PLEADING FOR DECLARATION OF ADOPTION
- That the plaintiff is the natural born son of '__________' of address.
- That as no child was born to the defendant's husband even after 15 years of his marriage, he despaired of having one born to him and yearned to perpetuate his line by adopting a son to him.
- That the defendant's husband had made requests to the plaintiff's natural father for giving the plaintiff in adoption to him, the plaintiffs father agreed to the proposal and accordingly the plaintiffs father on gave the plaintiff in adoption to the defendant's husband who took him in adoption after performing the adoption rites of giving and taking and Datta hommam.
- That since then the plaintiff became the adopted son of the defendant's husband and was brought up in his family severing all connections with his natural family. The defendant's husband educated the plaintiff and gave him in marriage in due course.
- That the defendant's husband died on whereupon the plaintiff performed his Sudhi-Kriya.
- On the death of the plaintiff's father the plaintiff and the defendant have succeeded to his estate as the next heirs and have been in possession thereof.
- That on the ill advice of some village touts, the defendant challenged the plaintiffs status as an adopted son and filed objections to the plaintiff's application for mutating his name in place of his adoptive father in proceedings before the Revenue Court. The Revenue Court being unable to decide if he plaintiff is the adopted son of the defendant's husband directed the plaintiff to obtain a declaration from the Civil Court as to his status and so the plaintiff has been compelled to institute this suit.
- That the cause of action for the suit arose on when the defendant challenged the plaintiffs status as an adopted son within the jurisdiction of this Court. The declaration sought for is valued Rs. 200 and fixed Court-fee of Rs _____ are paid under Article 3A, Schedule 1 of the Court-fees Act, 1870.
Court Fees Act - Sch. 1, Articles 3A(iii).
(i) Let it be declared that the plaintiff is the adopted son of ____________
(ii) The cost of the suit is decreed in favour of the plaintiff.