to the first defendant through his first wife Saradambal. It is the case of the first appellant/plaintiff that his father, the first defendant, his father's brother Manikasamy and their father Venkatachala Udayar were members of the joint family properties in which the property described in A Schedule of the plaint was allotted to the plaintiff's father viz., first defendant. From and out of the income derived from A Schedule property, the B Schedule property was purchased by the plaintiff and defendants 2 and 3 in the name of the first defendant, father. Thus, A and B Schedule properties are the joint family properties in which the plaintiff, defendants 1 to 3 are entitled to equal share. However, when the plaintiff demanded for a share in the A and B Schedule properties, the first defendant evaded and avoided to partition the property, hence, the plaintiff sent a notice dated 17.06.1976 to effect division of all the family properties, for which a reply dated 07.06.1976 falsely claiming tht the joint family properties are sufficient to maintain the joint family and that the first defendant purchased the B Schedule property by borrowing funds from third parties. It was also stated that the plaintiff's mother namely Angammal is not the legally wedded wife of the first defendant and that she is a concubine. Further, the plaintiff and his sister Sankari are illegimate children of the first deffendant. Even as illegitimate children, the plaintiff is entitled to a share in the suit property and therefore, he filed the suit.
