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1. Mrs. Kumuda Sundaram,
W/o. Sundaram,
And 19 others «««««««. Plaintiff

Vs
Mr. Govindasamy Chettiar,
S/o. Samabandham Chettiar,
Thamaraipakkam Village,
Thiruvellur Dist. ««««««. Defendant-2.

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The Defendant above named respectfully state as follows:

1. The Defendant above named is Mr. Govindasamy Chettiar, Aged about

S/o. Samabandham Chettiar, Residing at Thamraipakkam Village,

Thiruvellur Dist.

2. The address for service of all notices and processes on the Defendant is that

of their Counsels M/s. M.Velmurugan, J.SenthamilArasu, R.Arunkumar and

P. Mathivanan at No.166, 1st Floor, Thambu Chetty Street, Parrys, Chennai-

104.

3. At the outset, the Defendants state that the present suit itself is not

maintainable as framed and is liable to be dismissed in limine. The Plaintiff

has miserably failed to disclose any semblance of legal right or cause of

action to bring this suit and the same is liable to be dismissed as frivolous,

vexatious and illegal. The Defendant denies all the allegation and averments

put forth in the Plaint and the accompanying petition except those that are

specifically admitted herein and puts the plaintiff to strict proof of the same.
4. The Defendant denies the averments in Para 1 and 2, real fact is the
Bolatchiamman Temple was established by the village people in the
common place and deity was made by the wooden and still date was
maintained by the village people by forming of committee. The Defendant
submit that in our village all the community people are in the committee and
they same was well known to the village people, the Plaintiffs discloses that
the committee formed without the knowledge of the Plaintiff as per the
Village customary practice the members are only be the residence of the
Thamaraipakkam village. The Defendant submits that the Plaintiff admitted
that they are not the residence of the Thamaraipakkam, as per the knowledge
of the Second defendant the Plaintiff are coming with the new story that they
are established the temple and the Moola Vigraham was founded in the
house site of the fore father of the Plaintiff, the second defendant state that
the deity was established by the all community of the village and the
Bolatchiamman was the Kula Daiyvam for the Mudaliar community and the
village people all are maintain the temple.

5.