 values was ascertain and it was such has no legal identity for legal
importance.
13.That by reason of filing several suit which are still pending in several
places in as much as defendant no.-2 with the help of untoward persons
has executed several forged and fabricated documents for his wrongfull
gains by depriving the legal right of plaintiff with evil motive and design
against the plaintiff, hence the necessity of the suit.
14.That the cause of action for the suit arose on when the
defendant no.-1 has threatend to execute the deed in favour of some
unknown persons on. at vill-Maksudpur within p.s. Khizar
sarai, dist-Gaya with in jurisdiction of the court.
15.That the suit is valued at Rs. 10,00,000,00 for the purpose of jurisdiction
and court fee and the plaintiff on payment of fixed court fee worth of
Rs250/- only seeks the following.

Reliefs
a) That on and judication it be declared the alleged regd. deed of WILL dt.
30/06/1929 executed by Chandeshwar Prasad Narayan singh in favour of
“MATA BHAGWATI” and others deity with respect to entire properties
of the Maksudpur estate covered under schedule-I as fully described
below in the plaint.
b) Cost of the suit be awarded to the plaintiff.
c) Any other relief or reliefs if plaintiff is entitled to.