Suit for Possession -- Material Pleadings -- Plaintiff Must Plead Entitlement, Date of Dispossession, Mode of Dispossession, and Illegality of Defendant's Possession
For recovery of possession, plaintiff must plead and prove entitlement to property, manner of entitlement, specific date and mode of dispossession, and nature of defendant's possession establishing illegality. For perpetual injunction, actual possession on date of suit must be proved. Pleadings must contain sufficient particulars including detailed, specific averments with supporting documents. Absence of material pleadings on dispossession renders suit for recovery of possession non-maintainable.
